We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our Company collects information from all end users of our services (the “Services”), including those who access some of our Services (“Members”) and/or those who may purchase Products (“Users”) (together referred to as “Users”).

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. In an effort to comply with changes in technology, and the adoption of new regulations and laws, we may need to change our Policy at some point in the future, in which case we'll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

Effective Date: July 30, 2023

Warmspace Private Limited, doing business as “Warmspace” (”Warmspace”, “we”, “our” and/or “us”) value the privacy of individuals who use our websites and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from Users of our Services. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

Please note that Warmspace’s Services are intended to facilitate live conversations among Users around specific topics. Warmspace employs Guided Conversation Flows to cultivate trust, foster meaningful conversations and increase engagement between Users. Warmspace does not provide professional advice, including medical advice or care.

Your Data Only For You

The data we collect from you is to give you a personalized experience. We do not record or store the conversations. They remain confidential to provide the safest space for you to connect with other Users.

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us.

Personal data is any information from or about an identified or identifiable person, including information that Warmspace can associate with an individual person. We may collect, or process on behalf of our User, the following categories of personal data when you use or interact with Warmspace products and services:

1. Registration Information. When you register to use our Services, we ask you for your preferred name and email address.
2. Sign up Information. When you sign up to our Services, we ask for your first name, last name and email. Optionally, you can choose to provide us with your preferred name, gender and phone number.
3. Information You Provide When Using Our Services. Depending on which Services you choose to access, we may ask you specific questions that are relevant to those Services. For example, we may ask you how you are feeling on a scale of 1 to 10 before and after accessing our Services and whether you would recommend the Services to a friend on a scale of 1 to 10. Optionally you may also leave video, audio or written feedback on the Services. This information helps us better provide you with the Services. If you sign up for Flows, Sessions or Gatherings you will view these Services “synchronously”, meaning in real time, with other Users. All our Services and interactive experiential topics are not individual therapy and are intended solely to present generalized subject matter on the topic. Your username (also referred to as “preferred name” or “first name” or “last name”), which you will select, will be visible to Administrators of your company when you participate in any of our Services.
4. Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our customer support team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
5. Careers. If you apply for a job with us, you may submit your contact information and resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. It may also be possible to apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.
6. Payment Information. If you make a purchase through our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

B. Information We Collect When You Use Our Services.

1. Location Information. When you use our Services, we infer your general location information, for example by using your internet protocol (IP) address.
2. Device Information. We receive information about the device and software you use to access our Services, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations and device identifiers.
3. Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, and the dates and times of your visits.
4. Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as, but not limited to, analytics, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
5. Audio/Video Information. For some of our Services, we work with a third-party partner to facilitate internet videoconference between you and the other users and teachers providing the Service. We receive information about these communications, such as the date and time of the internet videoconference, who attended, the duration of the video conference and a transcript of the chat. We do not record or receive a recording of the videoconference (either video or audio). However, it is possible a User could violate this policy and record the videoconference through a secondary means, such as an iPhone video. It is also possible that your videoconference could be viewed by others with access to the other users’ device where the videoconference is being streamed.
6. User Feedback. We may ask you to voluntarily participate in a survey to rate and review our Services. If you voluntarily participate in our survey, we will not share a quote from your review without your permission. We may ask whether you permit us to use a quote from your survey on our website or other platforms where we advertise the Services.

C. Information We Receive from Third Parties

1. Information from third party services. If you choose to link our Services to a third-party account, we may receive information about you. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options available in our Terms of Service.

D. How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services, including scheduling the Services;
• To personalize your experience on our Service such as by providing tailored content and recommendations;
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• To facilitate the connection of third-party services or applications, such as social videoconferencing and scheduling appointments;
• For marketing purposes if you complete our voluntary survey;
• To facilitate transactions and payments;
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our TOS or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

E. How We Share the Information We Collect:

1. Warmspace Staff. Within our organization, access to your data is limited to those persons who require access in order to provide you with the Services you purchase from us, to contact you, and to respond to your inquiries, including requests for refund. Those staff members may be on teams such as: marketing, community, development, sales, customer support, finance. Employees only have access to data that is relevant to their team, on a “need to know basis”.
2. Affiliates. We may share any information we receive with our affiliates (if any) for any of the purposes described in this Privacy Policy.
3. Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
4. Marketing. We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes, unless we have your permission.
5. Analytics Partners. We use analytics services such as Google Analytics and Meta to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/ You can learn more about Meta’s practices by visiting: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0. We abide by Google’s and Meta’s Data Use Restrictions. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, people you follow, purchases you make, your comments, any content you post, and the dates and times of your visits.
6. Sharing Between Users. When you use the Services, the information you are able to share with other Users is limited. When you participate in a Flow, Session or Gathering, you may share questions and comments that will be visible to the group, and may participate via audio. Your username, which you will select, will be visible to other Users in your Warmspace session. If you choose to turn on your camera during a Warmspace session, other Users will also be able to see your video image.

