Convene Privacy Notice

Last Updated: September 10, 2020

SCOPE

This Privacy Notice applies to personal information processed by Sentry Centers Holdings LLC, d/b/a Convene (“Convene,” “we,” “us,” and “our”) in our business, as collected from our website(s) (each a “Site”), mobile application (the “App”), virtual event services, Convene properties, and related online or offline offerings (collectively, the “Services”).

PERSONAL INFORMATION WE COLLECT

When you use our Services, we may collect the following categories of information:

Information You Provide to Us.

Contact Information including your name, email address, phone number, and other information.

Verification Information including a photo or government issued ID and your date of birth.

Professional Information including your company name, title, role, team, and other related information. 

Preference Information including dietary restrictions or other information you have shared with us.

Payment Information including your payment card details or other financial information necessary to facilitate a transaction you request.

Convene Wi-Fi. If you use one of the Wi-Fi networks in one of Convene’s properties, we will collect personal information from you to log you on to the network, including your name and email address. We may also collect information about your use of the Wi-Fi, such as the web pages you visit, your MAC or IP address, and your inferred location while using the Wi-Fi.

Email Calendar Information. If you choose to integrate your email calendar with Convene’s room scheduling software, we will collect information regarding the rooms you book.

Communications with Us. We may collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, sign up for our newsletter, request customer or technical support, or otherwise communicate with us.

Customer Service and Support. If you call or otherwise interact with Convene’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes. 

Interactive Features. Convene may offer interactive features such as commenting functionalities, chat services, collaboration tools, review forums, and social media pages. Convene and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.

Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Convene and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV, cover letter, or other information to us, we will collect and process the information you provide to assess your suitability, aptitude, skills, and qualifications for employment with Convene.

Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

Information We Collect Through Your Use of the Services.

We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off your IP address), Internet service provider, pages that you visit while using the Services, analytics and details about your activities when attending one of our virtual events, and other information about how you use the Services. Information we collect may be associated with your account and the devices you use.

Cookies, Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.

●      Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

●      Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Analytics. We may use Google Analytics and other service providers to collect information regarding user behavior and user demographics on the Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s processing of data generated by your use of the Services by visiting http://tools.google.com/dlpage/gaoptout.

BLE Beacons. If configured properly, our App may include the capability to read and process Bluetooth (BLE) “beacons.” “Beacons” are small Bluetooth-enabled devices that may be placed throughout Convene properties that emit a unique signal that our App can detect and process.

When the App on your mobile device detects a BLE beacon, we will collect your mobile identifier (e.g., IDFA or Ad Id), the location data and metadata associated with the BLE Beacon signal (e.g., the known location and ID of the BLE beacon detected, the App’s latitude/longitude coordinates, and the date and time the BLE beacon was detected), and information about your mobile device such as the device type, model and operating system version, device language, mobile carrier, device name, device processes, device battery state, device speed, and current IP address.

Please note that in order for our App to detect and process BLE beacons, you must have: (i) the App open on your mobile device; (ii) Bluetooth enabled on your mobile device; and (iii) Location Services enabled for the App.

To opt-out of our collection of BLE beacon signals using the App, disable your mobile device’s Bluetooth capabilities and/or Location Services for the App.

If you have any questions about our use of BLE beacons, please contact us as set forth below.

CCTV. Some of Convene’s properties may have CCTV installed to protect the safety of Convene employees, members, guests, and properties. In addition, we may also use CCTV footage to improve our products and Services, including to analyze how individuals navigate and utilize Convene spaces.

Recordings at Virtual Events.  If you use our Services to attend a virtual event, the virtual event buyer may record certain audio and/or video footage which may include your personal information.

De-Identified and Aggregated Information. When you visit Convene properties, we may generate and/or collect de-identified and/or aggregated information from your use of the Services, including information about how individuals navigate and utilize Convene properties. For example, we may place sensors in rooms that inform us when an individual has entered or exited a room. De-Identified and/or aggregated information is not personal information.

Information from Other Sources.

Third Party Organizations. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as a social networking service or a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings.

Convene Customers. We may receive personal information from our customers in the form of an attendee, invitee, or employee list. Our use of this information may be governed a separate contract with our customer, but typically it is used to facilitate your access to and enjoyment of Convene properties and events.

