SPACEIN Privacy Policy

Last updated: 10th June, 2022

1

Introduction

1.1
We respect your privacy and are committed to protecting your personal data. This policy applies to your use of the SPACEIN platform (and to any related communications with us), accessible via https://spacein.co.uk and https://app.spacein.co.uk/ (“Platform”), together, as applicable, with our:
(a)
the Platform’s end-user licence agreement, set out at: https://spacein.co.uk/eula];
(b)
our website terms and conditions, set out at: https://spacein.co.uk/terms-and-conditions;
(c)
our cookie policy, set out at: https://spacein.co.uk/cookies-policy; and
(d)
any terms agreed in between us in relation to any of the services accessible through the Platform or provided by us in respect of the Platform,

(together, the “Services”)
1.2
Neither the Platform nor the Services are intended for children and we do not knowingly collect data relating to children.

2

Important information and who we are

2.1
The Platform is offered by MCCGLC Limited, a company registered in England and Wales, under registration number 05563882 with registered address Arnold House, 21-33 Great Eastern Street, London, EC2A 3EJ, UK ("MCCGLC", "we", "us", "our").
2.2
MCCGLC is the controller responsible for the Platform and Services. If you have any questions about how we use your data, you can get in touch with us:

Email address: support@spacein.co.uk
2.3
You have the right to make a complaint at any time to the Information Commissioner's Office (https://ico.org.uk/) (“ICO”).

3

Changes to the privacy policy and your duty to inform us of changes

3.1
We keep our privacy policy under regular review. This version was last updated on the date at the top of it. It may change and if it does, these changes will be posted on this page. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.
3.2
Please keep us informed if your personal data changes during our relationship with you.

4

Third party links

Our Sites (as defined below) may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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. Please check these policies before you submit any personal data to these websites or use these services.

5

The data we collect about you

5.1
We may collect, use, store and transfer different kinds of personal data about you as follows:
(a)
Identity Data: including first name, last name, pronouns, username or similar identifier, date of birth, gender.
(b)
Profile Data: including your profile picture/avatar, username, password, password hints, similar security information used for authentication and account access, preferences, feedback, survey responses and support data (such as support chats or calls (including recordings of those calls) and service support tickets).
(c)
Contact Data: including email address and telephone number (optional).
(d)
Financial Data (if applicable): including billing address, bank account and payment card details.
(e)
Usage Data: including details of your use of the Platform including, but not limited to: the number of users per allocated “space” on the Platform and information required for us to host an event on the Platform, such as the event title and details, consent to contact attendees, names and email addresses, and employment information.
(f)
Device Data: 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 the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
(g)
Technical Data: including your internet protocol (IP) address, login data, referring URL, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform (as applicable).
(h)
Content and Employment Data: including (if used for work purposes) your employer, check-ins, meetings schedule, job role and/or department, employee count (if applicable), contacts and other details provided by you on the Platform. If you choose to provide this, this may also include social media login data.
(i)
Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.
5.2
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
5.3
We do not intentionally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Please do not provide us with any copies of special categories of personal data.

6

How is your personal data collected?

6.1
We will collect and process the following data about you:
(a)
Information you give us. This is information you consent to giving us by registering to use the Platform or our other websites, products or services (together “Our Sites”), or by corresponding with us (for example, by email, social media or chat). It also includes information you provide when you share data via the Platform's functions, enter a competition, promotion or survey, and report a problem with the Platform, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
(b)
Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy (https://spacein.co.uk/cookies-policy) for further details.
(c)
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
(i)
Device Data from the following parties:
(A)
analytics providers such as Google based outside the UK;
(B)
advertising networks based inside or outside the UK; and
(C)
search information providers based inside or outside the UK.
(ii)
Identity Data, Profile Data and Contact Data from providers you use to access the Platform via the Single Sign-On functionality, including Google and Microsoft and from services you connect the the Platform, such as integrated social media platforms.
(iii)
Identity Data, Profile Data and Usage Data from third parties that sign you up to access their “space” on the Platform or access on of their events via the Platform.

7

Cookies

We use cookies to distinguish you from other users of the Platform, Our Sites and to remember your preferences. This helps us to provide you with a good experience when you use or browse any of Our Sites and also allows us to improve Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy (https://spacein.co.uk/cookies-policy).

8

How we use your personal data

8.1
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
(a)
where you have consented before the processing;
(b)
where we need to perform a contract we are about to enter or have entered with you;
(c)
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
(d)
where we need to comply with a legal or regulatory obligation.
8.2
Please see “Lawful Basis” at paragraph 17 below to find out more about the types of lawful basis that we will rely on to process your personal data. You have the right to withdraw that consent at any time by contacting us. Where we rely on consent as our lawful basis you have the right to withdraw your consent at any time by contacting us.

