Privacy policy

Privacy policy

This policy was last updated on 25th May 2022

Introduction

SpaceThreeTwo Limited (Space32, we or us) cares about the privacy of your personal information and is committed to protecting it. This Privacy Policy (Policy) explains what information we collect about you and why, what we do with that information, and how we handle that information.

For the purposes of all applicable data protection laws (including the General Data Protection Regulation (Regulation (EU) 2016/679) as incorporated into UK law (UK GDPR) and the Data Protection Act 2018), the data controller with responsibility for your personal data is Space32. This Policy applies to personal data obtained by us through your use of our website at Spacethreetwo.com (“Website”) including when you register as a Space Provider or a Space Seeker (or do so on behalf of a business).

Collection of your personal information

Space32 collects information that, alone or in combination with other data, could be used to identify you (Personal Data), such as your e-mail address, name, physical address or telephone number. Space32 may also collect anonymous information where your identity has been removed (Non-Personal Information). Personal Data does not include Non-Personal Information. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier and title.
• Contact Data includes address, billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes computer hardware and software, internet protocol (IP) address, your login data, browser type and version, domain names, access times, time zone setting and location, browser plug-in types and versions, operating system and platform, referring website addresses, pages visited, links clicked, text entered, internet service provider and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, services you have registered for, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website and services.
• Marketing and Communications Data includes your search criteria in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you or a business that you represent, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or the business that you represent (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How we collect your Personal Data

Space32 will collect your Personal Data in a number of ways, including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or when you contact us through the Website, by telephone, post, e-mail or through any other means. This includes Personal Data you provide when you:
• register for a Space32 account including for a business that you represent;
• request marketing to be sent to you; or
• give us feedback or contact us.

• Information from third parties or publicly available sources.

  We collect Personal Data about you from third parties and publicly available sources as set out below:

• Identity and Contact Data from publicly available sources such as social media networks;
• Technical Data from analytics providers such as Google based outside the EU;
• Identity and Contact Data from any space providers for whom we act as agent (i.e. third parties who have registered with us to market their office space) (“Space Providers”).
• Identity and Contact Data from space seekers (i.e. potential occupiers of office spaces) (“Space Seekers”).
• Identity and Contact Data from other third parties.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details.

Use of your Personal Data

Space32 collects and uses your Personal Data where the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform or administer any contract we are about to enter into or have entered into with you or a business that you represent;
• Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests; and Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data.

Purposes for which we will use your Personal Data

We have set out in the Schedule to this Policy, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the Schedule.

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time[insert email address]. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us in connection with the performance or administration of a contract we have with you or an organisation that you represent.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Storage of Personal Information

Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this Policy, or until you request that the information be deleted in accordance with your right of erasure (see "Your rights" section below).

We reserve the right to maintain a copy of your Personal Data for legal, tax or regulatory purposes, but in such event, we will do so only as long as necessary to fulfil those legal, tax or regulatory purposes. Otherwise we will hold your Personal Data for a period of 12 months after our last contact.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. If you are a Space Provider or a Space Seeker, we will also anonymise your Personal Data and create a profile for you on our Website to market opportunities for you. Your profile will be used to identify a match with other Space Seekers or Space Providers.

Personal Information access and disclosure

We may share your Personal Data with the third parties set out below for the purposes set out in the table in the Schedule to this Policy:

• we will share a Space Seeker’s Identity Data with a Space Provider once a viewing has been arranged between the Space Seeker and that Space Provider. If you (or the business that you represent) intend to enter into an agreement with a Space Provider, we will share your name, email address and phone number with that Space Provider. If you (or the business you represent) enter into an agreement with a Space Provider, any such Space Provider will act as data controller and will process your Personal Data for its own purposes in accordance with its own privacy policy which will be provided to you by the relevant Space Provider at that time;
• if you are or represent a Space Provider we will share your Personal Data with prospective Space Seekers who have registered for our services and other agents once a viewing has been arranged between you;
• when we use vendors, lawyers and service providers to assist us in meeting business or operating needs, such as providers of legal services, auditing services, insurance services, Website hosting services, IT services, and invoicing and payment services;
• we may share Personal Data with HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances; and
• we may share Personal Data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We may also share your Personal Data with other third parties when we have your explicit consent to do so; or when we determine that disclosure is required to protect the rights, property, or personal safety of Space32 and/or users of the Website, or to respond to lawful subpoenas, warrants, or requests by public or regulatory authorities, including requests by law enforcement authorities.

Transfers outside of the EEA

We do not transfer your personal data outside the UK and the European Economic Area (EEA).

Use of cookies

The Website uses "cookies" to help you personalise your online experience. A cookie is a text file that is placed by us or our remarketing partners on your hard drive by a web page server. Our cookies do not run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server in the domain that issued the cookie to your computer.

One of the primary purposes of cookies is to provide a convenient feature to save you time. The cookie tells the server that you have returned to a specific page. For example, if you personalise the Website pages, or register with the Website, a cookie helps the Website recall your specific information on subsequent visits. This simplifies the process of recording your Personal Information, such as your billing address or site preferences. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customised.

Cookies

Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make our Website more relevant to your interests and for remarketing as described below.

If you want to check or change what types of cookies you accept, this can usually be done within your browser settings. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

How to reject cookies

If you do not want to receive cookies, you can usually choose to opt-out by modifying your browser settings to decline them. If you choose to decline cookies, you may not be able to access all or parts of, or to fully experience the interactive features of, the Space32 services or web pages you visit.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. This site also provides details on how to delete cookies from your computer.

Data security & integrity

Space32 is committed to taking reasonable and appropriate steps to protect the Personal Data that we hold from being misused, accidentally lost, or accessed in an unauthorised way, altered or disclosed. We do this by using a range of technical and organisational measures including measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your personal information, please let us know immediately. We will notify you and any applicable regulator of a breach where we are legally required to do so.

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

However, while we do our best to protect your Personal Data, we cannot guarantee the security of all data which is transmitted to the Website or to another website via the internet or similar connection. If we have given you (or you have chosen) a password to access certain areas of the Website, please keep this password safe.

Your rights

Under data protection laws, you have various rights in relation to your Personal Data, such as the rights of access, rectification, restriction, objection, portability, and erasure. Please note that these rights are subject to certain limitations set forth in applicable law. You have the right to:

• Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
  • If you want us to establish the data accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise these rights, please contact u (via the contact details set out below). We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of applicable laws. Please note that we may keep a record of your communications to help us resolve any issues you raise.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Complaint resolution

You have the right to file a complaint at any time with the UK Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk). However, we hope that you'll attempt to resolve the complaint with us first. Please contact us for more information.

Links to third party websites

Our Website may include links to third party websites, plug-ins and applications whose privacy practices are not under Space32’s control and we are not responsible for their privacy statements. If you submit Personal Data to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy on any website that you visit.

Children

We do not intend to solicit or collect Personal Data from children. If you believe a child or yours has supplied Personal Data to us, please contact us to have the data removed and to terminate the child's account.

Changes to this Policy and your duty to inform us of changes

We keep our Policy under regular review and will occasionally update this Policy to reflect company and customer feedback. Space32 encourages you to periodically review this Policy to be informed of how we are protecting your Personal Data.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Contact information

Space32 welcomes your comments regarding this Policy. Please contact us at dpo@space32.com, or write to us at:

Space32 Limited

4 Beaconsfield Road, St Albans, Hertfordshire, AL1 3RD

Email: info@space32.com