This policy is updated from time to time. The latest version is published on this page.
If you have any questions about this policy, please email firstname.lastname@example.org or write to: Suite 27, Oxford House, Parkway Court, John Smith Drive, Oxford, OX4 2JY.
YOUR PRIVACY IS IMPORTANT TO US
RIGHTS TO ACCESS, RECTIFICATION OR ERASURE, RESTRICTION AND OBJECTION, OF PROCESSING
4.1. You have the right to access, rectification, opposition, erasure (“right to be forgotten”), and right to restriction of processing of your personal data by directing any such requests to School Space registered at address 45 Flanders Close, Bicester, England, OX26 6FY. In order to make things easier for you, and without prejudice to the legal requirements School Space must comply with under the laws, School Space also allows you to exercise the above-mentioned rights by opening a support ticket via emailing email@example.com
PERSONAL INFORMATION ABOUT USERS AND PARTNERS
School Space is used by School Space “Users” and by School Space “Partners”. The information we receive from Users and Partners and how we handle it differs, as set out below.
SCHOOL SPACE USERS
As a User, we collect information relating to you and your use of our Services from a variety of sources:
5.1 (i) Information we collect directly from the User
- Contact information: information you provide for us to send you availability and booking related details. For example, contact number, email address, non-transactional communication preferences.
- Booking data: We store your booking history data for you.
- Billing info: if you are booking with us, we require you to provide your billing details.
- Other data you want to share: We may collect your personal information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial
(ii) Information we collect about the User indirectly or passively when interacting with us
- Usage data: School Space collects usage data about Users whenever they interact with our services, including information they have elected to make publicly available.
- Device and application data: School Space collects data from the device and application the User uses the Site to access our services, such as the IP address and browser type. We may also infer the geographic location based on the User IP address.
- Referral data: if the User arrives at the website from an external source (such as a link on another website or in an email), we record information about the source that referred the User to us.
- Information from cookies and page tags: School Space uses third party tracking services that employ cookies and page tags to collect aggregated and anonymised data about visitors to our websites. This data may include usage and User statistics.
5.2 School Space Partners
As a Partner, when you agree to work with School Space to hire out your facilities, we collect operational and site information on your school from a variety of sources:
(i) Information we collect on school management team and site staff
- Contact information: information you provide for us to contact you in case of an emergency on site, or to provide you with feedback from you Users. For example, contact number, email address, non-transactional communication preferences.
(ii) Information we collect about the school site
- We collect and store site specific information on our Partners. This data may include door codes, alarm codes, fire escape routes, contact details, and other site specific information,
(iii) School Space’s obligations as data controller when collecting Users’ data
As the Data Controller, School Space will fulfil the following obligations
- To treat the personal data only to carry out the provision of the contracted Services.
- To maintain the duty of secrecy with respect to the personal data to which the Data Processor has access, even after the termination of the contractual relationship, and to ensure that their employees have committed in writing to maintain the confidentiality of the personal data processed.
- To ensure, taking into account the available technology, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the risks of varying probability and severity for the rights and freedoms of natural persons, that they will apply adequate technical and organisational measures to ensure a level of security appropriate to the risk, including, where appropriate, among other things:
- The ability of ensuring the continued confidentiality, integrity, availability and resilience of the systems and services ;
- The ability of restoring the availability and access to personal data quickly in the event of a physical or technical incident;
- A process of regular verification, evaluation and assessment of the effectiveness of the technical and organisational measures in order to ensure the safety of the processing
When evaluating the adequacy of the security level, special account shall be taken of the risks presented by the data processing, in particular as a consequence of the destruction, loss or accidental or unlawful alteration of the personal data transmitted, stored or otherwise processed, or the communication or unauthorised access to such data.
- To keep under their control and custody the personal data to which they have access in relation with the provision of the Service, and to not disclose them, neither transfer or otherwise communicate them, not even for their preservation, to persons unrelated with the provision of the Service covered by this Agreement.
Access to the data made by natural persons who render their services to the Data Processor, acting within the organisational framework of the latter by virtue of a commercial and non-labour relationship, is authorised. In addition, access to the data is granted to companies and professionals that the Data Processor has hired in their internal organisational framework in order to provide general or maintenance services (computer services, consulting, audits, etc.)
