• We are D2 Interactive Ltd t/a Smart Spaces (Company Registration Number: 07116878, VAT No. GB984427188). With a registered office at Ground Floor, Portsoken House, 155-157 Minories, London, England, EC3N 1LJ, we are committed to looking after your data and have ISO:27001 and Cyber Essentials Plus Certification.
• We only store the data you voluntarily give to us when using this app such as First Name, Last Name and Email Address when signing up for an account on the 22 Bishopsgate app or any information provided when requesting support.
• We cannot see or access anything on your phone outside of this app, unless you willingly volunteer that information to us.
• We use your data to allow access to the building, use of amenities, communications about the building, provide support, improve the services and all other applicable and reasonable purposes to ensure the app functions correctly.
• Your data is stored in a data centre within the UK.

PLEASE READ THIS PRIVACY POLICY CAREFULLY

This Privacy Policy sets out how we will use your personal data when you set up a 22 Bishopsgate app account with us by downloading our 22 Bishopsgate mobile application (App) or via our website https://app.22bishopsgate/(Site). As part of your account set up, you will be asked to give various consents depending on what level of service you wish to receive. Please note that in some circumstances we may need your consent in order for you to use all or part of the App and Service. If you do not wish to give these consents, you will not be able to open a 22 Bishopsgate app account.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

• Information you give us (Submitted information): This is information you give us about you by filling in forms on the App and/or our website https://www.smartspaces.app/ (our Site), or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, make an in-App purchase, and when you report a problem with an App, our Services, or our Site. If you contact us, we will keep a record of that correspondence. 
• The information you give us may include your name, address, e-mail address and phone number, device's phone number, age, username, password and other registration information, financial and credit card information, personal description and other preferences.
• Information we collect about you and your device. Each time you visit our Site or the App we will automatically collect the following information:
  • Technical information, including the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by your device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting (Device Information);
  • Ddetails of your use of the App or your visits to our Site including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information).
• Should you use the access control functionality of the App, information stored in the access control systems at the location.
• Location information. We also use GPS technology or your access to the internet via Wi-Fi to determine your current location. Our location-enabled Services require your personal data (longitude and latitude) for the feature to work. You will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time via the App by adjusting the privacy settings on your device. This may result in those Services which rely on that data no longer operating within the App. If you do not grant permission for your location data to be accessed, we will not collect such data.
• Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services). We will use this personal data either where you have provided your consent to the third party or to (22 Bishopsgate) for that data sharing taking place, or where (22 Bishopsgate) has a legitimate interest to use the personal data in order to provide you with its service.

Users' Image Information (Photos)

Data collected, and for what purpose:

• Photos (Optional) for App functionality

Our website and application may collect user images for various purposes, such as profile pictures or content submission. Please be aware that any images submitted to our platform may be stored on our servers for future use. However, we do not share these images with third parties; they are only used for internal purposes, such as uploading profile images, or content for the app.

By submitting an image to our platform, you acknowledge and consent to our collection and storage of your image.

Data Retention (Request to delete)

If you'd like us to delete your personal information, please contact us at dpo@smartspaces.app and we will respond within the time limit prescribed by law. Please note that we may be required to retain certain information by law.

Upon request, we will delete or anonymise your personal data or any visitor’s data so that it no longer identifies you or that visitor, unless we are legally required to retain such information. This includes, but is not limited to:

• Being required to retain certain personal data for legal, tax, audit and accounting obligations. We will retain the necessary information for the period required by applicable law; and/or
• Where necessary for our legitimate interests, such as fraud prevention and security measures.
• Except where we are required to retain personal data as set out above, we will delete all personal data within six (6) months of our Partner ceasing to operate a subscription with us to provide our services at {APP NAME}.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• Profile information: to identify that you are authorised to access the building and services of 22 Bishopsgate, in adherence with the building’s stringent security protocols. We need this information in order to perform our contract with you.
• Submitted information: to provide and tailor Services directly to you; communicate with you; select offers which are of most interest to you. We rely on either consent or our legitimate business interests to process personal data in this case.
• Device information: to determine how many people use the App on a particular type of device so that we can ensure adequate technical support for each type of device. We either rely on performance of our contract with you or our legitimate business interests to process personal data in this case.
• Location information: to enable the app to verify your location within the permitted zone to utilise the app; to enable you to benefit from auto-check-in features in the Service. We either rely on your consent or performance of a contract with you in order to process personal data in this case.
• Third Party information: to monitor performance of the Service, to protect you and other people from fraud or misuse of the Services. We rely on our legitimate business interests to process personal data in this case.
• Research information: we may anonymise the information that we collect in order to use it for future research into how buildings operate and are used. We rely on our legitimate business interests to process personal data in this case.

