Privacy Notice

Last updated: 24 May 2024

1. Introduction

This Privacy Notice provides details about our processing of your

personal data, including how and why we use your personal data
and how we keep it safe. It also explains the rights you have over
your personal data.

The controller responsible for processing your personal data is the

Soho House company or af liated company ('we', 'us' and 'our') with
which you have dealings as a website visitor, member or
membership applicant, customer or prospective customer, an
attendee at one of our events, a subscriber to our publications or
newsletters or with which you otherwise engage or communicate.
Speci c information relating to the types of personal data processed
and our purposes of processing that data is set out below.

This Privacy Notice covers all jurisdictions in which we operate and/

or in which, or to which, we offer our goods or services. We set out
speci c data protection information in relation to some of these
jurisdictions in the Appendices to this Privacy Notice.

You should read this Privacy Notice so that you know what we do
with your personal data. Please also read any other privacy notice
that we may provide to you from time to time that may apply to our
use of your personal data in speci c circumstances.

Please see the 'How to contact us' section at 16 below for details
about how to contact us.

2. Explanation of terms

In this Privacy Notice:

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'personal data' (also referred to in this Privacy Notice as 'personal
information') means any information that relates to you from which
you can be directly or indirectly identi ed;

'process' means any activity relating to personal data, including

collection, use, sharing, storage and transmission; and

'controller' is a legal term and refers to the company that makes

decisions about how and why your personal data is processed and
is therefore responsible for ensuring that the processing is done in
accordance with relevant data protection laws.

3. How do we obtain your information?

Most of the personal information we process is provided to us

directly by you when you engage with us, such as when you apply
to be a member, complete our web forms in order to make an
information request, make an enquiry, attend an event, book a room
and stay with us, purchase our goods or services or when you
subscribe to our newsletter.

We process personal information about you when you use or

interact with our website or apps (as applicable) ("Sites"), create an
account, generate or make any content on, or upload to, a Site,
including preferences you set (such as choice of language),
photographs and videos you upload, conversations and
connections you have with other users and comments you make via
our messaging services.

When you visit, use or navigate our Sites, we may process certain
information about you automatically. This information does not
reveal your speci c identity (like your name or contact information)
but may include device and usage information, such as your IP
address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country,
location, information about how and when you use our services,
and other technical information which may identify you. This
information is primarily needed to maintain the security and
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operation of our Sites, and for our internal analytics and reporting
purposes. Like many businesses, we also collect information
through cookies and similar technologies, which you can read more
about in our Cookie Policy

We may also collect personal information from available sources in

the public domain and from other third parties, such as other
members (e.g., if relevant, your proposers for membership).

In certain circumstances, we will also require certain personal data

in order to manage our relationship with you/provide you with our
services (e.g., your payment card details to take payment or certain
information to enable you to create an account with us).

Please note that we may combine the personal data that you
provide to us with other information we collect about you when you
make a reservation through third-party services, such as online
restaurant/hotel reservation websites, so that we may process your
requests.

Where we don't need your personal data, we will make this clear,
for instance we will explain if any data elds in our forms are
optional and can be left blank.

If you submit any personal information relating to another person,

you represent that you are authorised by that person to do so and
to permit us to use the information in accordance with this Privacy
Notice.

4. What information do we collect?

We collect personal data about you, including the following:

Identity and Contact Information: rst name, last name, title, postal
address, email address and telephone numbers, driving licence,
passport, CCTV and photographs.

Personal Details: age, gender and date of birth.

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Information collected when you contact us: includes information in
emails and other communications with us such as feedback and
surveys.

Employment Data: employment details, including employment

status, job title, employment address, telephone number and
previous employment details.

Diversity, Equality and Inclusion Data: sexual orientation, religion,

gender identity and ethnicity and race.

Preferences: Preferred language, direct marketing and cookie

preferences.

Nationality: nationality and citizenship.

Financial Data: bank account details, tokenised payment card data

and billing information.

Technical Data: device identi ers such as internet protocol (IP)

address, usernames or similar identi ers, geolocation data, usage
and login data.

Health and Medical Information: Health and disability information

and dietary requirements.

Payment information

Any credit/debit card payments and other payments you make

through our Sites will be processed by our third-party payment
providers. The payment data you submit will be securely stored and
encrypted by our payment service providers using up to date
industry standards. Please note that aside from card information
tokenisation, we do not directly process or store the debit/credit
card data that you submit; this is handled by our third-party
payment provider.
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We may arrange that card or payment data you submit in support of
a membership application, subscription fee, ticket purchase and/or
F&B purchase at any of our operations is stored for the purpose of
processing your application, initiating your membership and
collecting your subscription fees if your initial application for
membership is successful. If you are put on to a membership
waiting list, please note that this data may be stored for later use to
initiate your membership and subscription. We store and use card
or payment information for the purpose of processing any future
payments that you make as a member for additional goods and
services.

You may choose to opt out of us holding your card or payment data,
although this means that you will need to re-supply us with card/
payment details to initiate your membership subscription fee, or for
the purpose of making any future purchases.

5. What are our lawful bases for processing your personal data?

We ensure that we have a lawful basis or bases for processing your

personal data. Our lawful bases for processing your personal data
(which are based on data protection law requirements in the United
Kingdom (UK) and European Economic Area (EEA)) are as follows:

o It is necessary in our legitimate interests. We have a legitimate

business interest in processing your personal data. Our legitimate
interests are in:
o Evaluating and processing your membership application and
contacting proposers indicated within your application.
o Providing our products and services.
o Analysing, managing, evaluating and improving our business.
o Dealing with your queries and feedback.
o Improving our guests'/members' experiences
o Managing reservations
o Operating our facilities and events.
o Ensuring the security of our premises, facilities and property.
o Detection and prevention of crime.
o Maintaining the security of our websites.
 o Communicating with you regarding your reservation.
Where we rely on legitimate interests, we have balanced our rights
against your interests, fundamental rights and freedoms and
determined that our legitimate interests are not overridden in those
circumstances.

o It is necessary to comply with a legal obligation. We collect and

process some information about you to comply with our legal
obligations (e.g., in relation to accounting and tax requirements)
and keep records as required by law.

o It is necessary for the performance of a contract between you

and us or to take steps at your request prior to entering into the
contract, for example, we will need to process your personal data to
ful l a transaction with you to provide our goods or services.

o In rare cases, it may be necessary to process your personal data

to protect your or another person's vital interests (i.e. your life) –
e.g. in emergency circumstances when communicating with rst
responders or medical professionals – or because it is necessary
for the performance of a task in the public interest.

o In limited circumstances, we may request your consent to

process your personal data.

