Privacy policy

Commune Work PRIVACY POLICY Effective date: August 1st, 2026 Last updated: August 1st, 2026 1. Introduction Urban Living Solutions Co., Ltd., operating the Commune Work coworking space in Siem Reap, Cambodia (“Commune Work”, “we”, “us” or “our”), respects the privacy of its members, prospective members, visitors, event participants, website users and other individuals who interact with us. This Privacy Policy explains: what personal information we collect; why and how we use it; the circumstances in which we may share it; how we protect and retain it; and how you may contact us or make a request concerning your information. This Privacy Policy applies to personal information collected through: our website; our coworking and membership-management platform; membership applications and agreements; enquiries, tours and bookings; payment and accounting systems; events and community activities; and other communications and interactions with Commune Work. By providing personal information to us or using our services, you acknowledge that your information will be handled in accordance with this Privacy Policy. 2. Who Is Responsible for Your Information? The organization responsible for collecting and using your personal information is: Urban Living Solutions Co., Ltd. Trading as: Commune Work Address: Rose Apple Rd, Krong Siem Reap 17252 Siem Reap, Kingdom of Cambodia Email: hello@communekh.com Telephone: +855 011 408 271 3. Applicable Legal Framework We process personal information in accordance with the laws and regulations applicable to our activities in the Kingdom of Cambodia. These may include relevant provisions of the Law on Electronic Commerce, the Law on Consumer Protection, and other applicable Cambodian laws and regulations. Cambodia is developing a dedicated personal data protection framework. Until such legislation enters into force, Commune Work applies reasonable internal privacy and information-security practices, including transparency, data minimization, accuracy, appropriate security, limited retention, and responsible handling of personal information. Where the privacy laws of another jurisdiction apply to a particular individual, transaction, or processing activity, we will take reasonable steps to comply with those applicable requirements. 4. Personal Information We Collect The personal information we collect depends on your relationship with Commune Work and the services you use. 4.1 Contact and identification information We may collect: full name; email address; telephone number; residential or business address, where required; nationality; company or organization name; job title or professional information; emergency contact information, where required; a copy of a passport, Cambodian national identity card or another valid government-issued identification document; and a profile photograph, where voluntarily provided or required for account identification. All members, except individuals purchasing a day pass, are required to provide a valid passport, Cambodian national identity card or another government-issued identification document. Identification information is collected for membership registration, identity verification, contractual administration, payment verification, security, and compliance with applicable legal requirements. Day-pass users are not normally required to provide a copy of an identification document. However, Commune Work may request identification where reasonably necessary for security, fraud prevention, payment verification or compliance with applicable law. 4.2 Membership and booking information We may collect information concerning: the membership, office, meeting room, event space or other service requested; membership start and end dates; booking history; account status; invoices and payment status; discounts or promotional offers; membership enquiries, tours and sales communications; member preferences and service requests; complaints, feedback and support requests; and records relating to breaches of our membership rules or agreements. 4.3 Payment and accounting information When you purchase a membership, day pass, office, meeting-room booking, event-space booking or another service, we may collect and process payment-related information, including: billing name and contact details; billing address, where applicable; invoice information; payment amount; payment date and status; transaction or payment reference; bank-transfer information; payment method; information relating to deposits, refunds, discounts and outstanding balances; limited payment-card information made available by the payment provider, such as the card type and last digits; and information required for accounting, taxation, financial reporting, fraud prevention and payment reconciliation. Payments may be processed through ABA PayWay, a bank-transfer service or another authorized payment provider. Complete payment-card details, card security codes and online-banking credentials are normally submitted directly to the relevant payment provider. Commune Work does not normally receive or store this information. Payment and transaction information may be shared with or processed by: ABA PayWay; our banking providers; payment processors; QuickBooks; our accountants and auditors; and other service providers involved in payment processing, invoicing, bookkeeping or financial reporting. Each payment provider processes information in accordance with its own privacy policy and security procedures. Financial and accounting records may be retained for the period required under applicable Cambodian accounting, taxation and commercial laws. 4.4 Website and technical information When you use our website or online services, we may automatically collect: Internet Protocol address; browser type and version; device type; operating system; pages visited; date and time of access; approximate location derived from an IP address; links or features used; referring website; and website performance and diagnostic information. We may collect this information through cookies and tools such as Google Analytics. 4.5 Communications We may keep records of communications with you, including: emails; messages sent through our website; telephone enquiries; communications through Spacebring or another membership platform; customer-support requests; survey responses; and communications through approved messaging or social-media channels. 4.6 Information about visitors and guests Where a member brings a guest or books a service for another person, we may collect the guest’s name, contact details, visit information and other limited details necessary to administer the visit. Members should only give us another person’s information when they are authorized to do so and should inform that person that their information may be provided to Commune Work. 5. How We Collect Personal Information We may collect personal information: directly from you; when you submit an enquiry or membership application; when you sign a membership or rental agreement; when you make a booking or payment; when you create or use a Spacebring account; when you visit or use the coworking space; when you attend an event; when you communicate with our team; through our website, cookies and analytics tools; from a company purchasing services for its employees or representatives; from payment, accounting and technology service providers; and from publicly available professional or business sources, where appropriate. 