As Required By Law and Similar Disclosures, we may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

F. Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or if we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

G. Consent. We may also disclose your information with your permission.

H. Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

I. Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. An exhaustive list of those third parties and a link to their terms of service are included in our TOS. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

J. Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

K. Children’s Privacy

You must acknowledge you are over 18 to use the Services. We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

L. International Visitors

Our Services are hosted in Amsterdam, the Netherlands. If you choose to use the Services from other regions of the world with laws governing data collection and use that may differ from General Data Privacy Regulation (GDPR), then please note that you are transferring your personal information outside of those regions to the Netherlands for storage and processing. Also, we may transfer your data from the Netherlands to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

M. Copyright and Intellectual Property Protection

1. DMCA Notification. We comply with the provisions of the Copyright Act in Singapore. If you have an intellectual property rights-related complaint about material posted on the Service, you may contact us at [email protected].
2. Content of Notification. Any notice alleging that materials hosted by or distributed through the Service infringe intellectual property rights must include the following information:

• an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other right being infringed;
• a description of the copyrighted work or other intellectual property that you claim has been infringed;
• a description of the material that you claim is infringing and where it is located on the Service;
• your address, telephone number, and email address;
• a statement by you that you have a good faith belief that the use of the materials on the Service of which you are complaining is not authorized by the copyright or intellectual property owner, its agent, or the law; and
• a statement by you that the above information in your notice is accurate and that, under penalty of perjury, you are the copyright or intellectual property owner or authorized to act on the copyright or intellectual property owner’s behalf.

3. Repeat Infringers. Warmspace will promptly terminate the accounts of member that are determined by Warmspace to be repeat infringers.

N. General Data Privacy Regulation (GDPR)

The GDPR takes effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.

If you are a resident of the European Economic Area (EEA), or are accessing this Site from within the EEA, you have certain rights with respect to your data. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to [email protected].

1. Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
• In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
  

2. Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:

• Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
• Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

3. Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

4. Data Controller and Data Protection Officer

Your personal data collected by Company is controlled by Warmspace’s Data Protection Officer is located at the same address and can also be reached by email at [email protected].

5. Update Your Information or Pose a Question

You can update your account and profile information through your profile settings. If you have questions about your privacy on the Services or this privacy policy, please contact us at [email protected].

O. Prohibited Conduct

BY USING THE SERVICE, YOU AGREE NOT TO:

1. use the Service for any illegal purpose or in violation of any local, state, national, or international law;
2. use the Service for discussing topics outside of the topic recommended by the Service, including but not limited to conspiracy theories, content that promotes, bashes, and discredits specific organizations or movements, hate speech or discrimination of any kind;
3. harass, threaten, demean, embarrass, bully, make romantic advances, offer sex, or otherwise harm any other member of the Service, including but not limited to by using slurs, intentional use of derogatory language, explicitly violent language, threats or implied threats to other members, and disparaging comments toward or about any members;
4. share or display nudity that is sexually explicit, make comments sexual in nature, contain sexual references, have sexual undertones, and/or sexually suggestive;
5. violate, or encourage others to violate, any right of a third party, including by infringing or misappropriating any third-party intellectual property right;
6. interfere with security-related features of the Service, including by: (a) disabling or circumventing features that prevent or limit use or copying of any content; or (b) reverse engineering or otherwise attempting to discover the source code of any portion of the Service except to the extent that the activity is expressly permitted by applicable law;
7. interfere with the operation of the Service or any member’s enjoyment of the Service, including by: (i) uploading or otherwise disseminating any virus, adware, spyware, worm, or other malicious code; (ii) making any unsolicited offer or advertisement to another member of the Service; (iii) collecting personal information about another member or third party without consent; or (iv) interfering with or disrupting any network, equipment, or server connected to or used to provide the Service;
8. perform any fraudulent activity including impersonating any person or entity, claiming a false affiliation, accessing any other Service account without permission, or falsifying your age or date of birth;
9. record, photograph, or screen-capture any portion of a Session or a Gathering session or any other event;
10. sharing any personal information about other members learned during a Session or Gathering or other event, including but not limited to names, locations, details from stories that jeopardize the anonymity of members, and any other identifying information;
11. sell or otherwise transfer the access granted under these Terms or any Materials (as defined in Section 6) or any right or ability to view, access, or use any Materials; or
12. attempt to do any of the acts described in this Section or assist or permit any person in engaging in any of the acts described in this Section.

P. Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Q. Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].