PLEASE READ THIS PRIVACY POLICY CAREFULLY
This Privacy Policy sets out how we will use your personal data when you set up a MyWorkspace app account with us by downloading our MyWorkspace mobile application (App) or via our website smartspaces.app(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 you must provide certain minimum consents as explained when you download the App in order to use the App and Service. If you do not wish to give that consent, you will not be able to open a MyWorkspace app account.
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 are the Data Controller for the purposes of the Data Protection Act 1998 and, from 25 May 2018, we will be the Controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679).
Please also refer the section below called our partners for the circumstances in which our Partner(s) may also be Data Controllers/Controllers for the purposes of data protection law.
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 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, share data via the App's social media functions, enter a competition, promotion or survey 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 photograph (including your profile picture if you sign up through Facebook) and other preferences.
Each time you visit our Site or the App we will automatically collect the following information:
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, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
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.
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 MyWorkspace 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. 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 1998 and, from 25 May 2018, a Controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679). For as long as they participate in the The Coleman Building 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 MyWorkspace 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 MyWorkspace app is:
ADDRESS: Canterbury Court, Kennington Park, 1-3 Brixton Road, London SW9 6DE.
REGISTERED NUMBER: 02041612
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 opening a MyWorkspace app account, you expressly acknowledge and agree 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.
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.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). 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. By submitting your personal data, you agree to this transfer, storing or processing. 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:
- 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@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.
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@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.
You have the right to access information held about you. You may request a copy of your information via the function on the App or by 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
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:
Any changes we may make to our privacy policy in the future will be posted on our Site at 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.
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
Who is your Data Protection Officer?
GDPR does not require a Data Protection Officer for organisations with less than 250 staff.
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.