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Privacy Policy

DATE OF LAST REVISION: January 10, 2024

Welcome to the Privacy Policy of HqO, Inc ("HqO", "we", "us" and/or "our"). This Privacy Policy is provided by HqO and has been created to provide information about how we collect and process information through the HqO website ("the Site"), mobile applications ("App"), and services provided by us (the "HqO Services"), as well as from our business customers who use our business services (the "HqO Business Customer Services"). This Privacy Policy is divided into 3 parts depending on what type of user of the HqO services you are:

  1. Site visitors, who are individuals visiting our website to learn more about HqO, in which case the "HqO Privacy Policy for Site Visitors" applies to you;
  2. End-Users of HqO Services offered by HqO customers, in which case the "HqO Privacy Policy for End Users of HqO Services Offered by HqO Customers" applies to you; and
  3. HqO business customers, in which case the "HqO Privacy Policy for HqO Business Customers" applies to you

 

Data Privacy Framework Policy Updates

HqO and its affiliates comply with the requirements of the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce (collectively, the DPF). HqO has certified to the U.S. Department of Commerce that it adheres to the DPF Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom (and Gibraltar), and/or Switzerland to the United States. If there is any conflict between the terms in this DPF Policy or another applicable privacy policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework and to view HqOs certification, please visit: https://www.dataprivacyframework.gov.

This DPF Policy applies to personal information within the scope of HqOs DPF certification, which covers the following categories of information:

  • Personal information regarding current, former and prospective partners, principals and employees for the purposes of operating and managing HqO, performing human resource administration and maintaining contact with individuals.
  • Personal information regarding current, former and prospective clients and their personnel, customers, or other data subjects for the purposes of delivering HqO services, maintaining ongoing relationships and performing business development activities.
  • Personal information regarding our suppliers, service providers, and other third parties, and their personnel for the purposes of managing and administering HqOs business relationships with such third parties.

 

Accountability for Onward Transfers Consistent with the DPF Principles

HqO may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individuals personal information to third parties under one or more of the following conditions:

  • The disclosure is to a third party providing services to HqO, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the DPF Principles. To the extent provided by the DPF Principles, HqO remains responsible and liable under the DPF Principles if a third party that it engages to process personal information on its HqO | HqO's Data Privacy Framework Policy 2 behalf does so in a manner inconsistent with the DPF Principles, unless HqO proves that it is not responsible for the matter giving rise to the damage;
  • With the individuals permission to make the disclosure;
  • Where required to the extent necessary to meet a legal obligation to which HqO is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation;
  • Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims. Individual rights Individuals whose personal information is covered by this DPF Policy have the right to access the personal information that HqO maintains about them as specified in the DPF Principles. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the DPF Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individuals privacy, or where the rights of persons other than the individual would be violated). Individuals may also have the right to limit the use and disclosure of their personal information (opt out) under certain circumstances, such as marketing. Requests to access, correct, amend, delete, or limit the use and disclosure of personal information (opt out) may be submitted using our request form.

 

Security

HqO takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.

Enforcement in compliance with the DPF Principles

HqO commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our DPF Policy should first contact HqO. HqO has a policy of responding to individuals within forty five (45) days of an inquiry or complaint. If an individual has an unresolved complaint or concern that is not addressed satisfactorily, that individual may contact our U.S. based third party dispute resolution provider (free of charge). If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution TRUSTe (free of charge) here. If the dispute involves human resources personal information or information collected in the context of an employment relationship, we will cooperate with the competent EU, UK, or Swiss data protection authorities and comply with the advice of such authorities. You may have the option to select binding arbitration under the EU-U.S. Data Privacy Framework Panel for the resolution of your complaint under certain circumstances. HqO is also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Modifications- HqO may update this DPF Policy at any time by publishing an updated version here, however we will not update this DPF Policy in contravention of the DPF Principles.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, HqO, Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioners Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship. This applies to parts A, B, and C of the Privacy Policy.

HqO Contact Information:

No matter what type of user you are, if you have any questions about HqO's Privacy Policy or the information practices of the HqO Services, or wish to exercise any of your data protection rights as described in the sections below, please email [email protected].

If you are a resident of the United Kingdom or European Economic Area, please note that we have appointed an EU data protection representative. If you have any questions, please contact HqO's Compliance Team at [email protected].

 

 

(A) HqO Privacy Policy for Site Visitors

HqO, Inc., is the controller of your information collection through your use of our Site pursuant to the EU General Data Protection Regulation 2016/679, as applicable.

Please read this section of Privacy Policy to understand how we may process your information via your use of our Site. If you do not agree with how we process your information, please do not use the Site.

(B) HqO Privacy Policy for End-Users of HqO Services Offered by HqO Customers

To the extent that you are providing information via the mobile applications ("App") in connection with your occupation or use of a building or particular physical space ("End-Users") in which you live, visit or work, please note that HqO processes this information on behalf of our customers who are building or space owners ("Customer Data") to provide HqO services, including access to the HqO Platform and Tenant Experience applications (the "HqO Services") to you as an App End User. We are a processor when we process Customer Data, our customer is the data controller. This Privacy Policy explains the information collected from and about you as an End User of the App.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, HqO, Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioners Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship. This applies to parts A, B, and C of the Privacy Policy.

Please read this Privacy Policy to understand how we and our Customers (together referred to herein as "we") may process your information via your use of the HqO Services. If you do not agree with how we process your information, please do not use the HqO Services.

(C) HqO Privacy Policy for HqO Business Customers

If you are a business customer of HqO, HqO, Inc., is the controller of your information collected from and about you as part of our business customer services (HqO Business Customer Services).

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, HqO, Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioners Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship. This applies to parts A, B, and C of the Privacy Policy.

Please read this Privacy Policy to understand how we may process your information via your use of our HqO Business Customer Services. If you do not agree with how we process your information, please do not use the HqO Business Customer Services. If you are a business customer that also uses the HqO Services through our App, or that uses our Site, please also see the privacy policies relevant to those services.

Please read this Privacy Policy to understand how we may process your information via your use of our HqO Business Customer Services. If you do not agree with how we process your information, please do not use the HqO Business Customer Services. If you are a business customer that also uses the HqO Services through our App, or that uses our Site, please also see the privacy policies relevant to those services.

Schedule I
Affiliates of HqO, Inc.

  • HqO UK Limited (UK)
  • Office App Limited (UK)
  • Leesman Limited (UK)
  • Office App (Netherlands)