Privacy policy and TC

Opus Privacy Policy

Introduction

We are Opus Nordic AB, a limited company registered in Finland, operating under business id: 3133530-5 with our registered address at Kapteenintie 17, 00890, Helsinki, Finland. (we,us orour).

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use the Opus mobile application software (App) and tell you about your privacy rights and how the law protects you.

This policy (together with our end-user licence agreement (EULA)) applies to your use of the App once you have downloaded and registered the App onto your mobile telephone(Device).

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

• Important information and who we are

• The data we collect about you

• How is your personal data collected?

• How we use your personal data

• Disclosures of your personal data

• International transfers

• Data security

• Data retention

• Your legal rights

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of the App.

The App is not intended for use by children below the age of 16 years old and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

We are the controller and responsible for your personal data. By this we mean that we determine the purposes for which and the manner in which your personal data is, or is to be, processed.

Contact details

If you have any questions about this privacy policy, our privacy practices or want to submit a request to exercise your legal rights, please contact the Opus team using the details set out below:

Names of contact person: Christian Ehrstrom.

Email address: christian@opusnordic.com

Postal address: Kapteenintie 17, 00890 Helsinki, Finland

Telephone number: +358400236851

You have the right to make a complaint at any time to the to the legal authorities in Finland (ICO), However, we would appreciate the chance to deal with your concerns before you approach the governmental authorities so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 20th October 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The App will include links to third-party websites, plug-ins and applications (including Facebook). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the App, we encourage you to read the privacy policy of every website or application you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data- includes first name, last name, username or similar identifier, date of birth, gender, photographs that you use for display photos, and social media profiles.

Contact Data- includes email address, telephone numbers, company name

Device Data- includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.

Content Data- includes your account biography, information stored on your Device, including friends' lists, login information, photos, videos or other digital content.

Profile Data -includes your username and password, history, your interests, preferences and feedback.

Usage Data- includes details of your use of the App including, but not limited to, traffic data and other communication data and the resources that you access.

Marketing and Communications Data- includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Location Data - includes your current location disclosed by GPS technology.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our App). In this case, we may have to cancel your registration to the App but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email). It includes information you provide when you download or register to use the App, search for the App, share data via the App's social media functions, and when you report a problem with the App. If you contact us, we will keep a record of that correspondence.

• Information we collect about you and your device.Each time you use the App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.

• Location Data.We also use GPS technology to determine your current location and we will ask for your consent in order for your data to be used for this purpose. If you do not provide your consent for this, you will be unable to use the App. Once you have provided your consent, you can withdraw your consent at any time by disabling Location Data in your settings.

• Information we receive from other sources including third parties. We will receive Device, and Usage Data from analytics providers such as Google Inc., based outside of the EU.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

This does not apply to any advertisements or marketing displayed to you within the App, which are automatically displayed. You have the absolute right to withdraw this consent, please see [your legal rights] below for further information.

We use cookies and/or other tracking technologies to distinguish you from other users of the App or Appstore and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where you have consented before the processing;

• Where we need to perform the contract we are about to enter into or have entered into with you;

• Where it is necessary for our legitimate interests(or those of a third party) and your interests and fundamental rights do not override those interests; and/or

• Where we need to comply with a legal obligation.

You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data may also include sharing your contact information with our workspace partners in order to make your experience with Opus better and help facilitate finding permanent office spaces or memberships. Your contact information data may also be used in sales purposes from Opus Nordic AB partners.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

To install the App and register you as a new App user -

(a) Your consent

(b) Identity

(d) Device

To enable full functionality of the App e.g. (a) Your consent (b) Performance of a contract with you

(a) Identity

(b) Location

(d) Profile

(e) Device

(f) Usage

(g) Content

To determine which advertisements to display to you within our App -

(a) Your consent

(b) Identity

To monitor the characteristics of our user base -

(a) Your consent

(a) Identity

To manage our relationship with you including notifying you of changes to the App -

(a) Your consent

(b) Performance of a contract with you

(d) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions or privacy policy)

(e) Identity

(f) Contact

(g) Profile

To administer and protect our business and this App including troubleshooting, data analysis and system testing -

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

(b) Identity

(d) Device

To deliver content and advertisements to you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the App -

(a) Consent

(b) Necessary for our legitimate interests (to develop our App and grow our business)

(d) Contact

(e) Device

(f) Content

(g) Profile

(h) Usage

(i) Marketing and Communications

(j) Location

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may also share your personal data with the parties set out below for the purposes set out in the table in above. If any of these organisations are based, or have group or affiliated companies that are based, outside of the European Economic Area, then section 6 below sets out the basis on which your personal data is transferred to them.

If you require further information on how our third parties are processing your personal data, we recommend that you consult their privacy policies or contact them directly.

• CloudStrap AD

"SashiDo" is a product of CloudStrap AD, a company registered and based in Bulgaria. We use the SashiDo product for cloud-based data storage. See section 7 for further details.

https://www.sashido.io/policies.html#privacy-policy

• Google Inc.

Google is a company incorporated and registered in the USA. We use analytic services provided by Google in the management of the App.

You can access Google’s terms and conditions and privacy policy on its website.

We may also share your personal data with other third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Some of the third parties identified in section 5 above are based outside the European Economic Area (EEA), or have group or affiliated companies based outside of the EEA, so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

All information you provide to us is stored on servers hosted by SashiDo. The servers are based in Bulgaria and Germany.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

Certain services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In some circumstances you can also ask us to delete your data see [your legal rights] below for further information.

If you delete your account, we will delete all of your personal data within 28 days following the deletion of your account, unless: (a) we reasonably believe it is necessary for us to retain your personal data for the reasons outlined above, or (b) you have already asked us to delete or remove personal data where there is no good reason for us continuing to process it.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

• Right to object to automatic profiling and monitoring

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by emailing us at christian@opusnordic.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

AUTOMATED PROFILING AND MONITORING

Automated profiling and monitoring is the making of a decision, about an individual, based solely on automated means without any human involvement.

LAWFUL BASES

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with access to our App. We will advise you if this is the case at the time you withdraw your consent.

Object to automated profiling and monitoring. You have an absolute right to withdraw your consent to us processing your personal data for the purposes of determining which advertisements to display to you. We rely on your explicit consent to profile you in this way. If you wish to withdraw your consent, we will not be able to provide you with access to our App.