6. How We Use Personal Information We may use personal information to: respond to enquiries and arrange tours; create and manage member accounts; verify a member’s or authorized user’s identity; prepare and administer membership, office-rental, booking and service agreements; provide coworking, office, meeting-room and event-space services; manage bookings, access, occupancy and service availability; process payments, invoices, deposits, refunds and outstanding amounts; maintain accounting and financial records; communicate operational information; provide customer service and technical support; maintain the safety and security of members, visitors, staff and premises; manage guest registrations; investigate complaints, incidents or breaches of our rules; improve our workspace, services, website and member experience; conduct internal reporting and business analysis; send newsletters, event announcements or promotional communications where you have agreed to receive them or where otherwise permitted; prevent fraud, misuse and unauthorized access; establish, exercise or defend legal claims; enforce our membership agreements, house rules and other contracts; comply with accounting, taxation, regulatory, court or law-enforcement requirements; and carry out another purpose disclosed to you when your information is collected. We will seek to avoid collecting or using more personal information than is reasonably necessary for these purposes. 7. Identification Documents All Commune Work members, except day-pass users, are required to provide a valid passport, Cambodian national identity card or another government-issued identification document. This requirement applies to, as relevant: individual members; fixed-desk members; flex-desk members; private-office members; authorized users of a company membership or private office; and other individuals receiving ongoing membership or workspace entitlement. We collect identification information to: verify the identity of members and authorized users; confirm the identity of the person entering into a membership or rental agreement; administer memberships and contracts; prevent fraud, impersonation and account misuse; maintain the security of the premises and the member community; manage payment, billing and account enquiries; investigate security incidents or breaches of our agreements; and comply with applicable legal, regulatory or public-authority requirements. Day-pass users are not normally required to submit a copy of an identification document. Commune Work may nevertheless request identification where reasonably necessary for security, payment verification, fraud prevention, incident management or compliance with applicable law. Identification documents may include information such as: full legal name; photograph; nationality; date of birth; document number; issue and expiry dates; issuing country or authority; and signature. We will not use identification-document information for advertising or unrelated marketing purposes. Copies of identification documents will be accessible only to authorized members of staff and, where necessary, authorized technology, legal, accounting or compliance service providers. Identification documents will be stored using reasonable security measures and retained only for as long as reasonably necessary for membership administration, contractual, security or legal purposes. Where keeping a full copy of an identification document is no longer necessary, we may delete the copy while retaining a limited record confirming that the individual’s identity was verified. 8. Marketing Communications With your consent, or where otherwise permitted, we may send information about: Commune Work memberships and services; events and community activities; special offers; workspace news; and partner activities that may be relevant to members. You may unsubscribe at any time by: using the unsubscribe link in an email; changing your communication preferences in your account, where available; or contacting us using the details at the end of this Privacy Policy. Unsubscribing from marketing will not prevent us from sending necessary operational communications relating to your membership, bookings, invoices, security or contractual relationship with us. We do not sell personal information to third parties for their independent marketing purposes. 9. Cookies and Analytics Our website may use cookies and similar technologies. Cookies are small files stored on your device that help websites operate, remember preferences, understand usage and improve performance. We may use: essential cookies, which are required for the website or service to function; preference cookies, which remember choices and settings; analytics cookies, which help us understand how visitors use the website; and security cookies, which help detect misuse and protect our online services. We may use Google Analytics to collect aggregated or pseudonymous information about website traffic and usage. You can control or delete cookies through your browser settings. Disabling certain cookies may affect the functionality of our website or online services. Where required, we will ask for your consent before placing non-essential cookies. 10. How We Share Personal Information We may share personal information only where reasonably necessary and with appropriate safeguards. 10.1 Service providers We may share information with service providers that help us operate our business, including: Spacebring, or another coworking and membership-management provider; ABA PayWay, banks and other payment providers; QuickBooks or another accounting provider; Google Analytics and website technology providers; website hosting, cloud-storage and email providers; information-technology and cybersecurity providers; professional advisers, including accountants, auditors, insurers and lawyers; and contractors supporting our operations, where necessary. These providers may process information only to provide their services to us, subject to their contractual obligations and their own applicable privacy requirements. 10.2 Companies purchasing memberships Where a company purchases memberships, offices or other services for employees, contractors or representatives, we may share relevant account, usage, billing or membership information with the company’s authorized contact. We will limit such information to what is reasonably necessary to administer the company’s agreement. 