Privacy Policy

01 Privacy statement

At Qemera Global LLC ("Company", "we" or "our"), we respect and protect the privacy of visitors to our website ("Site"), and our customers who use our services ("Services") offered on the Site. Qemera maintains a strict policy to ensure the privacy of our Visitors and Customers (as further defined below). This policy ("Privacy Policy") describes the types of information we may collect from you and our practices for how we collect, use, maintain, protect, and disclose such information. This Privacy Policy also includes a description of certain rights that you may have over information that we may collect from you. Capitalized terms used in this Privacy Policy that are not defined have the same meaning as defined in the Qemera Terms of Service ("Terms").

If you do not agree with our policies and practices, your choice is not to use our Site or Services. By accessing or using the Site or Services, you agree to this Privacy Policy. This policy may change from time to time as stated below. Your continued use of this Site or Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

02 Scope of this policy

This Policy details our commitment to protecting the privacy of individuals who visit our Site ("Visitors") and entities or individuals who have subscribed to our Services and agreed to the Terms ("Customers"). This policy applies to information that is automatically collected via the Site or Services or that is affirmatively provided to us by Visitors or Customers.

This Privacy Policy does not apply to:

• Client Personnel. Unless they are also a Visitor or Customer of Qemera, individuals who are employees or contractors of our Customers and assigned to work at our facility ("Client Personnel") are not covered under this Privacy Policy. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information from Client Personnel. If you are Client Personnel and would either like to amend your contact information or no longer wish to be contacted by us, please contact the Customer (your employer) that you interact with directly. If your Personal Data is processed within Customer Data, we will process the Personal Data for as long as we are instructed to do so by the Customer that is the data controller of the Personal Data.
• Offline Information. Information collected by us offline or through any other means, including on any other website operated by Qemera or any third party (including our affiliates and subsidiaries) is not subject to this Privacy Policy.
• Third Parties. Qemera is not responsible for the privacy policies or other practices employed by websites linked to, or from, our Site nor the information or content contained therein, and we encourage you to read the privacy statements of any linked third party.

The Services are intended for use by enterprises. When we process Personal Data on behalf of a Customer, that Customer is the Data Controller of your personal information and Qemera is a Data Processor under the General Data Protection Regulation ("GDPR"). When you visit our Site or use our Services, and we collect information from you, including Personal Data, Qemera shall be the Data Controller for the collected data under the GDPR.

03 Information we collect

Qemera gathers a variety of information about our Site visitors, Customers, and Client Personnel, including information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("Personal Data"); that is about you but individually does not identify you; and about your internet connection, the equipment you use to access our Site or Services and usage details.

We collect this information directly from you when you provide it to us; automatically as you navigate through the site; or from third parties, for example, our business partners.

Information That You Provide to Us

When you sign up to use the Services or when you request certain materials, you may be required to provide Personal Data. During these processes, we may ask you to provide your (i) contact information such as name, e-mail address, mailing address, IP address, or geographic location, as well as certain related information like your company name and website name; (ii) billing information, such as credit card number and billing address; (iii) name and e-mail address when you provide feedback from within the Services; and (iv) unique identifiers, such as username, account number or password.

Through your use of the Site or Services, we may also obtain Personal Data from records and copies of your correspondence (including email addresses), if you contact us; your responses to surveys that we might ask you to complete for research purposes; or details of transactions you carry out through our Site or Services.

Finally, we may also obtain information if you provide information to be published or displayed (hereinafter, "posted") on public areas of the Site or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information Automatically Collected Through Your Use of the Site or Services

As you navigate through and interact with our Site and Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and pattern. The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Site and Services and allows us to deliver a better and more personalized service, including enabling us to estimate our audience size and usage patterns, to store information about your preferences, and to recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site and Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site and Services.
• Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies.
• Log Files and Web Beacons. Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Site and Services. In such a case, we would treat the combined information in accordance with this Privacy Policy.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

04 How we use your information

Qemera identifies the purposes for which the information is being collected before or at the time of collection. The collection of your Personal Data will be limited to that which is needed for the purposes identified by Qemera. Unless you consent, or we are required by law, we will only use the Personal Data for the purposes for which it was collected. If Qemera will be processing your Personal Data for another purpose later on, Qemera will seek your further legal permission or consent; except where the other purpose is compatible with the original purpose. We will keep your Personal Data only as long as required to serve those purposes. We will also retain and use your Personal Data for as long as necessary to comply with our legal obligations, resolve disputes.

We may use aggregated information about our users, and information that does not identify any individual, without restriction.

We use information about you, including Personal Data, for a variety of purposes, including:

• To enable you to use our Site or Services;
• To provide you with information, products, or services that you request from us;
• To provide workspace, facility, and infrastructure services under our seat-leasing and managed workspace agreements;
• To respond to your comments, questions, and requests;
• To provide customer service and support;
• To send you administrative messages about the Site or Services;
• To provide you with notices about your account, including expiration and renewal notices;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Site or Services or any products or services we offer or provide through it;
• To allow you to participate in interactive features on the Site or Services;
• To monitor and analyze trends, usage, and activities in connection with the Site and Services;
• To investigate and prevent fraudulent transactions, unauthorized access to the Site and the Services, violations of the Terms, and other illegal activities;
• In any other way we may describe when you provide the information; or
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please follow the unsubscribe instructions included in our marketing communications.