When we process particularly sensitive personal data (also known

as special categories of personal data) – e.g., health/disability data,
sexual orientation, ethnicity/race or religious beliefs – we have an
additional lawful basis for the processing of such personal data
based on data protection law requirements in the UK and EEA. In
the limited circumstances where we process such personal data:

o We will request your explicit consent to do so.

o It is necessary for the establishment, exercise or defence of
legal claims.
o It is necessary for reasons of substantial public interest.
o The personal data is manifestly made public by you.
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 o There may also be very rare occasions where we need to
process this information to protect your or another person's vital
interests (i.e., your or the other person's life) where you are
physically or legally incapable of giving consent.

6. How and why do we use your information?

Please see the table below for details of the different purposes for
which we use your personal data, as well as the lawful basis or
bases relied upon for each purpose of use:

Purpose
To evaluate your membership application: We will process your data
in order to assess your suitability for membership or to check you
maintain the conditions of Soho House's membership, when you
are asking for the renewal of your membership.

Lawful basis or bases

This processing is necessary for the performance of a contract and
for Soho House’s legitimate interests.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
Ful lment of reservation: We may process information relating to
your bookings. This includes bookings in our Houses, restaurants,
spas and gyms. The data may be processed for the purpose of
completing your room reservation/restaurant reservation.

Lawful basis or bases

This processing is necessary for the performance of a contract and
is necessary for the purposes of our legitimate interests.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
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Reservation communications: To communicate with you about your
visit to our Site and Digital Channels, Soho Houses, spas,
restaurants, gyms and Soho Works sites.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
Purchases: To process transactions, Soho House must collect data
such as your name, purchase, and payment information.

Lawful basis or bases

This processing is necessary for the performance of a contract and
Soho House’s Legitimate Interests

Purpose
Events: We also collect information regarding Soho House events,
attendance and ticketing which we require for the purposes of
completing your ticket purchase and attendance at the event. Soho
House also uses personal information about attendees to plan and
host corporate events, host online forums and social networks in
which event attendees may participate.

Lawful basis or bases

This processing is necessary for the performance of a contract and
is necessary for the purposes of our legitimate interests.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
Response to enquiries: We may process information contained in or
relating to any communication that you send to Soho House. This
data may include the communication content and metadata
associated with the communication.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests to respond to your queries.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
Marketing and promotions: To communicate news and promotions
to you relating to Soho House’s products and services, or other
marketing or promotional activities.

Lawful basis or bases

This processing is carried out with your consent.

Purpose
To understand your preferences and interests: To be able to
improve the member’s experience.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests in improving our services.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
To enable you to socialise on our Site: For example, through Soho
Connect and our messaging platform and by allowing other
members to identify you via your shared interests if you consent to
this through our Site preferences.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests.
We will only allow other members to see your shared interests with
your consent.

For special categories of data this processing is conducted with

your explicit consent.

Purpose
Proposers: To contact proposers you have indicated within your
application.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests in processing your membership application.

Purpose
Internal business purposes: For our internal business purposes,
such as data analysis, audits, market research, developing new
products, improving our services, obtaining statistical information,
identifying usage trends and visiting patterns, determining the
effectiveness of our promotions and meeting contractual
obligations.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests in improving our products and services and for performing
a contract.

Purpose
Your Preferences: To understand your preferences and interests
and be able to improve your experience of our goods and services

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests.
For any special categories of personal data processed: explicit
consent
Purpose
Our Sites: To improve, promote and develop our Sites and promote
popular conversations, programs and campaigns on the Sites.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests.

Purpose
Administrative and other communications: To send you important
information regarding our Sites, changes to our terms, conditions,
and policies, or other administrative information (e.g., information
about your reservations, such as reservation con rmations), to
enforce our terms and conditions and policies, to provide you with
customer/user support and to contact you for public health reasons
and to comply with government guidelines, regulations and
mandates.

Lawful basis or bases

This processing is necessary for the purposes of our legitimate
interests, and it is necessary to comply with a legal obligation.

For any special categories of personal data processed: explicit

consent, legal claims, public information, vital interests and
substantial public interest.

Purpose
Our legal duties: To comply with legal and regulatory requirements
or demands in accordance with applicable law, a court order,
subpoena, or other legal process.

Lawful basis or bases

This processing is necessary to comply with a legal obligation.

Purpose
Corporate Arrangements: To facilitate the sale or potential sale of
our business or part of our business.
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 Lawful basis or bases
This processing is necessary for the purposes of our legitimate
interests.

1. Do we share the information we receive?

· Sharing within our group

As a global organisation, we may share your personal data with our

group and af liated companies in order to provide our services and
bene ts to you, such as to enable you to avail of membership
services outside your home country or for our general business
management and corporate reporting purposes. With your consent,
other group or af liated companies may send information about
their products or services to you. We also share personal data
where support or functions are provided by other group and
af liated companies, such as in relation to customer services,
website hosting and IT support and maintenance.

· Sharing outside our group

We may also share your personal data with third party service
providers outside our group to provide us with services, such as
o card processing or payment service providers;
o credit reference agencies;
o IT suppliers and contractors (e.g. data hosting providers)
o analytics providers/ web analytics providers;
o providers of digital advertising services;
o event organisers and
o providers of CRM, marketing and sales software solutions.

We carry out due diligence to check that these service providers

have appropriate security in place to protect your personal data and
we enter into written contracts with them to impose appropriate
security obligations on them.

We may also share your personal data with third parties who act as
controllers of that data.
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 We may share your personal data with:
· consultants and professional advisors, including our lawyers and
accountants;
· prospective sellers, buyers or other third parties if we transfer,
purchase, reorganise, merge or sell any part of our business;
· business partners;
· courts and court-appointed persons/entities;
· trade associations;
· our insurers; and
· government departments and statutory and regulatory bodies,
including data protection regulators, law enforcement and tax/
revenue of ces.

2. Is your personal data sent outside your home country?

Soho House is a global organisation that operates in many

countries. We may share your personal information with other group
or af liated companies, our service providers, and other third
parties that may be located in other countries. Although the data
protection laws of these various countries may differ from those in
your own country, we will take appropriate measures to ensure that
your personal information is handled as described in this Privacy

Notice and in accordance with the applicable law.

If we transfer your personal data outside the UK or EEA (including

to our group or af liated companies), we will implement appropriate
safeguards for that transfer in accordance with the applicable law,
such as implementing standard contractual clauses for data
transfers approved by the relevant data protection authorities or by
transferring your data to countries which have been deemed by the
relevant data authorities to provide adequate levels of data
protection. If you would like to receive more information on the
safeguards that we implement, including copies of relevant clauses
of data transfer contracts, please contact us as indicated below.
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3. How do we protect your personal data?

