Privacy Policy

Purpose: A privacy policy aims to communicate the 1E’s data practices in a clear and accessible manner, ensuring that individuals are informed about how 1E uses their personal information.

Scope: This Privacy Policy covers all personal data collected through our websites, applications, and other interactions with our company. It details the types of data collected, the purposes for data collection, security measures in place, and conditions for data sharing. Additionally, it explains user rights concerning data access, correction, deletion, and how we communicate any changes to this policy.

1E, including its subsidiaries and affiliates (“1E,” “us” or “we”), respect the privacy of our online visitors, office visitors, supplier personnel, vendor personnel, and any other external individuals who interact with 1E. This privacy policy (“Privacy Policy”) describes our procedures regarding the collection, use, storage, and disclosure of information we collect from you when you communicate and interact with us directly, use 1E software, or visit 1E.com, other 1E websites accessible globally through this site, or other sites displaying this Privacy Policy (collectively, “Websites”). This Privacy Policy may be supplemented by additional information provided at the time when we collect your personal information.

Compliance with applicable laws. When Using your Personal Information in the context of our activities, we will do so in compliance with relevant data privacy and data protection laws, which includes regulatory and national law requirements that may apply to such use and, where applicable, giving you the specific rights that apply in the country where you reside (altogether “Applicable Data Protection Law”).

For further information on 1E’ collection, use, storage, and disclosure of personal information of individuals located in:

• for residents of United States, please refer to our “US Privacy Notice”.
• for residents of European Economic Area (EEA) or United Kingdom (UK), please refer to our “EEA/UK Privacy Notice”.

We collect personal information from and about you as follows:

1. Personal Information You Provide. “Personal Information” is information relating to a directly or indirectly identified or identifiable natural person such as your name, email address, physical address, or telephone number. 1E may request, or provide you an opportunity to submit, personal information. For instance, if you register for an event, request information, purchase or use our Software or Services, or request support. While under no obligation to provide us with personal information, you should understand that we will not be able to process your communications with us or render certain services that we offer without this information.
2. Use of Job Applicant Data. 1E will use personal information provided by job applicants for the following purposes:
   1. assess candidate suitability for the position for which he/she applies and make hiring decisions;
   2. communicate with and send materials to candidates (including telephone, email, and postal mail) as well as with designated emergency contacts, including to notify candidates of office closures or emergent situations;
   3. investigate, document, and report security incidents and onsite injuries, illness, or grievances;
   4. communicate offers of employment to the candidate and inform the candidate of current and future career and training opportunities;
   5. manage interview-related travel;
   6. manage and improve 1E’ recruiting and hiring processes, administer pre-employment activities, and maintain employment records;
   7. authenticate candidate identity and conduct or obtain reference and background checks only to the extent required or permitted by applicable law (if the candidate provides personal information of personal references, 1E may also reach out to them directly);
   8. other purposes as required or permitted by applicable law.

   For detailed information, please refer to the privacy notice provided in our career portal.

3. Information Collected Automatically. As you navigate through and interact with our websites or collaborate on or review our confidential or proprietary business materials, we collect, process, and store certain personal information automatically from the computer, smartphone, or other electronic device (“device”) you use to visit the Website or collaborate on or review these materials. This may include, for example, information about your equipment and activity, such as your device’s Internet Protocol (IP) address, operating system, browser type, and web pages viewed immediately before and after visiting our websites, information you search for on our websites, files accessed, and other technical data. We collect such information through use of browser cookies and similar technologies. For information on our processing of Personal Information through browser cookies and similar technologies on our websites, please refer to our Cookies Policy, which is part of this Privacy Policy.
4. Information Collected by Third Parties. If you interact and communicate with us directly, we may receive certain limited information about you from third parties. We use certain technologies that protect sensitive business information and help detect, prevent, or otherwise address fraud, security, or technical issues. If you receive or handle our confidential or proprietary business information when you interact with us, we may receive information about how you handle that information. This may include personal information like your name, email address, activity, and IP address or device information. Accordingly, we encourage you to read the terms, conditions, and privacy policy of each third-party service that you choose to use or interact with.
5. Sensitive Personal Information. Occasionally we collect and process what may be considered sensitive personal information. For example, if you purchase something from us or subscribe to our Services, we will collect payment information, such as financial or bank card information, and other information necessary for us to process the transaction. Some of our Services may ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service. Information that is considered sensitive under applicable law will be handled in accordance with such laws.