9

Purposes for which we will use your personal data when using the Platform (and in related communications with us)

Purpose/activityType of dataLawful basis for processing
To register you as a new Platform user and verify your identityIdentity
Contact
Device
Content and Employment		Your consent;
Legal or regulatory obligation; and/or
Performance of a contract with you.
To manage our relationship with you, which will include:
(a) Notifying you of changes to the Platform or any Services;
(b) Notifying you about changes to our terms or privacy policy;
(c) Asking you to leave a review or take a survey; and/or
(d) Sending you updates and marketing communications 		Identity
Contact
Profile
Device
Marketing and Communications		Your consent;
Performance of a contract with you; and/or
Necessary to comply with a legal obligation (to inform you of any changes to our terms and conditions); and/or
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and the Platform including troubleshooting, data analysis and system testingIdentity
Contact
Device
Technical		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver the Services and other content to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the Platform
To monitor and analyse usage of the Platform and Services and specific “spaces”
To enable user-to-user communication		Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Content and Employment		Your consent;
Performance of a contract with you; and/or
Necessary for our legitimate interests (to raise awareness about our products/Services and to develop them and grow our business)
(If applicable) To process and deliver your order including:
(a) Manage payments, fees and charges; and/or
(b) Collect and recover money owed to us		Identity
Contact
Financial
Transaction
Marketing and Communications
Your consent;
Performance of a contract with you; and/or
Necessary for our legitimate interests (to recover debts due to us)

10

Disclosures of your personal data

10.1
We may share your personal data for the purposes set out in the tables above with the parties set out below.
(a)
Third Parties as set out in the Glossary.
(b)
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
10.2
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11

Marketing

11.1
We strive to provide you with choices regarding our use of your personal data, particularly around marketing and advertising.
11.2
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
11.3
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
11.4
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

12

International transfers

12.1
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
12.2
If we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a)
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
(b)
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
12.3
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

13

Data security

13.1
All the information you provide to us is stored on our secure servers. You are responsible for keeping all your passwords and other Profile Data confidential.
13.2
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
13.3
You may communicate with us publicly through social networking platforms or forum features. You may also communicate with other users on the Platform, including event attendees. You must ensure when doing so that you do not submit any personal data that you do not want to be seen, collected or used by other users.
13.4
We cannot and do not: (a) control the information a user may choose to share during a meeting or event; or (b) control the actions of anyone with whom you or any other user may choose to share information when using the Platform; nor do we (c) guarantee that any Content Data or other user content that you or any user provides will not be viewed by unauthorised third parties. Platform users and account holders should be cautious about the access granted to others and the information shared when using the Platform and Services and should be aware that no security measures are perfect or impenetrable.
13.5
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

14

Data retention

14.1
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
14.2
To determine the appropriate retention period for personal data, we consider: (i) the amount, nature and sensitivity of the personal data; (ii) the potential risk of harm from unauthorised use or disclosure of your personal data; (iii) the purposes for which we process your personal data and whether we can achieve those purposes through other means; and (iv) and the applicable legal, regulatory, tax, accounting or other requirements. For more information on how long we hold your personal data please contact us.

15

Your legal rights

15.1
You have the right to:
(a)
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b)
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c)
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d)
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e)
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(i)
if you want us to establish the data's accuracy;
(ii)
where our use of the data is unlawful but you do not want us to erase it;
(iii)
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv)
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f)
Request the transfer of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g)
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15.2
You also have the right to ask us not to continue to process your personal data for marketing purposes.
15.3
You can exercise any of these rights at any time by contacting us at support@spacein.co.uk

16

Glossary

16.1
Lawful basis
(a)
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
(b)
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
(c)
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
(d)
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

17

Third Parties

(a)
Google (Gmail and Google Calendar), for connecting to your third-party account and retrieving meetings information.
(b)
Google (Maps APIs), for geolocation.
(c)
Microsoft, for example we use Microsoft Azure for cloud hosting, user authentication, database hosting and messaging services.
(d)
Mixpanel, for website and Platform analytics and providing support functions, including processing Usage Data.
(e)
HubSpot, for Processing Usage Data to tailor personalised content distributed via email or online chat functionalities.
(f)
Typeform, for signups and surveys.
(g)
8x8 (Jitsi), for video-conferencing functionality.
(h)
Mux, for live-streaming functionality (including User Data).
(i)
Atlassian (Jira), for user support and ticketing services.
(j)
Sendgrid Email API, for email distribution.
(k)
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
(l)
HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
(m)
Social networks, such as Instagram, Facebook, YouTube and LinkedIn, but only in so far as is necessary to provide features on our Platform.


In the case of our advertising and marketing partners, your data will always be made available in line with our Cookies Policy (https://spacein.co.uk/cookies-policy), and you can manage your consent to receive cookies here (https://spacein.co.uk/cookies-policy). You can also opt-out of these activities through your device and/or browser settings or third-party tools, such as the Network Advertising Initiative opt-out ((https://optout.networkadvertising.org/?c=1).