We take the security of the personal information we collect

seriously. We have implemented and maintain technical and
organisational security measures (as required by applicable data
protection laws) to protect your personal information from accidental
or unlawful destruction, damage, loss, alteration or unauthorised
disclosure or access.
Unfortunately, the transmission of information over the internet or
public communications networks can never be completely secure
and we therefore cannot 100 per cent guarantee the security of
personal data that you provide to us online.

4. For how long will we keep your information?

We will keep your personal data only for as long as is necessary for
the purposes outlined in this Privacy Notice, or for the duration
required by any legal, regulatory, accounting or reporting
requirements, whichever is longer. We will only ever retain your
personal data for a limited period of time.

To determine the appropriate retention period for your personal

data, we consider the amount, nature and sensitivity of the personal
data, the purposes for which we process it, applicable legal
requirements or operational retention needs and whether we can
achieve those purposes through other means.
Upon expiry of the applicable retention period, we will securely
destroy your personal data in accordance with applicable laws and
regulations. In some circumstances we may anonymise your
personal data so that it can no longer be associated with you, in
which case it is no longer personal data.

5. Automated decision making

Automated decisions are where a computer makes decisions about

you without a person being involved. Pro ling is the recording and
analysis of a person's psychological and behavioural
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characteristics, to assess or predict their capabilities or to assist in
identifying or classifying categories of people.

Soho House does not make automated decisions about, or pro le,
its clients or customers.

6. What are your personal data protection rights?

Certain applicable data protection laws give you speci c rights in

relation to your personal data. In particular, if the processing of your
personal data is subject to data protection law in the UK and EEA,
you have the following rights in relation to your personal data:

Right of access: If you ask us, we will con rm whether we are

processing your personal data and, subject to certain conditions, we
will provide you with a copy of that personal data along with certain
other details such as the purpose(s) of the data processing.

Right to recti cation: If your personal data is inaccurate or

incomplete, you are entitled to ask that we correct or complete it.
Please help us to keep your personal data up to date by letting us
know of any changes to your personal data (including changes to
your contact details) as soon as possible.

Right to erasure: Subject to certain conditions, you may ask us to

delete or remove your personal data, such as where we no longer
need the personal data for the purposes for which it was collected
or our legal basis for the processing is your consent and you
withdraw consent.

Right to restrict processing: You may ask us to restrict or 'block' the

processing of your personal data in certain circumstances, such as
where you contest the accuracy of the personal data or object to us
processing it. We will tell you before we lift any restriction on
processing.

Right to data portability: You have the right to obtain from us (or to
have transferred to another controller) your personal data that we
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process by automated means on the basis of your consent or
necessity for a contract with you. We will provide the personal data
in a structured, commonly used and machine-readable format.

Right to object: You may object to our processing your personal

data, and we will stop processing your personal data if (i) we are
relying on a legitimate interest to process your personal data,
unless we demonstrate compelling legitimate grounds for the
processing or (ii) we are processing your personal data for direct
marketing purposes.
Right to withdraw consent: If we rely on your consent to process
your personal data, you have the right to withdraw that consent at
any time. This will not affect the lawfulness of processing of your
personal data carried out before we received notice that you wished
to withdraw your consent.

7. Right of complaint to your data protection authority

If you have a concern about our privacy practices, including the way
we handled your personal data, we would appreciate the
opportunity to put it right. However, you may be able to make a
complaint to your data protection regulator.

If you are located in the UK, you have the right to complain to the
Information Commissioner's Of ce (ICO) (https://ico.org.uk/).

If you are located in the EEA, you have the right to complain to the
competent data protection authority for your jurisdiction, a list of
which can be found at https://edpb.europa.eu/about-edpb/board/
members_en.

8. Third party notices

This Privacy Notice may contain links to other third party websites.
We are not responsible for the content of these other sites and you
should read the privacy notices provided by such websites.

9. Changes to this Privacy Notice

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We keep our Privacy Notice under regular review. Any changes we
may make to our Privacy Notice in the future will be posted to this
Site. Please check back frequently to see any updates or changes
to this Privacy Notice.

10. How to contact us

If you have any questions about this notice or how we handle your
personal data, please contact our Data Protection Of cer at
[email protected].

APPENDIX 1

PRIVACY NOTICE (ISRAEL)

1. Your personal data protection rights

If the Israeli data protection and privacy laws are applicable to your
personal data, Section 12 of the Privacy Notice is replaced as
follows:
12. What are your personal data protection rights?
Under Israeli data protection and privacy laws, you have the
following rights in relation to your personal data:

· Right of access: If you ask us, we will con rm whether we are

processing your personal data and subject to certain conditions, we
will provide you with a copy of that personal data along with certain
other details such as the purpose(s) of the data processing.

· Right to recti cation: If your personal data is inaccurate or

incomplete, you are entitled to ask that we correct or complete it.
Please help us to keep your personal data up to date by letting us
know of any changes to your personal data (including changes to
your contact details) as soon as possible.

2. Database Owner
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Please note that the equivalent term under the Israeli data
protection and privacy laws for "Controller" is "Database Owner".

APPENDIX 2

PRIVACY NOTICE (BRAZIL)

1. Children's data

In compliance with the Brazilian Data Protection Law ('LGPD'), the

processing of personal data of children (up to 12 years old) and
adolescents (between 12 and 18 years old) will only be carried out
in their best interests and, speci cally, in relation to children, always
with the speci c and express consent given by at least one parent
or legal guardian. We reserve the right to request proof of your age,
at any time, to con rm if we are in compliance with the terms of this
Privacy Notice, as well as to cancel any non-compliant accounts (if
any). If you are a parent or guardian and believe we have collected
children’s personal information in a manner not permitted by local
laws, please contact us as set forth in this Privacy Notice and we
will take corrective action required by local laws.

2. Your personal data protection rights

If the LGPD is applicable to your personal data, Section 12 of the

Privacy Notice is replaced as follows:

12. What are your personal data protection rights?

Under LGPD, you have the following rights in relation to your

personal data:

·The right to anonymization, blocking or elimination of data that is

unnecessary, excessive, or processed in disagreement with the
local law;

·The right to obtain information of the public and private entities with
which the controller performed shared use of data; and
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·The right to obtain information on the possibility of not providing
consent and on the consequences of the refusal.

·In addition to the above rights, you may object to processing based
on one of the cases of exemption from consent, in case of non-
compliance with LGPD's provisions.

APPENDIX 3

PRIVACY NOTICE (HONG KONG)

This privacy notice relates to website visitors, members or

membership applicants, customers or prospective customers,
attendees at our events, subscribers to our publications or
newsletters or with which you otherwise engage or communicate
('you' or 'your' being interpreted accordingly) living in Hong Kong:
Personal Data (Privacy) Ordinance

We comply with the Personal Data (Privacy) Ordinance

('Ordinance'). You may wish to visit the of cial website of the Of ce
of the Privacy Commission for more information about this
Ordinance.

