At SPACER, we care about the privacy of the people who use our services. This policy explains how we deal with the personal information that you give us.
This policy applies to all interactions you may have with us, SPACER, for example visiting our website, using our free wifi, commissioning works, or hiring our artist spaces.
WHAT TYPE OF INFORMATION DO WE COLLECT ABOUT YOU?
We may collect certain personal information which (either on its own or when combined with other information we hold about you) allows us to identify you as an individual and/or which is about you.
Below is a list that outlines the types of data we collect, depending on which of our services you use:
General Personal Data for Contact and/or Transaction Purposes
– first name(s) and/or surname
– postal address (including billing/shipping addresses and postcode)
– telephone number (including home and mobile phone numbers)
– email address
– payment information (such as debit or credit card details)
General Personal Data from Online Activity
– device information (such as MAC address, IP address, operating system and browser type)
– location information (such as a GPS signal emitted by your mobile device)
– marketing preferences (for example where you have opted in to receive our newsletter(s))
– opinions, preferences, feedback, complaints, comments and/or suggestions (including comments made on our social media pages and online discussion forums)
– online browsing habits, activities and behaviour (such as which of our web pages you have visited and when you visited them)
Other Information from Interactions Not Listed Above
– information necessary for legal compliance (including disability/access requirements)
– preferences, access needs and dietary requirements (for any courses or events we hold)
– employment related information (if you apply for a job, placement, internship or volunteer post)
Please note that this may be updated from time to time as our business needs and legal requirements dictate, so please use this list above as a guideline.
HOW DOES SPACER COLLECT YOUR PERSONAL INFORMATION?
We will usually collect personal information directly from you when you volunteer it to us for contact purposes, or when we gather it to be able to use our services.
We limit our use of personal information to the details we absolutely need to provide the requested or agreed service for you.
Use of our website means you have the choice to allow our cookies, which permit us to understand our audience’s needs, for example what website areas and functions are working and which are not. The information collected here does not identify you as an individual.
We do not normally collect any Sensitive Personal Information (SPI) from or about you, and do not wish to do so unless it is absolutely essential. We may, on rare occasions, collect and use your SPI, such as dietary or access and assistance requirements which may indicate a health condition or illness.
If we need SPI we will ask you to provide us with necessary details only. For example, we may need to collect SPI if you are attending or giving a course or event so that we can help you with any access requirements you might have and to comply with our legal obligations under equality legislation. In other cases, we will collect and use this type of information only with your clear consent. Please do not provide us with SPI under any other circumstances.
On some occasions, we may also collect your personal information from public sources where it is fair and lawful to do so. For example, we may use publicly available information to track down the owner of certain intellectual property rights. These sources may include internet search engine results, or publicly available data from social media platforms (like Facebook), or other information in the public domain.
COLLECTION TYPES AND USES
There are many ways in which your personal data is collected depending on your interaction with SPACER. Examples of this are:
– physical sites; including via the staff, systems and equipment located in our buildings
– our website, specifically our contact form and online shop
– our official social media pages
– communication channels (telephone, SMS/text message, email)
SPACER may also use your personal information to manage and develop the services that we offer, for example to:
– ensure that our data collection and services are provided in the most effective manner for you and the device you are using
– manage and improve our data collection and services
– review and analyse your use of our services in order to develop and improve the quality of our offering and strengthen our relationship with you
– contact you if we have not heard from you for a certain amount of time
– invite you to provide feedback, assist with surveys and input into consultation exercises
– provide you with administrative information and/or announcements and updates; including changes to our policies and terms
– ensure our records are accurate and up to date
– perform any contract SPACER has with you. For example; where you make a purchase in connection with any of our services and we need to process your payment and/or deliver something to you
Other uses of personal information will be to ensure that SPACER can meet its legal, regulatory and good governance obligations (and regulator’s expectations), such as to:
– meet audit requirements
– comply with our contractual/legal obligations
– establish, defend or exercise our legal rights
– comply with orders/requests received from the public and regulatory, governmental and judicial bodies
– comply with our legal, regulatory and internal governance obligations (for example record retention policies)
We may also convert personal information into anonymous data and use it for research and analysis to improve our services, processes and performance. For more information, please see the Converting Your Data to Anonymous Information section directly below.
