Privacy Policy

Flexspace No 1 LLP, Flexspace No. 2 LLP and Flexspace Management Ltd, trading as Flexspace (“we” or “us”) are committed to protecting and respecting your privacy and to implementing appropriate technical and organisational measures in order to meet the requirements of the EU General Data Protection Regulation (“GDPR”), and the Data Protection Act 2018 (the “Act”). This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The data controllers are Flexspace Management Ltd of 112 Culley Court, Peterborough, PE2 6WA.

Flexspace is made up of different legal entities. This Privacy Policy is issued by us on behalf of the Flexspace group, including our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (our “Group”).

Once you have entered into a contract with us we may receive more data from you, and we may use it and share it in different ways – at that time you can read about this in more detail in our Customer Privacy Policy.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are Your Rights?

Except for in certain circumstances, under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

1. The right to be informed about we collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 26.
2. The right to access the personal data we hold about you.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 26 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. However, there are a small number of circumstances where we can refuse you that right.
8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

In any case, this wouldn’t affect any of the processing we’ve done to that point, but it might stop us from being able to provide services to you. We would let you know if that were the case when responding to your request.

You can exercise certain of your rights by checking certain boxes on the forms we use to collect your data. You can also exercise these rights at any time by contacting us at Privacy Officer, Flexspace, 112 Culley Court, Peterborough, PE2 6WA. In the event that we believe we have a reason not to follow your request, we will explain why.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first at privacy@flexspace.co.uk or Privacy Officer, Flexspace, 112 Culley Court, Peterborough, PE2 6WA.

What Personal Data Do We Collect and How?

We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on our site www.flexpace.co.uk (“our site”) or by corresponding with us by phone, e-mail, on social media or otherwise. You may also provide information to us in person or by other means, such as on the telephone. The information you give us may include your name, address, e-mail address, social media identifiers and phone number.

Information we collect about you on our site. With regard to each of your visits to our site we may automatically collect the following information: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we collect about you on our premises. In the event that you visit our premises we may automatically collect images and video footage of you on our closed-circuit television (CCTV) recording equipment. The equipment is managed and operated by a third-party supplier.

The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the UK GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of our Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the UK GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.

Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Uses made of the Information
We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to notify you about changes to our services; and
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you on our site. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we collect about you on our premises. We will use this information to:

• detect, investigate, report and seek to prevent crime;
• improve the safety of our customers and the security of their possessions on our premises; and
• abide by laws and regulations that apply to us.

Information we receive from other sources. Sometimes we receive your personal data from third parties, including web brokers, property listing sites and agents who you have given your personal data to in order that they can help you find products such as ours. We always take care to ensure we can trust the third parties who give us data. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

With respect to each of the aforementioned processes, we carry out these activities on the basis of our legitimate interest in the success of our business, and the use and analysis of our website to promote the success of our business. Where you enter into a contract with us, we may also use your personal data in order to perform that contract with you, and in other situations we may process your personal data in order to comply with a legal obligation (such as in our relationship with HMRC). Where we need your personal data to perform a contract with you, but you withhold that data, we may not be able to perform the contract with you. Where you have given us your details in order that we may contact you for marketing purposes, you may have provided your consent; in those circumstances we process on the basis of that consent or any other legal basis that might enable us to contact you (such as a soft opt-in).

If we have access to your special category personal data (for example if you are about to enter into a contract with us and we require it in order to set up your account) we will use this only: (i) with your consent; (ii) as needed for us to carry out our responsibilities in the field of employment and social security and social protection law in so far as we are authorised to do by law or other collective agreement providing appropriate safeguards; (iii) if we need to protect yours or another person’s vital interests in certain circumstances; (iv) if it is manifestly made public by you; (v) if we need to in order to establish, exercise or defend a legal claim; or (vi) if necessary for preventative or occupational health purposes.

Disclosure of your information
We may share your personal information with any member of our Group.

We may share your information with selected third parties including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
• analytics and search engine providers that assist us in the improvement and optimisation of our site; and
• credit reference agencies (“CRAs”) for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. The CRAs have created a joint document called the Credit Reference Agency Information Notice (“CRAIN”) which describes how they process your personal data. The CRAIN is accessible from each of the three CRAs and via the following links:
• Call Credit – www.callcredit.co.uk/crain;
• Equifax – www.equifax.co.uk/crain; and
• Experian – www.experian.co.uk/crain.

In each case we will do this either in order to perform our contract with you, or on the basis of our legitimate interest, promoting the success of the business.

We may disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets as it would be in our legitimate interests (in the success of the business and in the interests of our shareholders) to do so;
• if Flexspace No 1 LLP, Flexspace No 2 LLP, Flexspace Management Ltd, any other member of the Group or substantially all of the assets of Flexspace No 1 LLP, Flexspace No.2 LLP or any other Group entity are acquired by a third party. In such an event personal data held by us may be one of the transferred assets (and data transfer would take place pursuant to the legitimate interests of the Group, including Flexspace No 1 LLP, Flexspace No.2 LLP or Flexspace Management Ltd, as well as those of the buyer); and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Flexspace No 1 LLP or Flexspace No. 2 LLP, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We won’t share your personal data with third parties unless we have a legal basis to do so.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

How and where we store your personal data

Most of the data we store is held electronically. We may store a small amount of personal data in hard copies – generally this is customer personal data only. We use secure filing systems for this purpose and limit access. Our online data systems are secured with appropriate technical and organisational measures including industry standard security. We don’t hold personal data for longer than it is needed, and we delete data which we no longer need. In general, we retain data for the duration of our relationship
with you and for up to 7 years afterwards (in case of any legal claims).

The data that we collect from you is not routinely transferred to, or stored in, destinations outside of the United Kingdom or European Economic Area (“EEA”), but such transfer may occur where we are working with third parties, for example IT suppliers whose servers or services are located in, or originate from, outside of the United Kingdom or EEA. It may also be processed by staff operating outside the United Kingdom or EEA who work for one of our suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy, and that personal data transferred outside of the United Kingdom or EEA is done so only:

• in accordance with a decision by the United Kingdom or European Commission that the relevant country provides an adequate level of data protection; or
• if we have taken measures to ensure recipients provide an adequate level of data protection. For example, in such case, we may use standard contractual data protection clauses approved by the United Kingdom or European Commission.

We will do our best to protect your personal data and will use strict procedures and security features to try to prevent unauthorised access.

Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Accessing Your Personal Data: How to Make a Request

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown below.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Privacy Officer at Flexspace, 112 Culley Court, Peterborough, PE2 6WA or sent by email to privacy@flexspace.co.uk.

You have the right to make a complaint to the Information Commissioner’s Office (“ICO”) if you think your data is being misused. The ICO is the United Kingdom’s supervisory authority for data protection issues (www.ico.org.uk). However, we welcome the opportunity to resolve your complaint in the first instance. Please do not hesitate to contact us using the details above so that we can try to help you out in the first instance.