Supply of personal data

Please note that it is mandatory for you to provide the below

categories of personal data which are marked with an asterisk:

·Name and contact details (including home and/or business email,

telephone, and address, including country)*
· Gender
· Age/date of birth*
· Occupation, title and employer*
· Payment information, including data about your billing name and
address and method of payment, such as bank account details and
payment card information*
· Preferred language
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 · Photos/videos
· Geolocation data
· Online account information, including your log-in details*
· Technical and usage information (such as your IP address,
account settings, time zone setting and location) and information
about your use of our Sites*
· Enquiry information*
· Feedback and surveys
· Health/disability information
· Dietary requirements
· Religious beliefs
· Your direct marketing and communication preferences
· Information provided by you using our messaging services
· Any other information you provide to us voluntarily

Membership Applicants:
· Identi cation documents (such as your driving licence, birth
certi cate or passport). If you are under 27 years old, we will require
you to attach to your application a copy of your passport, driving
licence or birth certi cate in order to allow us to verify whether you
are eligible to the reduced under-27-years membership fee,
pursuant to the House rules, available here.*
· Nationality*
· Information you provide about your work, skills and/or interests
· Any other information you provide to us voluntarily to support your
application or that you disclose in your user pro le on our Sites

Members:
· Identi cation documents (such as your driving licence, birth
certi cate or passport)*
· Nationality*
· Membership information and information about your (current and
past) use of our facilities (including check in/out time and visit log
information)*
· CCTV and keycard information*
· Addition guests' names and identi cation documents*
· Reservation ful lment information, including details of your
bookings with us*
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 · Information about the products and services you have purchased
from us*
· Information about your sign up to our events*
· Information you provide about your work, skills and/or interests

Website Visitors, Event Attendees, Customers, and Publication

Subscribers:
· Information about your sign up to, and attendance at, our events*
· Information about your subscriptions to our publications*
· Information you provide about your work, skills and/or interests

In the event that you do not provide such personal data, we may not
be able to provide you with our products and services.

Direct Marketing
We intend to use your personal data collected from you (including
your name and contact details) for direct marketing purposes (e.g.
to communicate news and promotions to you relating to our
products and services) and that we may not so use the data unless
we have received your consent or indication of no objection.

We do not give your data to third parties for their use in direct
marketing. If we ever want to do this, we will obtain your separate
consent.

You may opt-out from receiving marketing communications from us

at any time, free-of-charge, by contacting our Data Protection
Of cer at [email protected] or 180 The Strand, London, WC2R
1EA

Personal data protection rights

If Hong Kong law is applicable to your personal data, Section 12 of

the Privacy Notice is replaced as follows:

12. What are your personal data protection rights?

Under Hong Kong law, you have the following rights in relation to
your personal data:
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You have the right to request access to and correction of
information held by us about you. If you wish to access or correct
your personal data, please contact our Data Protection Of cer at
[email protected].

In accordance with the Ordinance, we are entitled to charge a

reasonable fee for processing any data access or correction
requests.
APPENDIX 4

PRIVACY NOTICE (UNITED STATES)

This privacy notice relates to website visitors, members or

membership applicants, customers or prospective customers,
attendees at our events, subscribers to our publications, or
newsletters, or with which you otherwise engage, or communicate
('you' or 'your' being interpreted accordingly) living in the United
States and amends the Privacy

Notice in the following respects:

The following information is added to the Privacy Notice:

“Do Not Track” requests

Our Sites currently do not respond to “do not track” or similar
signals.
Third-Party websites and social media

Our Sites may contain links to other websites, including those of

third parties or partners.

While we seek to link only to sites that share our high standards
and respect for privacy, we cannot be responsible for the privacy
practices other websites use. By accessing other third party
websites or applications through our Sites, you are consenting to
the terms and privacy policies of those websites. It is possible that
other parties may collect personally identi able information about
your online activities over time and across different websites when
you use our Sites.
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 Our Sites may include social media features, such as Facebook
“Likes” or “Recommend” buttons, Pinterest, Twitter, Tumblr, and
YouTube. These social media features may require cookies to be
set to function properly. These features may also collect personal
information such as your IP address. These features are governed
by the privacy notice/policy of the social media platform. Please
review the privacy notice/policy of the social media platforms to
learn how they protect your information.

Users only of legal age of majority

Our services are not intended for children under 13 years of age.
We do not knowingly collect personal information from children
under 13. If you are under 13, do not use or provide any information
on this service or on or through any of its features/register on the
services or provide any information about yourself to us, including
your name, address, telephone number, e-mail address or any
screen name or user name you may use. If we learn we have
collected or received personal data from a child under 13 without
veri cation of parental consent, we will delete that information. If
you believe we might have any information from or about a child
under 13 without veri able parental consent, please contact us at
[email protected].
APPENDIX 5

PRIVACY NOTICE (CALIFORNIA)

We adopt this supplemental privacy notice to comply with the

California Consumer Privacy Act of 2018, as amended by the
California Privacy Rights Act (the 'CCPA'). This notice applies
solely to website visitors and members who reside in the State of
California. Any terms de ned in the CCPA have the same meaning
when used in this notice.
What information do we collect?
We may collect the personal information categories listed in below:
If you a California resident, please also refer to Appendix 5 'Privacy
Notice (California)'.
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 Personal Information Category
Identi ers, such as real name, alias, postal address, unique
personal identi er, online identi er, internet protocol address, email
address, account name, or other similar identi ers.
Source
Directly from you. For example, from forms you complete.

Sold or Shared
We do not sell or share this information.

Personal Information Category

Categories of personal information described in Cal. Civ. Code §
1798.80(e), such as name, signature, physical characteristics or
description, address, telephone number, bank account number,
credit card number, debit card number, or any other nancial
information.

Source
Directly from you. For example, from forms you complete.

Sold or Shared
We do not sell or share this information.

Personal Information Category

Characteristics of protected classi cations under state or federal
law, such as age, citizenship, and sex (including gender, gender
identity, gender expression, pregnancy or childbirth and related
medical conditions).

Source
Directly from you. For example, from forms you complete.

Sold or Shared
We do not sell or share this information.

Personal Information Category

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Commercial information, such as records of products or services
purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies.

Source
Directly from you. For example, from forms you complete. Indirectly
from you. For example, from observing your actions on our Site.

Sold or Shared
We do not sell or share this information.