In carrying out the above, SPACER processes your personal data in a variety of ways, each of which may have a different legal basis. We may process your personal data because:
– You have given your consent (e.g. for the provision of e-marketing correspondence)
– It is necessary for the performance of a contract with you (e.g. the purchase of goods or services)
– We are under a legal obligation to do so (e.g. for equality monitoring or health & safety purposes)
CONVERTING YOUR DATA TO ANONYMOUS INFORMATION
Converting your data to anonymous information does not personally identify you. SPACER will only conduct this for analytical purposes. For example: if feedback has been submitted on our services, we will only utilise the comments and not the personal data.
To find out more about how we collect and use this automatically collected information, please see our Cookies Policy.
Your personal information may be held by us in one or more customer relationship management or CRM database(s), consolidating details of your dealings with SPACER across various services, to ensure we have clear and accurate records about your use of our services, to better understand your requirements and how we might provide other services to you.
Where thought necessary by SPACER, in very limited cases, your personal information may also be shared with other people and organisations outside SPACER to the extent permitted or required by law. For example, we may be required to provide your personal information to:
– government authorities, law enforcement and regulatory authorities where required or permitted by law, and for tax or other lawful purposes
– external parties in response to legal process, and when required to comply with laws, to respond to an emergency, or to enforce our agreements, policies, rules and terms, or to protect the rights, property or safety of our staff, agents, customers and other users of our services
– parties to whom you authorise us to release your personal information
– other entities (including actual or prospective buyers of one of our services) in the event that we are involved in a reorganisation, or sale of any of our organisation and/or assets
Where this is in relation to a specific service you will be informed of the identity and location of the relevant recipient.
Please note that certain individuals who will see your personal information may not be based at SPACER or in your country (please see below).
WILL SPACER SEND YOUR PERSONAL INFORMATION OVERSEAS?
To be clear, the receivers of your personal information may be located in countries outside the European Economic Area (“EEA”) which may not have Data Protection laws equivalent to those in the UK. That being said, through our supplier audits we try and make sure that those who we store data with are GDPR compliant.
Where we (or a Data Processor acting on our behalf) transfer your personal information to countries outside of the EEA, we will put in place such other measures as are required by law to ensure that those transfers are adequately protected.
HOW YOUR PERSONAL DATA IS STORED
We store data both digitally and as hard copies. For processes like accounting, we have to keep both versions of the information we produce.
We make sure that digital data is stored off-site, and held on secure servers via the online services we use.
WHY DO WE COLLECT DATA?
SPACER may use your personal information for a variety of purposes, depending upon the service you have requested or are using. Quite often we will use your data simply to fulfil a request that you have initiated, such as to deal with your enquiry. We will then request further details from you if you were to commission works, for contractual and accounting purposes, or otherwise to provide you with and enable you to use our services.
DOES SPACER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
SPACER makes use of professional third party service providers to perform functions and/or provide services on our behalf (such as email hosting, payment services, e-marketing, and security). These third party service providers (“Data Processors”) may use your personal information in order to assist SPACER or to provide the agreed service to you on our behalf. All of our Data Processors are bound by strict contractual terms in order to ensure that your personal information will be protected appropriately.
SPACER takes data privacy and security of information seriously, so this is a priority when looking into service providers.
Your information is only used within SPACER. This means that employees who need to access your information to be able to conduct their roles within the company are the only ones who use it.
We do not sell or pass on your information to anyone outside of SPACER. If for legal reasons, your data needs to be released then we will follow the necessary protocols to keep you informed.
If you’d like to know more about the providers we use, then please get in touch and we can advise accordingly.
HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
SPACER takes steps to protect the security of your personal information, in accordance with our legal obligations, and as set out in our Information Security Policy.
Please note that we cannot guarantee the security of any transmission of personal information over the Internet. Communications sent over the Internet, such as emails, are not secure, although their security may be increased if they have been encrypted. While we strive to protect your personal information, we cannot guarantee the security of any information transmitted to us over the internet. Therefore, please do not submit personal information to us online unless you accept the security risks of doing so.
Online payments by credit or debit cards for services provided are processed under contract using specialist Data Processors. When a payment is processed by a Data Processor acting on our behalf, card details are collected over a secure link and protected by industry standard software which encrypts your information. We do not collect any payment card account details and they are not made available to us. Our service provider will use the information you provide to process your payment or to refund any monies due to you. Please refer to the terms and conditions for the relevant Service for further details.
We may change this policy from time to time to reflect changes in the law and/or our privacy practices. We will update the date at the bottom of this page whenever we do that.
We encourage you to check this policy for changes, for example when you revisit our websites. In the event of a major change to our policy, we will contact you to inform you of the change.
By submitting your personal information to us, you are indicating that you understand how we use your personal information, as described in this policy.
WHAT ARE YOUR CHOICES RELATING TO CONTACT FROM US?
We may contact you with information that may affect your use of a service, for example, disruptions to Services, problems with orders, or to request your feedback in relation to those services. Administrative e-mails may also be sent automatically following certain actions, for example, welcome e-mails when you register for a Newsletter.
We may wish to provide you with information about new Services, including products, events, courses, promotions and offers from SPACER which may be of interest to you, and we may invite you to take part in market research. We may contact you by email (or in some cases by mail) to tell you this information, but we will obtain your consent before contacting you with marketing material in this way.
We will ensure that any marketing communications that you receive from SPACER provide a simple way for you to decline or change your mind about further communications. For example, in emails SPACER will provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request. SPACER will take steps to stop any marketing to which you object, or in respect of which you withdraw your consent, within one calendar month of being told of your objection or withdrawal of consent.
If you tell us that you no longer wish to receive SPACER’s marketing communications we will take steps to respect your modified marketing preferences and will keep a record of your request so as to avoid contacting you again in the future with marketing content.
RETAINING YOUR PERSONAL INFORMATION
We will keep your details on record until we have completely dealt with your request, enquiry, or our contract with you, and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation.
SPACER may keep your details on record for as long as is necessary for the purposes of which it may use your personal information. When SPACER decides that holding your details is no longer necessary we will securely erase/destroy your details.
In general, and where it’s not related to a specific Service, we will retain the personal information that you have provided to us for 7 years since your last contact with us, for the purposes of audit, analysis and customer management, and the defence of any legal claims.
WHAT ARE YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION?
You have a number of rights in relation to your personal information, although in some cases these rights are subject to certain conditions and limitations. You are entitled to:
– request copies of, and/or access to your personal information.
– request that your personal information be corrected where inaccurate or incomplete
– request that your personal data be deleted (or that we stop using your personal data) where it is no longer necessary. This right normally only applies where your information was provided or processed on the basis of consent, or in the performance of a contract with you which lapsed more than six years ago.
– request that we stop sending you marketing communications.
If you would like more details about these rights as they apply to a specific Service of SPACER, or to exercise any of your rights, please contact our Data Protection Officer at:
St Lawrence Industrial Estate
firstname.lastname@example.org | +44 (0)1843 580083
To help us identify the personal information you are referring to, please include any details that will enable us to locate the relevant personal information.
In order to be sure that your personal information is not disclosed to an imposter, we may require you to provide us with proof of identity before any action is taken or personal information is disclosed.
Any request that you send to us in relation to your rights will be processed within one calendar month of SPACER accepting your request.
If after receiving a reply from us you are still unhappy with our response to such a request you may complain to the Information Commissioner’s Office (ICO). Details on how to do so can be found on the ICO’s website at https://ico.org.uk/.