PRIVACY | HOTSPACES

Privacy Page

HOT Spaces is committed to protecting your privacy. At all times we aim to respect any personal information you share with us, or that we receive from other sources, and keep it safe.

Please read this notice carefully. It provides information about the different types of personal information that we collect (including through your use of our website – www.hotspaces.org) and how we will use this information.

If you are a member (or in the process of becoming a member) please see our member privacy notice.

We may also provide you with specific notices explaining how we use your information in relation to a particular project or activity.

Please click on the links above for further information about the different types of personal information we collect and how it is used on these specific platforms.

If you have any questions please contact us using the contact details in section 1.

1. Who we are and how to contact us
2. When do we collect personal information about you?
3. What personal information do we collect?
4. Special categories of data
5. When will we get in touch?
6. What we do with your personal information?
7. Lawful processing
8. Do we share your personal information?
9. International Data Transfers
10. How long do we keep your personal information?
11. Your Rights

12. Updating this Privacy Notice

1. Who we are and how to contact us

Our parent company is Circular UK Limited. Our company number is 12510936. Our registered address is Unit 1, 218 Kingsland Road, London E2 8DB. Where we use the words “HOT Spaces” “we” “us” and “our”, we are referring to Circular UK Limited. HOT Spaces works with landlords to transform disused and underused space into coworking spaces focused on the impact economy. Our spaces provide our members with a community of purpose driven businesses in a tech forward, wellness focused and thought provoking environment. If you have any questions about how we use your personal information or how we comply with our responsibilities, please contact us as follows: • Email: hello@circularuk.com or hello@hotspaces.org

2. When do we collect personal information about you?

We may hold personal information relating to you from a number of sources and will collect personal information about you:

(a) When you give it to us directly

For example, when you contact us with a query, ask for information about becoming a member, or sign up to our mailing list.

(b) When we obtain it indirectly

Your personal information may have been provided to us by others. For example, a colleague of yours may have suggested that you may be interested in hearing about our spaces.

Your personal information may be available to us from external publicly available sources. For example, depending upon your privacy settings for social media services, we may access information from these accounts or services. This may occur if you interact with us via our Facebook page, or tweet at us on Twitter.

(d) When you visit the website 

When you visit the website (whether on a computer or through our mobile application), we automatically collect certain pieces of technical information. This includes your IP address and recent activity.

We also use cookies to assist with the functioning of the website. Please see our Cookies Notice for more information.

3. What personal information do we collect?

The personal information that we collect and use about individuals includes, but is not restricted to:

name
contact details (email, phone and address)
role within your organisation
social media handles
records of your correspondence with us
your marketing preferences
any other information you may provide (for example, information you give when you express interest in your organisation becoming a member)

If you contact us for any other reason we will collect your name, email and any information you provide to us as part of our correspondence.

4. Special categories of data

Data protection law recognises certain categories of personal information are sensitive and therefore require more protection. These categories of data include information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs and health data. Additionally there are further rules concerning the use of criminal data. We will not usually collect this type of data from you. We will only process this data if there is a valid reason for doing so and where the law allows us to do so. For example, if we host an event at one of our spaces that you wish to attend, we may request your explicit consent to collect accessibility and dietary information.

5. When will we get in touch?

When you give us your personal details you may receive follow up information from us directly, including news about HOT Spaces in general, as well as about any specific HOT Spaces space about which you’ve enquired. Some of these communications are administrative (for example to confirm details about your query) but others are marketing focussed. In general, we will only send marketing materials to your personal email address where you’ve requested to receive it (for example, if you sign up to our newsletter). However, if you have made a purchase from us in the past or contacted us in relation to one of our services, we may contact you in the future about similar services. We may also send marketing materials via email to your work email address (if you work at a company, partnership or other incorporated body) if we feel that you may be interested in hearing more about HOT Spaces and our work. We provide easy ways to stop our marketing, and you can opt out at any time. If at any time you wish to stop or change how we communicate with you, or update the information we hold, please do get in touch, using any of the options set out in section 1. To opt out of emails, click on the unsubscribe link at the bottom of our messages

6. What we do with your personal information?

We use the personal information collected through the website for the following purposes:
to provide you with information about HOT Spaces, our membership options and any other information you requested, as well as communicate with you in general
to arrange for visits to HOT Spaces
to arrange for your attendance at events held at HOT Spaces
to promote HOT Spaces, for example through our social media platforms
to analyse, evaluate and improve HOT Spaces’s services and spaces
to provide updates on our work
to conduct administrative tasks such as keeping track of activities and ensuring feedback has been addressed, etc.
to satisfy legal obligations which are binding on us
for research purposes
for the prevention of fraud or misuse of services; and
for the establishment, defence or enforcement of legal claims.