Personal Information Category

Biometric information

Source
No

Sold or Shared
We do not sell or share this information

Personal Information Category

Internet or other electronic network activity information, such as
browsing history, search history, and information regarding a
consumer’s interaction with an internet website, application, or
advertisement.

Source
Indirectly from you. For example, from observing your actions on
our Site.

Sold or Shared
We do not sell or share this information

Personal Information Category

Geolocation data

Source
 Directly from you. For example, from forms you complete. Indirectly
from you. For example, from observing your actions on our Site.

Sold or Shared
We do not sell or share this information

Personal Information Category

Audio, electronic, visual, thermal, olfactory, or similar information.

Source
Directly from you. For example, from video you upload to our Sites.
Indirectly from you. For example, from observing your actions on
our Sites (from CCTV footage).

Sold or Shared
We do not sell or share this information

Personal Information Category

Inferences drawn from other personal information to create a pro le

about a consumer re ecting a consumer’s preferences,
characteristics, and trends.

Source
Indirectly from you. For example, we may combine various piece of
personal information to develop inferences.

Sold or shared
We do not sell or share this information

Personal Information Category

Sensitive Personal Information (sexual orientation data, data related
to race and ethnic origin, disability data, account login information,
nancial account information, debit and credit card numbers with
any required security code, password, or credentials allowing
access to an account, and geolocation data).

Source
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Directly from you. For example, from forms you complete.

Sold or shared
We do not sell or share this information.

Personal information does not include: publicly available information

lawfully made available from government records, deidenti ed or
aggregated consumer information, or information excluded from the
CCPA.

How do we use your personal information?

We may use or disclose the personal information as discussed in
this Privacy Notice.
We will not collect additional categories of personal information or
use the personal information we collect for material different,
unrelated, or incompatible purposes without providing you with
notice.

What are your personal data protection rights?

Residents of the California have certain rights. Please note that the
below rights are not absolute, and we may be entitled to refuse
requests, wholly or in part, where exceptions under applicable law
apply.

Right to Access
You have the right to access personal information that we may
collect or retain about you. If requested, we shall provide you with a
copy of your personal information which we collected as permitted
by the CCPA.

You also have the right to receive your personal information in a

structured and commonly used format so that it can be transferred
to another entity ('data portability').

Right to Know
You have the right to request that we disclose the following about
your personal information, as de ned by the CCPA:
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 · The speci c personal information we may collect;
· The categories of personal information we may collect;
· The categories of sources from which we may collect your
personal information;
· The business purpose(s) for collecting or sharing your personal
information;
· The categories of personal information we may disclose for
business purposes; and
· The categories of third parties to whom we may share your
personal information.

Right to Opt-Out/Do Not Sell My Personal Information

You have the right to opt-out of sharing your personal information
with third parties for some purposes, including sharing that may be
de ned as a sale under applicable laws. You can opt-out of this
sharing by clicking on the “Do Not Sell or Share My Information” link
at the bottom of our homepage and submitting a request via the
authorized methods.
You also may have a right to opt-out of the use of curtained
automated decision-making technology.

Do Not Share or Disclose My Sensitive Personal Information

We collect sexual orientation data, data related to race and ethnic
origin, disability data, account login information, nancial account
information, debit and credit card numbers with any required
security code, password, or credentials allowing access to an
account, and geolocation data.

Right to Deletion
In certain circumstances, you have the right to request that we
delete any of your personal information that we collected from you
and retained, subject to certain exceptions. Once we receive and
con rm your veri able consumer request (instructions and
description below), we will delete, and, as applicable, direct our
service providers to delete, your personal information from our
records, unless an exception applies.
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We may deny your request to delete your personal information if
retaining the information is necessary for us or our service
providers, subject to certain exemptions in the CCPA.

Right to Correct/Right to Recti cation

In certain circumstances, you have the right to request correction of
any inaccurate personal information. Upon verifying the validity of a
valid consumer correction request, we will use commercially
reasonable efforts to correct your personal information as directed,
taking into account the nature of the personal information and the
purposes of maintaining your personal information.

Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights
under the CCPA. Unless permitted by the CCPA, we will not:
· Deny you goods or services;
· Charge you different prices or rates for goods or services,
including through granting discounts or other bene ts, or imposing
penalties;
· Provide you with a different level or quality of goods or services;
or
· Suggest that you receive a different price or rate for goods or
services or a different level or quality of goods or services.

California Shine the Light Law

California Civil Code Section 1798.83 permits our visitors who are
California residents to request certain information regarding our
disclosure of personal data to third parties for their direct marketing
purposes. To make such a request, please contact
[email protected].

Exercising Your Rights

If you are a resident of California, you can exercise any of your
rights as described in this Notice and under the CCPA by emailing
us at [email protected]. Except as provided for under
applicable privacy laws, there is no charge to exercise any of your
legal rights.
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However, if your requests are manifestly unfounded or excessive, in
particular because of their repetitive character, we may (as
permitted under the CCPA):
· Charge a reasonable fee taking in account the administrative
costs of providing the information or taking the action requested; or
· Refuse to act on the request and notify you of the reason for
refusing the request.

What Personal Information Do I Provide to Verify My Identity?

We take the privacy of your personal information seriously and want

to ensure that we provide only you or your authorized agent with
your personal information. Applicable law also requires that we
verify the identity of each person who makes a request to know
what personal information we have about you or to delete the
personal information we have about you. To verify your identity, we
may ask you to provide your:

· First name*
· Last name*
· Middle initial
· Email address
· Phone number
· Order number
· *required eld

How Do You Verify My Identity?

We may verify your identity in a few different ways in order to
balance the requirements of the CCPA and our obligation to keep
your information private. When you make your request, you may be
asked to answer a few questions about yourself to help us validate
your identity. This is a two-step process using information unique to
you, such as an order number, a product in an order, an address or
email address, etc.
In some instances, we may ask you to provide other documentation
to verify your identity. If this happens, we will reach out to you
directly with this request.
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 What If You Can’t Verify My Identity?
If we can’t verify your identity, we will not be able to process your
request to know what personal information we have about you or to
delete the personal information we have about you. If we are unable
to verify your identity with a high degree of certainty, we will only be
able to provide a report with category-level information and we may
not be able to delete some of your information.

How to Submit a Request Using an Authorized Agent

An authorized agent is a person or business who has authorization
to request to know what personal information we have about you, to
delete the personal information we have about you, or to opt out of
the sale of personal information on behalf of a California resident.
Authorized agents use the same links described above to submit
requests.
If you are submitting a request on behalf of another person, we
require a valid power of attorney or other documentation
demonstrating your authority to submit this request. This can be a
letter or other documentation signed by the California resident
authorizing you to submit this request. You can download a sample
letter from the request form.

How Do I Send You My Documentation?