05 How we disclose information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect, or you provide:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, including payment processors, storage contractors, and analytics contractors;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Qemera's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Qemera about our Site or Services users is among the assets transferred. Any successor in interest to this Privacy Policy will be bound to the Privacy Policy at the time of transfer.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Qemera, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

06 Customer data

"Customer Data" means any and all data, information or material provided or submitted by Customers to Qemera by any means, including Personal Data of Customer employees, contractors, and Client Personnel. We only process Customer Data as per our Customer's instructions. For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the processor and not the controller of the Customer Data. Our European Economic Area ("EEA") or Switzerland based customers are the "controllers" of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them provide notice to their Client Personnel concerning the purpose for which Personal Data is processed by Qemera.

As the controller, it is our Customers' responsibility to inform Client Personnel about the processing, and, where required, obtain necessary consent or authorization for any Personal Data that is collected as part of the Customer Data. As the processors of Personal Data on behalf of our customers, we follow customer's instructions with respect to the Customer Data to the extent consistent with the functionality of our Services. In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Data.

07 Data security

We have implemented appropriate technical and organizational measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL or TLS technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site and Services. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your Personal Data transmitted to the Site or Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or Services.

08 International transfer

Qemera stores personal information about visitors and Customers within the United States, Ethiopia, and in other countries and territories in which we, or our contractors, operate. To provide you with the Site or Services, we may transfer and access such Personal Data from around the world. If you are using the Site or Services from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Data to the United States, Ethiopia, and other jurisdictions in which we operate. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. Whenever we share Personal Data originating in the EEA, we will rely on lawful measures to transfer that data, such as the EU Standard Contractual Clauses (SCCs). By providing your Personal Data, you consent to any transfer and processing in accordance with this Privacy Policy.

09 Legal basis for processing (EEA only)

With respect to Personal Data collected from individuals from the EEA, our legal basis for collecting and using the Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. Our Company will normally collect Personal Data only where: (a) we have specific consent to do so, (b) where we need the Personal Data to fulfil a contract with a Visitor or Customer, or (c) where the processing is in our or a third party's legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your Personal Data. If we process Personal Data in reliance on your consent, you may withdraw your consent at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.

10 Standard contractual clauses

Qemera uses EU Commission-approved Standard Contractual Clauses (SCCs) as the lawful mechanism for transferring Personal Data from the European Economic Area (EEA), the UK, and Switzerland to countries that do not have an adequacy decision from the European Commission, including the United States and Ethiopia.

Qemera has executed SCCs with our service providers and contractors who process Personal Data on our behalf. If you are a Customer and require a signed Data Processing Addendum (DPA) including SCCs for your records, please contact us at privacy@qemera.com.

In compliance with applicable data protection law, Qemera commits to resolve complaints about your privacy and our collection or use of your personal information. EEA, UK, and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us via our data protection contact listed below.

11 Your choices

You can review and change your personal information by visiting your account profile page.

You may also send us an email to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete User Contributions from the Site or Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users.

Qemera tolerates only permission-based email. In addition, users always have the opportunity to opt-out or change preferences via a link in the footer of all non-transactional email messages. These options are made available in email messages delivered from our company. Some communications, however, are considered transactional and are necessary for all Qemera customers (e.g. important account notifications and billing information). You must cancel your Qemera account to unsubscribe from transactional communications.

Qemera does not currently respond to browser "Do Not Track" signals or other mechanisms. Third parties may collect data about your online activities over time and across sites when you visit the Site or use the Services.

12 EEA specific rights

Personal Data

If you are an individual resident in EEA, you have the following data protection rights regarding Personal Data:

• You have the right to access, correct, update or request deletion of your Personal Data. You can do so at any time by contacting us.
• You have the right to object to processing of your Personal Data, to ask us to restrict processing of your Personal Data, or to request portability of your Personal Data. Again, you can exercise these rights by contacting us.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.
• You have that right to revoke consent that was previously given. If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

If you would like to exercise any of the above rights, please contact our support team or contact our Data Protection Officer.

Customer Data

If you seek access to, or wish to correct, update, modify or delete Personal Data which is part of the Customer Data and processed by us on behalf of our Customer, you should direct your query to our Customer i.e., the controller. If you are a Customer and wish to raise a request on behalf of your Client Personnel in connection with Customer Data, please contact us.

13 Changes to this policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Site home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a prominent notice on the Site home page. Such changes will be effective when posted. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes. Your continued use of our Site or Services following the posting of any amendment, modification, or change to this Privacy Policy shall constitute your acceptance of the amendments to this Privacy Policy. You can choose to discontinue use of the Site or Services, if you do not accept the terms of this Privacy Policy, or any modified version of this Privacy Policy.

14 Children under the age of 16

Our Site and Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site or Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or register on the Site or Services, make any purchases, use any of the interactive or public comment features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address listed below.

15 California privacy rights

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the email address listed below.

Our site, products, and services are not intended to appeal to minors. However, if you are a California resident under the age of 18, and a registered user of our Site or Service, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content or information to the email address listed below.

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Under California law, California residents who have an established business relationship with us may opt-out of our disclosing Personal Data about them to third parties for their marketing purposes.

16 Contact us

Qemera acknowledges the individual's right to access their personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to the address below. If requested to remove data, we will respond within a reasonable timeframe.

If you have any questions about this Privacy Policy, please contact: