PLEASE READ THIS PRIVACY POLICY CAREFULLY

The privacy notice, while specific to the use of the Beazley Group App (The App) should be read in conjunction with the privacy notice published on the Beazley website:

https://www.beazley.com/london_market/privacy_and_cookies_statements.html. This Privacy Policy sets out how we will use your personal data when you set up a Beazley Group app account with us by downloading our Beazley Group mobile application (The App) or via our website https://app.beazleygroup/ (Site).

As part of your account set up, you will be asked to give various permissions and or consents depending on what level of service you wish to receive. Please note that you must provide certain minimum permissions and or consents as explained when you download the App in order to use the App and Service. If you do not wish to give that permissions and or consent, you should not continue to log-on to The App

Many of the Services are dependent on data sent from your devices, either location and / or Bluetooth capability. The use of location data and or bluetooth is required to improve the speed and accuracy of your mobile pass. This data is not stored by The App. The use of location and / or Bluetooth data may be used for elements such as an access card for the building and Beazley floors. The use of the functionality will only occur when a door reader, speed lane reader, lift call reader or any other registered building access reader, which you are permitted access control to, are detected. At the point a registered building access reader is detected, The App is not logging or storing your location. Your location is only required to confirm you are present at the point of access, in order for a registered building access reader to accept the your authorised access credential.

You will be notified on download and are required to select your location services preference and opt-in to either “Allow while app is in use” or “Allow always”. Depending on which option is chosen will determine when The App can access your location:

• If “Allow while the app is in use” is selected, you are permitting The App to know your location for the purposes of door access only, while The App is open on your device.
• If “Allow always” is selected, you permit The App to know your location for the purposes of access only, while the app is closed on their device.

You can turn off tracking and stop us collecting such data at any time by turning off the location and / or bluetooth services or the permissions for The App on your device. Please note that many of The App’s functions will not be available while location and / or bluetooth services permissions are turned off.

WHO WE ARE

We are D2 Interactive Limited (Company Registration No. 7116878, VAT No. 984-4271-88, Registered Office: Ground Floor Portsoken House, 155-157 The Minories, London, England, EC3N 1LJ). We will be hosting and manaaging the App on behalf of the Beazley Group.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:

• Information you or your organisation 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 sign-In to use The App, download or register The App, subscribe to any of our Services, make an in-App purchase, share data via The App's social media functions, enter a competition, promotion or survey and when you report a problem with The App, our Services, or our Site. If you contact us, we will keep a record of that correspondence.
• The information you or your organisation provide us may include your name, address, e-mail address and phone number, device's phone number, age, username, password and other registration information, personal description and photograph 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);
  • details of your use of the App or your visits to our Site including, but not limited to traffic data, weblogs and other communication data,
• Should you use the access control functionality of the App, information stored in the access control systems at the location, as well as any accompanying CCTV footage.
• Your preferences for temperature, lighting and fan settings.
• Location / Bluetooth information. We also use location and / or bluetooth technology to enable the provision of services. 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 access 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, advertising networks, analytics providers, search information providers,). We will use this personal data either where you have provided your consent to the third party or to Beazley Group to allow that data sharing taking place, or where Beazley Group 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}.

We use cookies to distinguish you from other users of the App and our Site. This helps us to provide you with a personalised experience when you use the App or browse our Site and also allows us to improve the App and our Site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Statement.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• Submitted information: to provide and tailor Services directly to you; communicate with you; select offers which are of most interest to you.
• Profile information: to identify that you are authorised to access the building and services of Beazley Group, in adherence with the building’s stringent security protocols.
• Device information: to determine how many people use The App on particular type of devices so that we can ensure adequate technical support for each type of device.
• Content information: to make it easy for you to populate your public account page and join in any social networking, chat room or forum features provided within The App or via the Site
• Location information: via location and / or bluetooth 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. Third Party information: to monitor performance of the Service, to protect you and other people from fraud or misuse of the Services.
• Research information: we will anonymise the information that we collect in order to use it for future research into how buildings operate and are used.

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 and any applicable legal or regulatory requirments for as long as it is combined.

OUR PARTNERS

When a Beazley Group app account is provided to you, 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.

In the event a Partner ceases to participate in the Beazley Group App Service, you will be notified, and we will communicate to you any revised privacy policy. In the event of such withdrawal, you may request for the deletion of any relevant personal data from the withdrawn Partner’s database.

You may also close your account with us and require us to delete all your information as explained above in the section called “Information We Collect From You”

Our partner for the Beazley Group app is:

Name:

Address:

REGISTERED NUMBER:

OTHER THIRD PARTIES

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 as part of the provisions of service, 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, Privacy Policy 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 logging Into a Beazley Group app account, you can choose to create a public profile. This expressly acknowledges and agrees that the following information will be publicly available:
• Your name
• Your profile picture
• Anything you post on your public account page or in any social networking, chat room or forum features provided within the App or via the Site.

When posting on your public profile page or in any social networking, chat room or forum features, you should ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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@smartspaces.app. 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 may be transferred to, and stored at, a destination outside the European Economic Area (EEA). If it is, then we will notify your organisation of such transfer and ensure that any such transfer is in accordance with data protection law with adequate protection. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. 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 AND YOUR PREFERENCES

As available and except as limited under applicable law, the rights afforded to individuals are:

• Right of Access: the right to be informed of and request access to the personal data we process about you;
• Right to Rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to Erasure: the right to request that we delete your personal data;
• Right to Restrict: the right to request that we stop processing all or some of your personal data;
• Right to Object: the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
• Right to Object to your personal data being processed for direct marketing purposes;
• Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to automated decision making: the right to not be subjected to a decision based solely on automated decision making, including profiling where the decision would have a legal effect on you.

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 the Beazley Data Protection Officer or us via the App or by email to privacy@smartspaces.app.

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.

ACCESS TO INFORMATION

We will retain your personal information for as long as you use The App and for a reasonable time thereafter (as specified in Data Retention below). If you'd like us to delete your personal information, please contact the Beazley Data Protection Officer or us at privacy@smartspaces.app 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 RETENTION

You have the right to access information held about you. You may request a copy of your information by contacting the Beazley Data Protection Officer emailing us at privacy@smartspaces.app

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 https://www.smartspaces.app/ 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@smartspaces.app

QUESTIONS

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.