If you submit a request via email at [email protected], you must
include the appropriate above listed documentation in order for us
to act on your request.

Response Timing and Format

We will con rm receipt of a request within 10 days and provide
information about how we will process the request. We endeavor to
substantively respond to a veri able consumer request within 45
days of its receipt. If we require more time (up to 90 days), we will
inform you of the reason and extension period in writing. If you
have an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our
written response by mail or electronically, at your option. Any
disclosure we provide will only cover the 12-month period preceding
the veri able consumer request’s receipt. The response we provide
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will also explain the reasons we cannot comply with a request, if
applicable. For data portability requests, we will select a format to
provide your personal information that is readily useable and should
allow you to transmit the information from one entity to another
entity without hindrance.

We do not charge a fee to process or respond to your veri able

consumer request unless it is excessive, repetitive, or manifestly
unfounded. If we determine that the request warrants a fee, we will
tell you why we made that decision and provide you with a cost
estimate before completing your request.

If you wish to appeal our decision, please submit your appeal to the
above contact information. Please clearly denote that it is an
appeal.

APPENDIX 6

PRIVACY NOTICE (INDIA)

This privacy notice relates to website visitors, members or

membership applicants, customers or prospective customers,
attendees at our events, subscribers to our publications or
newsletters or with which you otherwise engage or communicate
('you' or 'your' being interpreted accordingly) residing in India and
amends the Privacy Notice in the following respects:

1. Application of the privacy notice

The privacy notice shall apply to the collection and processing of

personal data. 'Personal data' as used in this privacy notice means
any information about you or in relation to you, through which you
may be identi ed and includes, but is not limited to, any data
collected online as well as information collected through of ine
means and digitized subsequently.

2. Legal basis for processing

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We may process your personal data on the basis of one or more
grounds for processing outlined below:

· Consent: We may request your consent for the processing of your

personal data, where relying upon the same. Our request for
consent will be speci c, informed and express and will provide the
personal data being processed, purposes and processing in line
with this privacy notice. You have the option of requesting that this
notice and/or this privacy notice be provided to you in English or
any other Indian language.

You may provide such consent directly to us or through a Consent

Manager (which is compatible with our platform), in accordance with
law. In the event that you provide such consent through a Consent
Manager, we may process your personal data to verify that you
have provided appropriate authority to the Consent Manager for
providing consent on your behalf.

· Legitimate Use: We may process your personal data for certain

legitimate uses. For example, you may voluntarily submit your
personal data on our website or otherwise provide it to us
voluntarily, for example, by (i) submitting your personal data through
the membership ‘Sign Up’ page, (ii) providing information using the
‘Contact Us’ feature, (iii) physically visiting one of our spaces or (iv)
otherwise emailing or contacting us. We may process your personal
data for the purposes of ful lling your request pertaining to our
services, providing services to you, for contacting you and/or for
purposes as indicated under ‘How We Use Your Information’. In
such cases, we would not require further consent from you for
processing your personal data.

· Legal Obligations: We may process your personal data for legal

compliance i.e., for ful lling our obligations under any law, for
complying with judgments or orders of courts or appropriate
authorities and continue to store your personal data for such period
required by such law, order or direction, thereof. In such cases, we
would not require further consent from you for processing your
personal data.
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 · Emergencies: We may process your personal data for responding
to medical emergencies, for providing medical treatment during
disasters, epidemics, public health situations or for taking other
measures to secure safety to any person during disasters or other
breakdown of public order. In such situations, we would not require
further consent from you for processing your personal data.

· Employment: We may process your personal data for responding

to your queries and actions in regard to gaining fresh or new
employment with us. The personal data shared with us for the
purposes of employment will be collected under a deemed
voluntarily shared consent. In such situations, we would not require
an express consent from you for processing your personal data.

3. Special provisions for Children or Persons with Disabilities

If you are under 18 (eighteen) years of age ('Child') or a person with

a disability and providing your personal data to us, we will require
consent from your parent or legal guardian for processing of such
personal data, in accordance with the legal requirements
surrounding such consent. The parental consent thus obtained will
be veri ed and reviewed by us pursuant to which we will process
your personal data, and as the case may be, provide you services.
We will not:

· process any personal data in a manner that is likely to cause any

detrimental effect on the well-being of a Child; or

· undertake any processing which involves tracking, behavioural

monitoring of a Child or conduct targeted advertising at a Child.

4. Cross-border transfers

We may share your personal data or store the same with third
parties located outside India, in such countries or territories, and
with such third parties, who ensure the same or similar level of data
protection that is adhered to by us under Indian law. We will not
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transfer or share your personal data with third parties in such
territories or countries, which are restricted by the Government for
the purposes indicated under ‘How and why do we use your
information’.

5. Security of Personal Data

We will implement appropriate technical, organizational as well as

security measures to protect your personal data, by implementing
reasonable security practices and procedures. Our information
security management systems are aligned with at least best
industry-standard practices and procedures or those speci cally
required by Indian laws.

We will report any cyber security incident affecting our systems and/
or networks to the relevant supervisory authorities as appropriate
and in accordance with their stated practices and procedures.
Where such incidents involve your personal data, in addition to
appropriate authorities, we may notify you about such incidents in
such form, manner and containing such information as required by
law.

6. Disclosure of Personal Data

We may share or disclose your personal data with third parties in

the manner provided by law including with:

To our af liates or group companies for the purposes described in

this notice;

To third-party service providers such as payment service providers,

credit reference agencies, IT suppliers and contractors, web service
and analytics providers, digital advertising service providers,
providers of CRM and other software solutions, legal advisors, and
other service providers to enable them to provide services required
for processing and delivery of products and services to you;
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 To our third-party service providers who provide services such as
website hosting, email delivery, auditing, fraud detection and other
services;

To third parties, to permit them to send you marketing

communications, for the purpose of data or website analysis,
market research, sticky quotient, website analytics, advertising and
development purposes consistent with your choices if you have
opted into such sharing; and
Such data available in reports and other materials provided by you
and/or your company may be shared pursuant to an engagement
with another business partner and/or a supplier.
We may also use and disclose your personal data as we believe to
be necessary or appropriate:

· to comply with applicable law, which may include laws outside

your country of residence, to respond to requests from public and
government authorities, which may include authorities outside your
country of residence, to cooperate with law enforcement or for other
legal reasons;

· to enforce our terms and conditions;

· to enforce or protect our contractual or other legal rights or to

defend or bring legal proceedings, threats or notices of legal
proceedings thereof; and

· to protect our rights, privacy, safety or property, and/or that of our

af liates and other users.

In addition, we may use, disclose or transfer your information to a

third party if necessary for a reorganization, restructuring, merger,
sale, joint venture, assignment, transfer or other disposition of all or
any portion of our business, assets or stock (including in connection
with any bankruptcy or similar proceedings) approved by a court or
other legal authority.

