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 LBG@Wellington Place app or any information provided when requesting support.
If you are a guest visiting LBG@Wellington Place, 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.
This Privacy Policy sets out how we will use your personal data when you set up a LBG@Wellington Place app account with us by downloading our LBG@Wellington Place 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 LBG@Wellington Place app account.
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:
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.
Data collected, and for what purpose:
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.
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 (LBG@Wellington Place) for that data sharing taking place, or where (LBG@Wellington Place) 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 LBG@Wellington Place via the App, Website or who check in at Reception via the Service:
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:
We use information held about you in the following ways:
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.
When you open a LBG@Wellington Place 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 LBG@Wellington Place 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 LBG@Wellington Place 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 LBG@Wellington Place 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.
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.
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.
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.
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.
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.
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:
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:
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.
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:
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.
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.
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.