Privacy Policy

JTP London Privacy Policy

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
JTP London app or any information provided when requesting support.

If you are a guest visiting JTP London, we received your First Name, Last
Name and Email Address or Phone Number from the person who invited you or
directly from you when you checked in at Reception. This information is
processed solely to facilitate your visit.

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 JTP London app account with us by downloading our JTP London mobile
application (App). 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 JTP London 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 collected when registering for the app may include your name,
e-mail address, password and device information. Additional information may
be requested to use services within the app, these services are optional.

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, 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

This app collects location data to enable your Mobile Access Pass to work
when the app is in the background or when the app is not in use. This
permission is only required for the mobile pass feature to work correctly.
This location data is not stored or uploaded and is only used for the
purposes of allowing your device to connect with a reader. You can withdraw
your consent at any time by adjusting the privacy settings on your device.

This app collects location data to enable a number of employee location-based
services. These services are optional at the discretion of the employee by
enabling Bluetooth within the settings of the app and/or Phone.

The app collects data to enable reporting on space use, your specific
location however will be anonymised by discipline and grades, and only
time-aggreged KPIs will be used to generate space utilisation insights e.g.
meeting rooms X% utilised by Y% of disciplines and Z grades. This is
ultimately to review the facilities provided and enable future changes to
better support your needs.

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.

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 (JTP London) for that data sharing taking place, or
where (JTP London) has a legitimate interest to use the personal data in
order to provide you with its service.

We will collect and process the following data about individuals who are
invited into JTP London via the App, Website or who check in at Reception via
the Service:

Their name, e-mail address and phone number.

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 JTP London.

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 JTP London, 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 use information held about a visitor solely for the purpose of
facilitating their visit to JTP London.

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 JTP London 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 JTP London 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 JTP London 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 JTP London 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.

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

There 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 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 dpo@smartspaces.app.

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 dpo@smartspaces.app.

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 dpo@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.

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 dpo@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 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
dpo@smartspaces.app.

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.