7. Your Rights
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You have the following rights with regard to your personal data
processed by us:

· Where we are processing your personal data on the basis of

consent, you have the right to withdraw such consent at any time by
writing an email to us at the coordinates provided in this notice.

· You have the right to request a summary of personal data being

processed by us and processing activities undertaken with respect
to such personal data, along with identities of third parties with
whom your personal data is shared and related information;

· You have the right to request correction, updating, erasure of your

personal data being processed by us in the form and manner
prescribed by law. We will modify, update or erase your information
on the basis of your request, unless otherwise required to do so
under law;

· You have the right to readily available means of raising

grievances with regard to any processing of your personal data by
us by writing to us at the details outlined in this notice. In the event
that you are not satis ed with the response provided, you have a
right to approach any data protection authority or board in
accordance with law;

· You have the right to nominate another individual who would

exercise your rights with regard to your personal data being
processed by us in the unfortunate event of death or incapacity, in
accordance with law.

8. Grievance Redressal

You may reach out to our designated of cer below in case of any
queries, concerns or grievances you may have regarding our
processing of your personal data. The details of the same have
been speci ed below.
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Data Protection Of cer
Email Address: [email protected]

APPENDIX 7

PRIVACY NOTICE (MEXICO)

This privacy notice relates to website visitors, members or

membership applicants, customers or prospective customers,
attendees at our events, subscribers to our publications or
newsletters or with which you otherwise engage or communicate
residing in Mexico and amends the Privacy Notice in the following
respects:

I. For purposes of Mexican law, this is your Privacy Notice (Aviso de

Privacidad).

Ii. The address of the controller in Mexico is located at Calle

Versalles No. 28, Colonia Juárez, Cuauhtémoc, CDMX, C.P. 06600.

Iii. The following sensitive personal data is going to be processed by

us:

· Health/disability information.
· Dietary requirements.
· Religious beliefs.

Iv. With respect to the processing of your personal data, only the
following are considered to be the primary purposes:

Website visitors, customers or prospective customers, membership

applicants, members, attendees at our events, subscribers to our
publications or newsletters or other individuals who engage or
communicate with us:

· Processing purchases and transactions.

· Dealing with and responding to enquiries and communications.
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· Managing our business, operating our Sites, providing, and
evaluating our messaging services, facilities, and events.
· Providing our goods and services.
· Our internal business purposes and technical operations,
troubleshooting, data analysis, audit and testing.
· Sending you important information regarding our Sites, changes
to our terms, conditions, and policies, or other administrative
information.
· Enforcing our terms and conditions and policies.
· Providing you with customer/user support and to contact you for
public health reasons.
· Complying with government guidelines, regulations, and
mandates.
· Obtaining legal advice and/or to protecting us, our staff, members
and customers and the public against injury, theft, legal liability,
fraud, abuse, and other misconduct.
· Complying with legal and regulatory requirements or demands in
accordance with applicable law, a court order, subpoena, or other
legal process.
· Facilitating the sale or potential sale of our business or part of our
business.

Membership applicants
· Acknowledging, con rming, and dealing with your membership
application and assessing your suitability for membership (and
where necessary put you on our waiting list).
· Evaluating your application.
· Automatically creating a user account in our system with the data
provided by you.
· If you have opted into receiving SMS/WhatsApp messages from
us, we may also send messages to you and collect mobile data on
you about membership and the membership application process.

Members
· Providing you with membership services, administering your
membership account, contacting you regarding your use of the
services (including sending con rmations or pre-arrival messages)
and assisting you with meetings, events or celebrations.
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· Checking you maintain the conditions of membership when you
are asking for the renewal of your membership.
· Enabling you to create a member account and log in to it via our
Sites.
· Processing information relating to your bookings, including
completing your room reservations, providing services to you and
answering any queries you may have.
· Keeping proper records of your stays at our locations and data
related to such transactions.
· Collecting information regarding your visits to our locations,
restaurants, spas, workspaces, and gyms for capacity planning
purposes and to comply with government guidelines, regulations,
and mandates.
· If you have opted into it, sending SMS/WhatsApp messages to
you and collecting mobile data about your membership and use of
our services.
· Processing information about you when you act as a proposer for
a prospective new member.
· Enabling you to socialise on our Sites and our messaging
platform and to allow other members to identify you via your shared
interests if you consent to this through our Site preferences.

Website visitors, event attendees, customers, and publication

subscribers
· Enabling you to create an account and log in to it via our Sites.
· Completing your ticket purchase for attendance at our events.
· Planning and hosting corporate events and hosting online forums
and social networks in which event attendees may participate.
· Assessing access and the suitability of our locations and/or
events and for catering purposes.

All of the other purposes are considered as secondary purposes

and do not give rise to, or are not necessary for, a legal relationship
between the controller and the data subjects.

In the event that you do not want your personal data to be

processed for these secondary purposes, please send an email to
the following email address [email protected], indicating your
refusal to permit the use of your personal data for the above-listed
secondary purpose or purposes.

V. Additionally, in relation to the rights described in Section 12 of the

Privacy Notice, you also have the following right with respect to
your personal data: limitation on use and disclosure of your
personal data. Please note that the right of data portability is not
applicable in Mexico.

In order to exercise any of your rights with respect to your personal

data, please follow the following procedure:
· Submit a request in writing to us through the following email
[email protected], which must contain the following
information:
o your full name and email, or other appropriate means to
communicate the response to your request;
o the documents that prove your identity or, where appropriate,
that of your legal representative;
o a clear and precise description of the personal data with respect
to which you seek to exercise any of your rights; or the statement
that you wish to limit the use and disclosure of your personal data;
and
o any other element or information that facilitates the location of
the personal data, as well as any other document required by
current regulations at the time of submitting the request.
· You may also request further information on the procedure to
exercise your rights by contacting us at the above email address.

We will respond to your requests in accordance with the terms,

conditions and deadlines established under the applicable law.

6. With respect to the use of cookies to process your personal data,

please note that these cookies may be disabled in accordance with
the settings on the use of cookies on the browser or internet service
you are using (for more information on how to disable such cookies,
please see here.
 7. We reserve the right to modify and/or update this privacy notice,
in some or all of its parts, at its sole discretion, in which case it will
communicate it by publishing the updated version with the last date
of modi cation on the Sites, where it will be updated and displayed
so that you can review it at any time.