1. Use of Personal Information. We use the personal information we collect for purposes as described above, to meet our legitimate business interests and for other necessary purposes as permitted by applicable law. This includes responding to your requests, inquiries, or otherwise serving you in ways associated with the circumstances under which we collected the information. We do not use your personal information for 1E’ marketing purposes unless you affirmatively agree or opt-in to such usage. Marketing may include sending you communications about our products and services or other communications targeted to your interests. If you do not wish us to use your email address or other contact information for our direct marketing purposes, do not select the opt-in option (if any) in the online form in which we collect your data. You can withdraw your consent at any time by:
   1. replying to a promotional email we have sent and indicating your preference to unsubscribe;
   2. clicking the “unsubscribe” link provided at the bottom of any electronic marketing communication; or
   3. adjusting your subscription settings for your account. You can also send us an email stating your request to DPO@1E.com.

   Additionally, we may use your personal information to execute an agreement or transaction concluded through the Website and to meet 1E’ legal obligations with regards to the agreement or transaction.

2. Chat rooms, messaging, and community and event forums. A number of our Services provide features including community and event forums for collaboration, peer connection, and information exchange purposes. Depending upon the Service, the personal information you choose to post, share, upload, or make available is public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. These Services may have their own Terms of Use and, where appropriate, their own privacy statements. We moderate these Services for compliance with our Terms of Use.
3. Use of Automatically Collected Information and Analytics. We use information we collect automatically through logging and Cookie technologies for legitimate business interests, to facilitate your use of our websites, to analyze usage by visitors, to improve user experience, detect against fraud, security, or technical issues, protect our intellectual property and sensitive business information, and to deliver better service. For more information on our use of these technologies for our websites, please refer to our Cookies Policy.
4. Legal obligations. We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate:
   1. under applicable law, which may include laws outside your country of residence;
   2. to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence;
   3. to enforce our terms and conditions; and
   4. to protect our rights, privacy, safety, or property, or those of other persons.
5. Research and development. We aim to de-identify the personal data wherever possible but where it is not possible we may use it for internal research and development purposes and to improve and test the features and functions of our Services.

1E collects data through the CCTV system for various reasons:

1. to control access to the buildings and to ensure the security of the buildings, the safety of 1E’s staff and visitors, as well as property and information located or stored on the premises;
2. to prevent, deter, and if necessary, investigate unauthorized physical access, including unauthorized access to secure premises and protected rooms, IT infrastructure, or operational information;
3. to prevent, detect and investigate a theft of equipment or assets owned by 1E, visitors or staff or threats to the safety of personnel working at the office (e.g. fire, physical assault). Legal basis for the processing is the legitimate interest of 1E as controller.

The CCTV system is not used for any other purpose, such as to monitor the work of employees or their attendance. It is important to notice that the location and positioning of the video-cameras are such that they are not intended to cover the surrounding public space; the cameras are aimed to give a general overview of events taking place in certain places but not to recognize persons. The system is also not used as an investigative tool or to obtain evidence in internal investigations or disciplinary procedures unless a security incident is involved. (In exceptional circumstances, the data may be transferred to investigatory bodies in the framework of a formal disciplinary or criminal investigation). The CCTV cameras are installed at the entrances, placed and focused in a way that only people who want to access the site or the annexed facilities including parking areas property are filmed. The CCTV system covers the area of entry and exit points of the building, entry points inside the building, delivery, garage, and outer area of the building. The system only captured images; no voice is recorded. The images are not shared with third parties and can only be accessed by a limited number of people in the local Security Office. They are periodically overwritten and deleted immediately once its purposes are fulfilled.

Your personal information is retained for as long as necessary to accomplish the purposes for which it was collected unless otherwise required by applicable law. In some instances, we may be required to retain personal information for longer periods of time to comply with legal requirements under applicable law, for example, to meet tax and accounting obligations. For more information on our retention of cookie data, please refer to our Cookies Policy.

1E may disclose or share your personal information with our corporate subsidiaries and affiliates worldwide that are also bound by this Privacy Policy. We will not share your personal information with any third party for that party’s marketing purposes, although we may disclose your information to certain third parties as described below.

1. Within 1E. Our businesses around the world are supported by a variety of teams and functions, and personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information. For a list of locations in which data may be processed you can visit the 1E website.
2. Service Providers and Agents. We may share personal information with outside service providers or agents. These outside service providers or agents are only authorized to use the information on 1E’ behalf for purposes such as to provide services or products you have requested, perform billing and collection, or help us manage and analyze data and improve our Websites.
3. Legal Compliance or Enforcement. We may disclose your personal information to third parties when we believe disclosure is necessary to:
   1. comply with a law, regulation or compulsory legal process, including a law enforcement, regulatory or court-authorized request;
   2. protect the rights, property or safety of 1E or other persons or entities; or
   3. enforce our Websites’ Terms.
4. Business Transfers. If 1E is involved in a merger, acquisition, business combination, reorganization, or other transfer of some, or all, of the company’s business, your personal information may be transferred to the buyer or other successor to 1E.
5. Non-Personal Information. We may disclose aggregated information, and information that does not identify or allow for the identification of a particular person, at our discretion.
6. Recruitment. If you register with 1E or one of our Recruitment Partners in order to apply for employment, your personal information, including any sensitive personal information you provide, will be made available to appropriate people in the appropriate part of 1E in order to consider your application.