10.3 Legal and safety disclosures We may disclose information: when required by Cambodian law, a court order or another valid legal process; in response to a lawful request from a competent public authority; to protect the rights, property or safety of Commune Work, our members, staff, visitors or others; to investigate fraud, theft, misconduct, security incidents or contractual breaches; or to establish, exercise, or defend legal rights. 10.4 Business transfers If Commune Work or Urban Living Solutions Co., Ltd. is involved in a restructuring, financing, merger, acquisition, sale or transfer of all or part of its operations, relevant personal information may be transferred as part of that transaction. The recipient will be required to handle the information consistently with applicable law and this Privacy Policy, unless you are informed otherwise. 11. International Processing and Transfers Some of our technology and service providers may store or process information outside Cambodia. For example, cloud-based membership, analytics, accounting, payment or communications providers may operate servers or support teams in other countries. Privacy and data-protection standards in those countries may differ from Cambodian standards. Where information is transferred or accessed internationally, we will take reasonable steps to: use reputable service providers; limit the information transferred to what is necessary; apply appropriate account permissions and security controls; review relevant contractual and privacy terms; and require the information to be handled securely and only for the intended purpose. By using our cloud-based services, you acknowledge that such international processing may occur. 12. Data Security We use reasonable organizational, physical and technical measures to protect personal information from: unauthorized access; accidental loss; misuse; alteration; disclosure; and destruction. These measures may include: limiting access to authorized personnel; password protection and multi-factor authentication where available; staff confidentiality obligations; secure cloud services; access controls; software and device updates; secure storage of identity documents; backup and recovery procedures; and secure deletion or destruction practices. No physical or electronic system is completely secure. We cannot guarantee absolute security, but we will take reasonable steps to protect the information under our control. You are responsible for keeping your passwords, access codes and account credentials confidential and for informing us promptly if you suspect unauthorized access. 13. Data Retention We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including to: provide services; manage an active membership; respond to enquiries; maintain business and accounting records; comply with Cambodian tax, accounting and other legal obligations; resolve disputes; manage safety or security incidents; and enforce our agreements. Different types of information may be retained for different periods. As a general approach: unsuccessful sales enquiries may be deleted or anonymized when they are no longer commercially relevant; active membership information will normally be kept for the duration of the membership; contractual, invoicing, payment and accounting records may be kept for the period required by applicable Cambodian law; identity-document copies should be deleted when they are no longer required for verification, contractual, security or legal purposes; marketing information may be retained until you unsubscribe or request deletion; and technical or analytics information may be retained in aggregated or pseudonymous form. At the end of the applicable retention period, information will be deleted, anonymized or securely destroyed where reasonably practicable. 14. Your Requests and Choices Subject to applicable law, contractual requirements and reasonable identity verification, you may ask us to: confirm whether we hold personal information about you; provide access to information we hold about you; correct inaccurate or incomplete information; update your contact details; withdraw consent for optional uses of your information; stop sending marketing communications; delete information that is no longer reasonably required; explain how your information is being used or shared; or raise a concern about our handling of your information. These rights may not be absolute. We may need to retain certain information to: perform an agreement with you; maintain required accounting or transaction records; comply with Cambodian law; resolve a dispute; protect safety and security; prevent fraud; or establish or defend a legal claim. We may ask you to provide sufficient information to verify your identity before processing a request, particularly where the request involves access to or deletion of personal information. We will respond within a reasonable period. 15. Information Relating to Children Commune Work’s memberships and online services are principally intended for adults and organizations. We do not knowingly enter into memberships with individuals under 18 without the involvement and authorization of a parent, guardian, school, employer or other responsible organization, as appropriate. Children may attend certain events or enter the premises when accompanied or properly authorized. Where personal information relating to a child is required, we will seek to collect only the information reasonably necessary for the activity, safety and administration of the visit. A parent or guardian who believes that a child’s personal information has been collected inappropriately should contact us. 16. Third-Party Websites and Services Our website, platform or communications may contain links to websites, payment services, social-media pages or other services operated by third parties. We do not control those third parties and are not responsible for their privacy practices. You should review the privacy policy of the relevant third party before submitting personal information to it. 17. Changes to This Privacy Policy We may update this Privacy Policy to reflect: changes to our services or systems; changes in our information practices; new legal or regulatory requirements; or improvements to our privacy and security procedures. The updated version will be posted on our website or made available through our membership platform. The “Last updated” date at the beginning of the policy will be revised accordingly. Where a change materially affects how we use existing member information, we will take reasonable steps to notify affected individuals before the change takes effect. 18. Contact Us Questions, requests or complaints concerning this Privacy Policy or our handling of personal information may be submitted to: Urban Living Solutions Co., Ltd. Trading as: Commune Work Address: Rose Apple Rd, Krong Siem Reap 17252 Siem Reap, Kingdom of Cambodia Email: hello@communekh.com Telephone: +855 011 408 271 Please include your name, contact details and a clear description of your request. We may contact you for additional information or to verify your identity before responding.