8. Date of the last update: May 24th 2024.

APPENDIX 8
PRIVACY NOTICE (TÜRKIYE)

This privacy notice relates to website visitors, members or

membership applicants, customers or prospective customers,
attendees at our events, subscribers to our publications or
newsletters or with which you otherwise engage or communicate,
living in Türkiye and amends the Privacy Notice in the following
respects:
Processing of sensitive personal data
If Turkish law is applicable to your personal data, the information
relating to 'sensitive personal data' (also known as 'special
categories of personal data') in Section 5 of the Privacy Notice is
replaced as follows:
1. What are our lawful bases for processing your personal data?

Sensitive personal data:

Personal data relating to race, ethnic origin, political opinion,

philosophical belief, religion, sect or other beliefs, appearance and
dress, membership to associations, foundations or trade unions,
health, sexual life, criminal convictions and security measures, and
biometric and genetic data are sensitive personal data.

We may process data relating to your race, ethnic origin, religion,

sect or other beliefs, appearance and dress and health on the basis
of your explicit consent.

Purposes of processing:
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 On the other hand, personal data relating to health and sexual life
may be processed without your explicit consent only for the
purposes of protection of public health, preventive medicine,
medical diagnosis, treatment and care services, planning and
management of health services and nancing, by persons or
authorized institutions and organizations under the obligation of
con dentiality.

For website visitors, customers or prospective customers,

membership applicants, members, attendees at our events,
subscribers to our publications or newsletters or any other
individuals who otherwise engage or communicate with us - we may
process your sensitive personal data for the purposes detailed in
Section 6, 'How and why do we use your information?' in the
Privacy Notice.

For membership applicants - in addition to the purposes detailed at

Section 6, 'How and why do we use your information?' in the
Privacy Notice, we may also process your sensitive personal data
for the purposes detailed in Section I, 'For what additional purposes
do we use membership applicant information?' of the Privacy
Notice.

For members - in addition to the purposes detailed at Section 6,

'How and why do we use your information?' in the Privacy Notice
we may also process your sensitive personal data for the purposes
detailed Section II, 'For what additional purposes do we use
member information?' of the Privacy Notice.

For website visitors, event attendees, customers, and publication

subscribers - in addition to the purposes detailed at Section 6, 'How
and why do we use your information?' in the Privacy Notice, we
may also process your sensitive personal data for the purposes
detailed Section III, 'For what additional purposes do we use your
personal information?' of the Privacy Notice.

Data sharing
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 If Turkish law is applicable to your personal data, the following
information is added to Section 7 of the Privacy Notice:
2. Do we share the information we receive?

We are a global organization that operates in many countries.

Therefore, we can share your personal data among our group and
af liated companies, service providers, other third parties, public
institutions and organizations, consultants and law of ces
established in Türkiye and/or the European Union/European
Economic Area (“EEA”) and/or other countries by complying the
requirements established under Article 8 and 9 of the Personal Data
Protection Law numbered 6698 (“PDPL”) to ful l the purposes
established under this Section 7 (Do we share the information we
receive?). We have implemented and maintain appropriate
technical and organisational security measures with respect to such
data sharing.

Legal grounds

If Turkish law is applicable to your personal data, the following

information is added to Section 6 of the Privacy Notice as follows:

Personal data transfers within Türkiye

Your personal data is transferred by us to our group and af liated

companies, our business partners, third party service providers,
suppliers, public institutions and organizations, consultants and law
rms established in Türkiye based on the legal grounds listed below
to ful l the purposes established under Section 7 (Do we share the
information we receive?). We have implemented and maintain
appropriate and adequate security measures with respect to such
data transfers.

Legal grounds:
· Processing of personal data is explicitly provided for by the law.
· Processing of personal data of the parties to a contract is
necessary, provided that it is directly related to the establishment or
performance of the contract.
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· Processing is necessary for us to ful l our legal obligations.
· Processing is mandatory for the establishment, exercise, or
protection of a right.
· Processing is mandatory for the protection of the life or physical
integrity of the data subject who is unable to provide his/her consent
due to actual impossibility or whose consent is not legally valid.
· Personal data has been made public by the data subject.
· Processing of data is necessary for the legitimate interests
pursued by the data controller, provided that this processing shall
not violate the fundamental rights and freedoms of the data subject.

Your name, surname, email address and/or telephone number are

processed within the scope of advertising and marketing activities
upon your explicit consent and transferred to the third-party service
providers and suppliers.

Sensitive personal data (such as health data) can only be

transferred with your explicit consent in line with the conditions for
data transfer stipulated under the PDPL.

Cross-border personal data transfers

If Turkish law is applicable to your personal data, Section 8 of the

Privacy Notice is replaced as follows:

3. Is your personal data sent outside your home country?

In order to ful l the purposes established Section 7 (Do we share

the information we receive?), Soho House transfers your personal
data among our group and af liated companies, its service
providers, and other third parties located outside Türkiye and
in case of the existence of a legal ground listed under Section 6
(Personal data transfers within Türkiye), personal data can be
transferred outside Türkiye without your explicit consent under the
following conditions:

· If the recipient country to which personal data will be transferred

has an adequate level of protection; or
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· In the absence of an adequate level of protection, the data
exporter and the data importer undertake an adequate level of
protection in writing and obtain the Personal Data Protection
Authority’s approval (or approval of Binding Corporate Rules).

Sensitive personal data (such as health data) may be transferred

outside Türkiye with your explicit consent in line with the conditions
for data transfer stipulated under the PDPL.

Your personal data protection rights

If Turkish law is applicable to your personal data, Section 12 of the

Privacy Notice is replaced as follows:

4. What are your personal data protection rights?

You have the following rights regarding your personal data under
the PDPL:

· To learn whether any of your personal data is being processed;

· To request information if personal data has been processed;
· To learn the purpose of the processing personal data and whether
they are used in compliance with the purpose;
· To know the third parties to whom your personal data is
transferred within the country or abroad;
· To request the recti cation of your incomplete or inaccurate data
(if any);
· To request the erasure or destruction of your personal data;
· To request reporting of the transactions of recti cation or disposal
to third parties to whom your personal data have been transferred;
· To object to the occurrence of an unfavourable result against you
as a result of analyzing the data processed solely through
automated systems; and
· To claim compensation.

In order to exercise the aforementioned rights, you shall convey

your request in writing, along with the information that will enable
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your identi cation, to us through the following means of
communication:
a. via e-mail to [email protected],;
b. via mail to the address Evliya Çelebi, Meşrutiyet Cd. No:56,
34430 Beyoğlu/İstanbul, Türkiye; or
c. via our application form.

In order for your request to be responded quickly, “Personal Data

Information Request” should be written on the application envelope
and/or the subject of the email.

Your submitted requests will be responded within 30 (thirty) days

from the date of receipt of your request, depending on the nature of
the request. If the information and documents you submit to us are
incomplete or incomprehensible, we will contact you to clarify your
request.
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