Privacy policy

WorkCo, Inc. and its affiliates ("Toku”, “WorkCo", "WorkDAO", "we", "our" or "us") are committed to respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use information that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies when you use our website or our services (together the “Service”).Please ensure that you have read this Privacy Policy and understood how we collect, store, use and disclose your personal information before using our Service.

WorkCo, Inc will be the controller of the personal information you provide to us when you use the Service. This means that we determine and are responsible for how this personal information is used.

We collect personal information that you submit directly to us when you use the Service. This can include information you provide to us when you interact with our business teams, or when you correspond with us by phone, e-mail or otherwise in relation to the Service. We will indicate to you where the provision of certain personal information is required in order for us to process your request, respond to your query or otherwise provide you with a functionality of the Service.

If you choose not to provide such personal information, we may not be able to provide support or respond to your other requests. We collect personal information that you submit directly to us when you use the Service. This can include information you provide to us when you interact with our business teams, or when you correspond with us by phone, e-mail or otherwise in relation to the Service.

We will indicate to you where the provision of certain personal information is required in order for us to process your request, respond to your query or otherwise provide you with a functionality of the Service. If you choose not to provide such personal information, we may not be able to provide support or respond to your other requests. When you use the service, we we collect the following information:
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- Your contact details, such as your name and email address
- Correspondence, comments and opinions
- When you contact us directly, e.g. by email, phone, through our social media channels or when you complete an online form, we will record your comments and opinions. We use this information to address your questions, issues and concerns
- Improve and Analyze Services​

How we use that personal information

We use this information to communicate with you regarding the Service, including contacting you to promote the Service. The processing is necessary for your employer's legitimate interests, namely communicating with you with regard to the Service.​ We use this information to develop new products and features available on the Service or otherwise improve the Service.

The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns. In accordance with local requirements, we will use this information to contact customers about special promotions, product release notices, and other information we think may be of interest to customers.

​We may also collect other personal information with your consent, which may be revoked at any time, subject to applicable laws.

Where we are responsible for your personal information (i.e., when we are the controller), we will generally store your personal information for no longer than necessary for the purposes set out in paragraph 3, in accordance with our legal obligations and legitimate business interests, and in any event no longer than 12 months after you stop using the Service.​ We may, however, need to retain your personal information for longer if we are required to do so by law.

In addition to the recipients listed in paragraph 3, we may also share your personal information with the following (as required in accordance with the uses set out in paragraph 3):

- Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, processing payments, mailing, email or chat services, fraud prevention, or providing analytic services.
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- Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
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- Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of WorkCo, its users or others.

We implement appropriate technical and organizational measures designed to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, as no protection measure is 100% secure and we cannot guarantee against unauthorized or illegal access, disclosure, modification, or loss of data.​International Transfers of your Personal Information.

The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal information may be processed outside of the EEA including in the United States.In the instance of such a transfer, we ensure that:
- the personal information is transferred to countries recognized as offering an equivalent level of protection; or
- the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold as a controller:

7.1 Right of access
You have the right to obtain:
- confirmation of whether, and where, we are processing your personal information;
- information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal information;
- a copy of the personal information we hold about you.

7.2 Right of portability
You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
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7.3 Right to rectification
You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
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7.4 Right to erasure
You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
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7.5 Right to restriction
You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.​ If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.​

Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.​

We will seek to respond to any request relating to your rights within one month of receipt of such request.​

Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, we will inform you of the extended deadline in which we will respond to your request. Such extension may not be more than two months from the date on which we notify you that an extension is required.​

Where we do not follow up on your request, we will inform you within the one-month deadline of the grounds on which we have based our decision and of your right to refer a complaint to your national data protection authority.

The Service may, from time to time, contain links to and from third-party websites, including those of our partner networks, advertisers, partner merchants, news publications, and retailers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

Our Services are not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the "last modified" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.​​

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.​​

Please contact privacy@toku.com if you have any questions, comments and requests regarding this Privacy Policy. If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.​​

This Privacy Policy was last modified in March 2023.