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Effective Date of Current Policy: September 21, 2022

European Privacy Addendum


UK and European Economic Area Privacy Notice

If you are a resident of the United Kingdom (UK) or the European Economic Area (EEA), the following additional UK/EEA-specific provisions apply to our processing of your personal information. Knotel may provide services under its Knotel brand name. For UK/EEA residents, the provisions of this UK/EEA Addendum prevail over any conflicting provision in our Knotel Privacy Notice (Privacy Notice).

Information We Obtain

We may collect, use, store and transfer certain personal information in order to provide services, or to use our websites or our apps, such as your IP address, physical address, phone number, date of birth. For a complete list of the categories of personal data we collect and how we collect this personal data, please see the Information We Collect section in our Privacy Notice. Where such information is required, we may be unable to provide you with our services unless you provide us with this information.

As you interact with our website or app, we will automatically collect technical personal data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. If you disable or refuse cookies, please note that some parts of our website/app may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookies section below.

We do not engage in automated decision-making, including profiling.

How We Use the Information We Obtain

The legal bases for which we collect, use, transfer or disclose your personal information include (i) where we have your consent, (ii) where we need to perform the contract we are about to enter into or have entered into with you, (iii) where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests, and (iv) where we need to comply with a legal obligation.

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. The purposes for which we process your personal information are systematically included in the How We Use the Information We Gather section in the Privacy Notice. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

If we request your consent, we will inform you of the intended purposes for which your information will be processed. Please note that if you choose to withdraw your consent, you may not be able to participate in or benefit from our programs, services and initiatives for which you provided consent.

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 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.

Disclosures of your Information

To learn more about the categories of third parties to who your personal information is disclosed, see the How We Share Personal Information section in the Privacy Notice. 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.

Data Retention

All personal information is maintained according to our corporate retention schedule. Your personal information will not be stored for longer than necessary for the purposes for which they were collected, 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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will take into account the length of time your personal data is required to:

• Continue to develop, tailor, upgrade, and improve our Services;

• Maintain business records for analysis and/or audit purposes;

• Comply with record retention requirements under the law;

• Defend or bring any existing or potential legal claims; or

• Address any complaints regarding the Services.

In some circumstances you can ask us to delete your data: see the Your Rights section below for further information.

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.

Your Rights

You have: (i) the right to access your personal information maintained by us; (ii) the right to correct inaccuracies in that information; (iii) the right to request the transmission of the personal information you have provided to us to you or another company, (iv) the right to object to any uses or disclosures of your personal information, (v) the right to withdraw your consent in relation to our processing of your personal information based on your consent, (vi) the right to request deletion of your personal information and (vii) the right to request that we restrict processing of your personal information.

You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before Knotel is able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact us using the contact information provided above in the How to Exercise These Rights or Identity of Controller section. In all cases, you have a right to file a complaint with the relevant Data Protection Authority (DPA) (to find your relevant DPA and their contact details, please see the list at: https://www.iptiq.com/european-data-protection-authorities.html). We would, however, appreciate the chance to deal with your concerns before you approach your DPA, so please contact us in the first instance.

We try to respond to all data subject 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.

International Data Transfers

We may transfer your personal information to countries outside of the EEA/UK (for example, to other companies within the same group of companies as Knotel or to external third parties based outside of the EEA/UK). Where these transfers are to countries that have not been found by United Kingdom regulators or the European Commission to provide adequate protection, such as the United States, Knotel takes necessary contractual measures to ensure that your personal information receives an adequate level of protection (including, for example, standard contractual clauses). For further information about Knotel’s international data transfer practices, and to consult the said contractual measures, please contact us using the contact details in the Contact Us section above.

Identity of Controller

Knotel Holdings, LLC, whose mailing address is 125 Park Avenue, New York, New York 10017, is the data controller for our Websites. You can contact us at legal@knotel.com.

Cookies

Our website and app use cookies to distinguish you from other users of our website/app. This helps us to provide you with a good experience when you browse our website/app and also allows us to improve our site/app.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can see what these are in our Cookie pop up on the website.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). You can see what these are in our Cookie pop up on the website.

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.] You can see what these are in our Cookie pop up on the website.


Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

Google

Facebook

To deactivate the use of third party advertising cookies, you may visit the page on our website for managing the use of these types of cookies [HERE].

You can choose which analytical, functionality and targeting cookies we can set by [ clicking this link and selecting to turn these cookies off].

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.