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

OUR PARTNERS

When you open a 22 Bishopsgate app account, we may provide the Service in conjunction with one or more partner businesses (Partners) who may offer additional services or features to enhance the app. The details for our partner for the 22 Bishopsgate App are set out below. You can withdraw or suspend your consent at any time but you will not then be able to use the App to utilise these services or features.

We will disclose your account information and personal details to the Partner(s). They will each be a Data Controller for the purposes of the Data Protection Act 2018 and the UK’s General Data Protection Regulation (GDPR). For as long as they participate in the 22 Bishopsgate app, they have agreed to comply with the terms of this Privacy Policy in how they handle your data. In the event a Partner ceases to participate in the 22 Bishopsgate app Service, you will be notified and they will communicate to you any revised privacy policy they wish to adopt. If you do not wish to accept their revised privacy policy, you may decline to give consent and they will be obliged to delete your account information and personal details. You may also close your account with us and require us to delete all your information as explained below in the section called your rights.

Our partner for the 22 Bishopsgate app is:

22 BISHOPSGATE LIMITED PARTNERSHIP acting by its general partner 22 BISHOPSGATE GENERAL PARTNER LIMITED (incorporated and registered in England and Wales under company registration number 09398335) the registered office of which is at 8th Floor, 155 Bishopsgate, London EC2M 3XJ

OTHER THIRD PARTIES

We do not disclose information about identifiable individuals to our advertisers or other third parties except as noted below in Permitted Disclosures, but we may provide them with anonymous aggregate information. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We will use the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

We may also ask your consent to share some of your app history data to third parties (but only that data which is relevant to each third party). You do not have to give that consent and you can withdraw or suspend it at any time. Some offers or features from a third party may, however, only be available to you if you agree to share relevant app history data with that third party.

PERMITTED DISCLOSURES

You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may also disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

If D2 Interactive Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

In order to:

enforce or apply our Terms of Use, Terms and Conditions of our Site and other agreements or to investigate potential breaches; or

protect the rights, property or safety of D2 Interactive Limited, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

YOUR PUBLIC PROFILE

By default your public profile will be hidden however by accepting this privacy policy, you acknowledge that your public profile, whether hidden or not, can still be viewed by certain key users (including, but not limited to Events Management, Administrator and Receptionist roles), in order to allow them to receive support queries and chat messages from hidden accounts.

CHILDREN

We do not use the App to knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@d2i.co.uk. We will delete such information from our files within the time limit prescribed by law.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be stored in a datacentre within the UK. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using industry leading encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We strongly recommend you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

TThere are multiple opt-out options for users of the App even where you have already given your consent to a specified use of your personal information:

• Opt-out of all information collection by uninstalling the App
• Opt-out of allowing us to have access to your location data
• Opt out of us processing your personal information for marketing purposes

We will always inform you (before collecting your personal information) of how we plan to use that personal information. You can exercise your right to prevent such processing by checking certain boxes on the App when you open your account or afterwards by adjusting the privacy settings in the App. You can also exercise the right at any time by contacting us via the App or by email to privacy@d2i.co.uk.

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You may request a copy of your information via the function on the App or by emailing us at privacy@d2i.co.uk.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please email privacy@d2i.co.uk.

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

RETENTION OF INFORMATION

We will retain your personal information for as long as you use the App and for a reasonable time thereafter. If you'd like us to delete your personal information, please contact us at privacy@d2i.co.uk and we will respond within the time limit prescribed by law. Please note that some or all of your personal information may be required in order for the Application to function properly, and we may be required to retain certain information by law.

Data will be retained in our records for no longer than is necessary to:

• Provide you with the services you have requested
• Comply with statutory guidance
• Support a claim or defence in court

CHANGES TO PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on our Site at d2i.uk and notified to you when you next use the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Privacy Team, D2 Interactive Limited or emailed to privacy@d2i.co.uk

QUESTIONS

Who is your Data Protection Officer? Mr Daniel Drogman, D2 Interactive Limited t/a Smart Spaces, who can be contacted using the contact information shown above.

Where is the legal document? GDPR explicitly asks for plain text documentation. This is the legal document.

How do I invoke one of my rights? You can request any of the rights in this document by talking to or sending an email to any of our staff. They have all been trained to handle requests in an expedient manner.