- To delete or return to the User, at their choice, all personal data to which they have had access in order to provide the Service. Likewise, the Data Processor undertakes to delete the existing copies, unless there is a legal rule that requires the preservation of the personal data. However, employees and other personnel working for the Data Processor are entitled to access Users and Partners data as required to carry out their obligations under the terms of their contract
- To notify the User or Partner, without undue delay, of any personal data security breaches of which he is aware, giving support to the User and Partner in the notification to the relevant Authorities if required
- To cooperate with the Control Authorities, at its request, in the fulfilment of its power.
- To make available to the User or Partner the whole information necessary to demonstrate the fulfilment of the obligations established under this Agreement, as well as to allow and contribute to the performance of audits, including inspections, by the User or Partner or by a third party authorised by them.
If the Data Processor or any of his Subcontractors violates this Agreement or any regulation when determining the purposes and means of the processing, they shall be held responsible for such processing. Furthermore, if such Subcontractors are based in countries which do not have a legislation on data protection which is equivalent to the EU legislation (“Third Countries”), Data Processor shall establish all safeguards required by the EU legislation in order to comply with all obligations arising from transfers of data to Third Countries, and shall promptly inform the User or Partner about such safeguards if so requested.
PURPOSES AND LEGITIMATE BASIS OF THE USE AND SHARING INFORMATION
PURPOSES OF PROCESSING
6.1. We use the information we collect from you to perform the services in connection enquiring and hiring out a school’s space
6.2. We also use your information to review, investigate and analyse how to improve the services provided. We may also collect and analyse your data to monitor, maintain and improve our services and features.
6.3. We may internally perform statistical and other analysis on information we collect (technical and meta data) to analyse and measure user behaviour and trends, to understand how people use our services, in order to improve and optimise our performance of such services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features and space offerings.
6.4. We may use your information for internal purposes designed to keep our services secure and operational, such as testing purposes, troubleshooting, to prevent abusive activity (i.e. fraud, spam, phishing activities), and for service improvement, research and development purposes.
6.5. We’ll be sending you School Space service information, feedback forms, and suggested space by any means, including email and similar means of electronic communication like personalised advertisements as part of providing relevant content helpful to use our services effectively. In order to customise such information and commercial communications as much as possible, School Space may use statistical techniques that allow the creation of user profiles and data segmentation.
6.7. Your data is not disclosed to any third party except (i) for providing the services you requested and for which School Space collaborates with third parties, (ii) when we have your permission, (iii) when it is required by a competent authority in the exercise of its duties (for example in order to investigate, prevent or take action regarding illegal activities) or (iv) as otherwise required by law.
LEGITIMATE BASIS OF PROCESSING
School Space use of your data for the purposes described above is based on the following legitimate basis:
7.1 Users’ & Partners’ Data
If you are a User or a Partner, we are entitled to use your data in order to fulfil our contractual obligations with you and, if you are acting on behalf of a legal person, we have a legitimate interest to use your data in order to maintain the relation with your company as a School Space client.
In addition, we are entitled by law to use your data for direct marketing purposes, in order to send you commercial communications related with School Space products or services which are similar to the Services, since legislation on data privacy recognises direct marketing to clients as a legitimate interest of use of personal data, and legislation on information society services expressly allows School Space to send you commercial communications by electronic means, provided that they are related with products or services which are similar to the Services. In any case, you are entitled to ask us, now or at any moment, not to send you any commercial communications. If you don’t want us to send you commercial communications, you can do it, now or at any moment, by emailing us at firstname.lastname@example.org
8.1 A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity throughout the School Space Service and that information helps us to understand your preferences and improve your experience.
CANCELLING YOUR ACCOUNT, OPTING OUT OF EMAIL, AND MODIFYING PERSONAL INFORMATION
9.1 You may opt out of receiving any emails from School Space at any time by emailing us at email@example.com. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).
9.2 We encourage you promptly to update your personal information when it changes. Information concerning your past behaviour with the Service may be retained by School Space as long as necessary for the purposes set out below.
RETENTION OF YOUR INFORMATION
10.1. We retain information for active School Space bookers as long as it is necessary and relevant for our operations. In addition, we may retain information from previous Users to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce the School Space Terms of Service and take other actions permitted by law.
HOW TO CONTACT US
Email us at firstname.lastname@example.org
If you consider that any use of your data might breach any of your rights, you can lodge a complaint at any time by emailing us at email@example.com, or alternatively, by filing a complaint before the Authorities.