Note that your personal information may be shared with and stored in countries outside your own, including in the U.S. and other countries. We will only transfer your personal information following applicable legal requirements and adopt security measures to protect your personal information. By submitting your personal information, you are consenting to the transfer of your personal information as described in this Privacy Policy.

Our websites are not intended for children, and we do not knowingly collect personal information from children. If you are a child or guardian of a child, please do not provide any child’s personal information on our websites or use any of the interactive or public comment features.

Some US residents may be able to exercise additional rights granted by state privacy laws in relation to the personal information that we have collected (subject to certain limitations) please refer to our “US Privacy Notice”. For more information, please contact us at DPO@1E.com.

Our websites may include links to sites operated by third parties. This does not mean that 1E endorses these sites, nor are we responsible for their content or policies. Third party sites are governed by their own privacy policies. You should familiarize yourself with the privacy policy of other sites you visit as it will govern any information you provide through that site.

Our Website includes social media features, such as the Facebook Like button and widgets, such as the Share This Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

1E takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. For example:

Policies and procedures

• We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data.
• We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets.
• We place appropriate restrictions on access to personal information.
• We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely.
• We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies.

Training for employees and contractors

• We require privacy, information security, and other applicable training on a regular basis for our employees and contractors who have access to personal information and other sensitive data.
• We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions.
• Vendors, we require, through the use of contracts and security reviews, our third-party vendors and providers to protect any personal information with which they are entrusted in accordance with our security policies and procedures

If you are a resident of EU/EEA/UK, please note that we may transfer your personal information outside the EU/EEA/UK. We will take all steps reasonably necessary to ensure that appropriate safeguards are in place to guarantee that your personal information are adequately protected according to the requirements of the applicable data protection laws. For example, with respect to transfer of EU personal information, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it.

You have the right to contact us at DPO@1E.com for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when it is transferred as mentioned above.

You can access and change personal information provided to us as described below. Subject to limitations in applicable law, you also have a right of restriction, opposition, erasure, and portability.

Access to personal information. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).

Correction and deletion. In some jurisdictions, you have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by getting in touch with us at DPO@1E.com.

Note that you have a right to lodge a complaint with the Supervisory Authority in your country if you think that 1E did not adequately address your concern.

Depending on your country/region of residency, you may have the following rights concerning your personal information (subject to legally permissible restrictions):

• Right of access: You may request access to your personal information, including requesting a copy thereof.
• Right to rectification: You may request to update or correct any inadequate, incomplete, or inaccurate personal information.
• Right to erasure: You may request that we erase your personal information, if such information is no longer necessary for the purposes it was collected, it was or is being processed unlawfully, or you have permissibly withdrawn your consent to such processing (where our processing is based on your consent).
• Right to restrict: You may request that we cease further processing of your personal information.
• Right to data portability: You may request that we provide your personal information in a structured, commonly used, and machine-readable format for your use or transfer.
• Right to object: You may object to 1E’s processing of your personal information for direct marketing purposes, for our own legitimate interest, or to allow us to perform a task in the public interest.
• Right to withdraw your consent: Where 1E is processing your personal information based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority if you believe that 1E’s processing of your personal information violates data protection regulations.

If you want to exercise any of these rights or have any questions or concerns about how we treat your personal information, please email your request to DPO@1E.com or fill out this request form.

If you have questions about this Privacy Policy or our privacy practices, please reach out to our internal data protection officer. Data protection officer’s name and contact information are as follows:

1E Data Protection Officer
Address: 1E, 8 Devonshire Square, WeWork, London, EC2M 4YJ
Email: DPO@1E.com

We reserve the right to change this Privacy Policy at any time at our own discretion in compliance with applicable legal requirements. This may be the case, for example, to comply with new legislation or to reflect new services on our website. We will, at all times, treat your personal information in accordance with the version of the Privacy Policy that was in effect at the time we collected this information. When visiting our website, only the latest privacy policy applies.

Where necessary and possible, we will inform you if any changes require your involvement (e.g. renewed consent) or individual notification.

By visiting our websites, you agree to accept the terms of our Privacy Policy posted on the Website at that time.