Verification Information. Building management or security in some of Convene’s properties may require you to provide personal information (such as a photo or government issued ID, and/or your date of birth) and may use the information or a copy thereof to produce a badge or other identification for you to use to gain access to and while in the building. Convene does not control or otherwise participate in the building’s collection of verification information by building management and/or security. If a copy of this information is provided to Convene, we will use it in accordance with this Privacy Notice.

HOW WE USE YOUR INFORMATION

We process personal information for a variety of business purposes, including:

To Provide the Services, Products, or Information Requested.

  • Perform our contract with you;

  • Manage your account and information;
  • Allow you to register for events;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of our Services; and
  • Answer requests for customer or technical support.

Administrative Purposes.

  • Measure interest and engagement in the Services;
  • Improve our products and Services;
  • Develop new products and services;
  • Ensure internal quality control;
  • Verify individual identity;
  • Communicate with you about your account, activities on the Services and policy changes;
  • Process your payment card information and/or other payment methods for products or services purchased;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms of Service; and
  • Comply with our legal obligations.

 

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

De-identified and Aggregated Information Use.  We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified and/or aggregated trends, reports, or statistics. De-identified and/or aggregated information is not personal information.

Technologies. Our uses of such Technologies fall into the following general categories:

●      Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;

●      Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

●      Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services and keeping track of your specified preferences or past pages viewed;

●      Advertising or Targeting Related. We may use first-party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites.

Other Uses. Convene may use personal information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention. In addition, Convene may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

HOW WE DISCLOSE YOUR INFORMATION

We Use Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v) customer service activities; and (vi) the provision of IT and related services.

Affiliates. We may share personal information with our affiliated companies.

Customers. If your use of our Services is based on a contract we have with our customer (e.g., your employer, a landlord for whom we manage a physical space, or an event buyer that is using Convene to host an event), we may share information about your use of our Services with the relevant customer(s). For example, if you use our workspaces under a contract we have with your employer or an organization with which you are affiliated, we may provide information about your use to your employer and/or the organization with which you are affiliated. Similarly, Convene provides its event services so that you can interact with event buyers. If you attend a virtual event or an event at one of our physical spaces, we may provide your contact information and information about your attendance (including analytics about your activities in the case of virtual events) to our customer that organized the event.

Once your personal information has been shared with our customer, it will also be subject to our customer’s privacy policy. Please note that we do not control and we are not responsible for our customer’s processing of your personal information.

Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide relevant personal information to business partners with whom we jointly offer products or services.

Building Management and Security. In some cases, we are required to share your personal information with building management and/or security at Convene properties to facilitate your access to the building.

Interest-Based or Personalized Advertising. Through our Services, Convene may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other countries.

YOUR CHOICES.

General. You may be able to opt out of certain uses of your personal information. Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

Mobile Devices. We may send you push notifications through the App. You may opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect location-based information when you use the App. You may opt-out of this collection by changing the settings on your mobile device.

To opt-out of our collection of BLE beacon signals using the App, disable your mobile device’s Bluetooth capabilities and/or disable Location Services for the App.

Technologies and Personalized Advertising. If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits.  Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

INDIVIDUAL RIGHTS IN PERSONAL INFORMATION

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict or object to our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by Convene, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below. 

We will process such requests in accordance with applicable laws. To protect your privacy, Convene will take steps to verify your identity before fulfilling your request.

DATA RETENTION

We retain the personal information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional use or disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an e-mail to you.

THIRD PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Convene has collected about them and whether Convene disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Convene

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

 

•   Service providers

•   Event buyers and participants you share or interact with

•   Advertising networks

Personal information categories listed in Cal. Civ. Code § 1798.80(e)

•   Service providers

•   Event buyers and participants you share or interact with

Commercial information

•   Service providers

•   Event buyers

Internet or other electronic network activity

•   Service providers

•   Event buyers and participants you share or interact with

•   Advertising networks

Sensory data

•   Service providers

•   Event buyers and participants you share or interact with

Professional or employment-related information

•   Service providers

•   Event buyers and participants you share or interact with

Inferences drawn from other personal information to create a profile about a consumer

•   Service providers

•   Event buyers

•   Advertising networks

 

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Convene does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification. When you make a request under the CCPA, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include verifying your email address or other information you have provided to us. 

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at:

Convene

Attention: Legal Affairs

101 Greenwich Street, 5th Floor

New York, NY 10006

privacy@convene.com

1 (800) 586-1753