Privacy Notice

12 MARCH 2024

Introduction

This notice applies across all gospace AI "services," which we define as our websites and all of our services, including online and mobile products and any other applications or services we offer such as events and training.

By "personal data," we mean identifiable information about you such as your name, email address, telephone number, and company affiliation. If you cannot be identified (for example, when your personal data has been aggregated and anonymised), this notice does not apply.

We may choose to update this notice from time to time. Where a change is significant and we have your information, we will notify you normally by email.

Who is gospace AI

"We" (or "our and "us") in this document refers to gospace AI limited, a private limited company registered in England and Wales, with company number 09096842, whose registered office is 9th Floor, 107 Cheapside, London, EC2V 6DN, United Kingdom, and its wholly-owned subsidiaries.

Regarding the UK Data Protection Act 2018 and European Union data protection laws, gospace AI limited is the data controller of personal data that you submit to us or personal data that we collect from you when you use our services. We are the data processor in cases where we are providing services to another data controller of your personal data, such as your employer.

If you would like to know what information we hold about you or if you have other questions or complaints about this privacy notice, please contact us at the above address or [e-mail]

The information we collect from you

When you visit our websites or use our services, we may collect personal data, normally by one of these methods:

Information you give us directly: Nearly all information we collect comes directly from you, or from you as our customer, or you as an employee of our customer. When you visit or use some parts of our websites or services, we might ask you to give us personal data; for example, we might ask for your contact information when you sign up for a trial, respond to a job application or email offer, participate in training and events, or request our support. You are not required to give us your personal data but in cases where you do not, you may be unable to use certain parts of our websites or services.

Information provided to us by your employer, or that we collect on your employer’s behalf: Your employer may provide us with information, or ask us to collect information, from building access systems such as radio frequency ID badges, or from building network systems such as wireless access points. This information may include data about your presence or absence in a building or facility, and the times you were present or absent. Depending on your employer’s agreements with you and our service to them, we may use that information to forecast group demand for workspaces, show you and your colleagues the current use of workspaces, or allow you and your colleagues to find one another for purposes of collaboration.

Information we collect automatically: We collect some information about you automatically, such as your IP address and device type, when you visit our websites or use our services. We also collect information when you navigate through our websites and services, including what pages you view and which links you click. This information helps us to understand how you use our websites and services and helps us to improve them. We collect some of this information using cookies and similar tracking technologies. If you would like to learn more about the types of cookies we use, why, and how you can control them, please see our Cookie Policy and cookie preferences settings on our websites. Our apps also may ask for your permission to access your phone’s camera, to allow you to scan a QR or similar code from a work point, according to your company’s policy; the information collected when you use your phone’s camera for this purpose is not used nor shared in any way by gospace AI outside the gospace AI app unless authorised by your company for your company’s previously disclosed purposes and in accordance with your company’s policies.

Information from third parties: We might collect personal data about you from other sources, including publicly available materials or trusted third parties such as our marketing and research partners. We use this information, and the personal data we already hold, to improve our services or to validate your personal data.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing your data are: (i) to satisfy a contract with you, or (ii) where we have legitimate interests and those interests are not overridden by your rights, or (iii) to meet a legal obligation, or (iv) to meet a contractual obligation, or (v) where we have your consent.

If we do not collect your personal data, we may be unable to provide you with some of our services, and some functions and features on our websites might not be available to you.

Use of your information

We use the information that you have given us to:

• Answer your requests (such as for training materials)

• Send you information we are required to send.

• Inform you about operational changes to our websites and services, notify you about security updates, or help you use our websites and services.

• Send you marketing communications according to your stated preferences.

• Ask you to participate in research we may conduct.

• Support you (for example, to resolve technical support problems or other problems related to our websites or services, whether by email, in-app support or otherwise).

• Enhance our websites and services (for example, to track and monitor your use of websites and services, or to conduct technical analysis of our websites and services to improve them).

• Provide features in our service, such as allowing you and your colleagues to see who is present in a building and available for collaboration, or to see forecasts of demand for workspace.

• Detect and prevent fraudulent or malicious activity, to ensure that our websites and services are being used according to our terms of service.

• Market to you, with your consent (see below). We may also use your personal data to display targeted advertising to you online, through our own websites and services or through third party websites and their platforms.

• Analyse and report (for example, we may use the personal data we collect about you and other users of our websites and services, whether obtained directly or from third parties, to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties).

Sharing your information

Other than as expressly set out in this privacy notice or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent.

We may disclose your personal information to:

• Any third party to whom disclosure is necessary to enable us to provide you with any services or products that you have requested through the site which may be provided by such third parties; and

• Any person to whom disclosure is necessary to enable us to enforce our legal rights, or to protect the rights, property, or safety of our employees or where disclosure is permitted or required by law.

You should note that any public elements of websites will be visible to other users of those websites anywhere in the world. You should only submit information about yourself directly on the non-public elements of websites, or if on public elements, only the information you are willing to be made public.

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

• Other companies in our group of companies;

• Third-party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you;

• Regulators, law enforcement bodies, government agencies, courts or other third parties where we must comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;

• An actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of any part of our business;

• Other people where we have your consent.

When we share data, it may be transferred to, and processed in, countries other than the country you live in. Where we disclose personal data to a third party in another country, we use safeguards to ensure your personal data remains protected.

For individuals in the European Economic Area (EEA), your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where we have approved transfer mechanisms in place to protect your personal data; for example, by adhering to the European Commission’s Standard Contractual Clauses. For further information on international data transfers, please contact us.

How we store your personal information

Security of your personal data is a priority for us. We are committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens. Our security processes are available upon request.

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you have requested or to comply with applicable contractual, legal, tax or accounting requirements).

We will retain your personal data for as long as we have a relationship with you and have a business need to retain it, in accordance with our data retention policies and practices. Following that period, we will delete or anonymise it.

Your data protection rights

Under data protection law, you have rights including:

• Right to know: You have the right to ask us for copies of your personal information including the categories and/or specific pieces of personal information we have collected about you, the sources for that personal information, the purposes for which we use that information, the third parties with whom we disclose the information, and the categories of information that we disclose to third parties.

• Right to rectification: You have the right to ask us to rectify your personal information you think is inaccurate, and to complete information you think is incomplete.

• Right to deletion: You have the right to ask us to delete your personal information in certain circumstances.

• Right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Right to object to processing: You have the right to object to the processing of your personal information in certain circumstances.

• Right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

We will not discriminate against you, and you are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at the address above or email [e-mail] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at [e-mail].

You can also complain to the ICO if you are unhappy with how we have used your data at https://www.ico.org.uk