7. Lawful processing

We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

(a) Legitimate interests Where applicable law allows us to collect and use personal information for our or another person’s legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights. Where you provide information, we will rely on the legitimate interest ground to communicate with you in most instances.

(b) Consent Where we ask for your consent for our use of your personal information for a specific purpose. You always have the right to withdraw your consent.

(c) Contract Where it is necessary to use your personal information to fulfil a contract with you or to take steps at your request prior to entering into one. For example, when you take steps to become a member of HOT Spaces.

(d) Legal obligation Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. For example, we may need to report matters from time to time to the Health and Safety Executive about incidents that occur in our spaces.

8.Do we share your personal information?

The personal information we hold about you will be provided to our staff, as well as to our members, where relevant (for example, if you ask about members’ experience with HOT Spaces). We operate each of our spaces through separate wholly owned companies, and so if you express interest in a particular HOT Space, we will share your details with that space. If you visit an HOT Spaces space, we will provide your information to the relevant HOT Spaces company, as well as the landlord (if the landlord has requested information about those visiting the site). We may disclose your personal information to selected third party processors (for example, the company which provides technical support for the website) for the purposes outlined at section 6. The third party in question will be required to use any personal information they receive in accordance with our instructions. If we share your information with any other third party, we will let you know in advance where reasonably possible. We reserve the right to disclose your personal information to third parties:

(a) in the event that we buy or sell any business or assets, in which case we may disclose your personal information to the prospective buyer or seller of such business or assets;

(b) if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;

(d) if we are under any legal or regulatory obligation to do so; and

(e) in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.

You will never receive marketing from other companies or organisations as a result of giving your details to us. We may need to share limited information with our service providers who help us to prepare and send you our communications. However, we do not allow these organisations to use your personal information for their own purposes and we take care to ensure that they keep your personal information secure, and delete it when it is no longer needed.

9.International Data Transfers

The website is hosted in the European Economic Area (EEA), however our membership and the landlords with whom we work may be located around the world. This means that it is possible that personal information we collect from you will be transferred to and stored in a location outside the UK or the EEA. Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred, stored, and/or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. For instance we may use cloud providers to store personal information who have servers in the US and are signed up to the Privacy Shield or we may enter into the European Commission approved standard contractual clauses with such providers. If you have any questions about the transfer of your personal information, please contact us using the details at section 1.

10. How long do we keep your personal information?

We will keep your personal information only for as long as required in connection with the purposes for which it was collected and/or is used. We may also retain information for longer periods where we are required to do so in accordance with legal or regulatory requirements, such as tax and accounting. In specific circumstances we may also retain your personal information for longer so that we have an accurate record of your dealings with us in the event of any complaints or challenges. If you would like further information about this, please contact us using the details at section 1.

11.Your rights

We explain how you can update your communication preferences above at section 5 above. Where we rely on your consent, you have the right to withdraw your consent at any time.

When we use your personal information you have the right to:

Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we are able to confirm your identity, we will, except where we can rely on an exemption, provide you with this personal information.

Request that we erase the personal information we hold about you, as far as we are legally required to do so.

Ask that we correct any personal information that we hold about you which you believe to be inaccurate.

Object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for research purposes.

Ask for the provision of your personal information in a machine-readable format (the data portability right) to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means. Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.

If you decide you do not want to receive any further communications from us, please tell us. Please note that you also have the right to lodge a complaint with the relevant data protection supervisory authority. For example, in the UK this is Information Commissioner’s Office at www.ico.org.uk/concerns.

12.Updating this Privacy Notice

We may update this notice. If we update this notice in a way that significantly changes how we use your personal information, we will bring these changes to your attention where reasonably possible. Otherwise, you can access the latest version of this notice on our website.

Version: 1.0

Dated: March 2020