Business Space Made Easy Limited Privacy Notice
Business Space Made Easy Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Business Space Made Easy Limited collects, processes and transmits your personal data through your use of this website, including any data you may provide through this website when you make an enquiry about the office accommodation that we offer or any of our other services.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Business Space Made Easy Limited owns this website and is the controller and responsible for your personal data (collectively referred to as the “Company”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO in the first instance using the details set out below.
Our full details are:
Full name of legal entity: Business Space Made Easy Limited
Name or title of DPO: Jean Eustace
Email address: email@example.com
Postal address: 6th Floor, Elizabeth House, 39 York Road, London SE1 7NQ
Telephone number: 020 3146 5555
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last drafted in May 2018. You can contact our DPO if you would like to request an historic version of this document.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Depending upon the features on our site and the way you use it, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, 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 this website.
Profile Data includes your username and password for any features on our website, any purchases or orders made by you, and enquiries about our office accommodation or other services, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.
We do not 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, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have with you or are trying to enter into with you (for example, to provide you with office accommodation and associated services). In this case, we may have to cancel a product or service you have with us or we might not be able to provide you with a quote for the provision of services but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, filling out an enquiry form on our website or otherwise. This includes personal data you provide when you:
submit an enquiry about our office accommodation or other services;
request our office accommodation or other services;
create an account using any features on our website;
subscribe to our service or publications;
request or agree to marketing being sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Third parties or publicly available sources. We may from time to time receive personal data about you from various non-exhaustive third parties and public sources as set out below:
Technical and Data from the following parties: ?analytics providers such as Google;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Identity and Contact Data from brokers of office accommodation.
Identity and Contact Data from social networks such as LinkedIn.
Identity and Contact Data from data brokers and advertising affiliates.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we are asked to provide you with information about our office accommodation and associated services and quotes for the provision of the same. This might be as a result of using the chat function on our website or sending us an email or letter.
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation.
Click https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/ to find out more about the types of lawful basis that we will rely on to process your personal data.
We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
To register you as a new customer
Type of data: (a) Identity, (b) Contact
Lawful basis for proceeding is performance of a contract with you
To provide information about our office accommodation and associated services and their likely cost.
Type of data: (a) Identity, (b) Contact
Lawful basis for proceeding is performance of a contract with you
To process and deliver your request including (a) Manage payments, fees and charges, (b) Collect and recover money owed to us
Type of data: (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications
Lawful basis for proceeding is performance of a contract with you and/or necessary for our legitimate interests (to recover debts due to us)
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications
Lawful basis for proceeding is performance of a contract with you and/or necessary to comply with a legal obligation and/or Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in any competition that we might run or to complete a survey
Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications
Lawful basis for proceeding is performance of a contract with you and/or necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity, (b) Contact, (c) Technical
Lawful basis for proceeding is necessary for our legitimate interests (for running our business, provision of vital administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring or re-financing exercises) and/or necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical
Lawful basis for proceeding is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical, (b) Usage
Lawful basis for proceeding is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile
Lawful basis for proceeding is necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please inform us if you do not wish to receive marketing information from Business Space Made Easy Limited.
Promotional offers from us
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).
You will receive marketing communications from us if you have requested information or a quote from us or acquired accommodation or services from us or if you provided us with your details when you entered a competition, registered for a promotion or completed a survey and, in each case, you have not opted out of receiving such marketing.
We will get your express opt-in consent before we share your personal data with any company outside of the Internal Third Parties listed in the Glossary for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
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 or other transaction.
A “cookie” is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but “persistent” cookies – which are not session-based – remain on the viewer’s computer, so that he or she can be recognised as a previous visitor when he or she next visits our Site. This allows us to collect information about a viewer’s browsing habits whilst on our Site which can be useful in assisting us to monitor and improve our services.
Our site uses Google Analytics cookies to provide us with information to help us better understand how users enjoy our website. These cookies are: utma, utmb, utmc and utmz. The information they provide us with is not shared with third parties (other than for use within Google Analytics), nor do we take steps to specifically identify any user or their personal information.
In addition to using cookies, we might also use GIFs and other web tools to collect information about your browsing activities whilst on our site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
Any information that we acquire about you using cookies, GIFs or other web tools is subject to the same restrictions and conditions as any other information we collect about you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary such as our employees and the operating companies which run each of our buildings.
External Third Parties as set out in the Glossary such as professional advisers and HMRC.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We retain your personal data for a period of 2 years because we provide office accommodation and our clients typically have to make medium to long term decisions about their place of operation.
In order to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may exercise the following legal rights in respect of the information that we hold about you:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact our DPO.
If you want to find out more about these rights please read the section entitled “Your legal rights” on page 13 and 14 or visit the website of the Information Commissioner – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it might take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO.
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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Business Space Made Easy Limited owns and publishes information on this website. However, in order to respond to enquires about office accommodation or to provide prospective clients with quotes for the provision of accommodation and services, we will transfer your personal data to the companies which run each of the office locations mentioned on our website. A list of the companies running the office accommodation that we advertise is set out below (together the “Companies”):
Clockhouse Property Consulting Limited
This transfer of personal data is necessary to develop our business and the business of the Companies and without transferring data it would not be possible for any contract for the provision of accommodation and services to be concluded or performed.
Both Business Space Made Easy Limited and the Companies listed above have the same data protection procedures and Eithne Yates whose contact details are at paragraph 1 of this policy is the Data Protection Officer of the Companies.
External Third Parties
Service providers acting as processors or joint controllers based in the United Kingdom who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, consultants and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
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.