Last update: 9 December 2020
We are committed to protecting your personal information and we take your privacy very seriously. We do not sell any personal information about our clients, suppliers, employees and other business associates. We only use any information shared with us for provision of our services and in that capacity operate as a data controller and, to the extent that we process the data, as a data processor.
APPLICABILITY OF THIS NOTICE
“Personal Information” means information that identifies you personally such as your name, photo or contact details or data that can be linked with such information in order to identify you.
We collect different types of Personal Information for different purposes.
We collect Personal Information about you when you access our Sites and Apps, register with us, contact us, send us feedback, purchase our Services, and complete customer surveys.
We collect this Personal Information from you either directly, such as when you register with us, contact us or purchase Services or indirectly, such as your browsing activity while on our Sites and Apps.
You give us the following personal information about yourself when you register for a SpaceIn Account or when you log in to our Sites and Apps. This information is required for setting up and maintaining access to your account. You can visit and browse our Sites without disclosing the data below.
The following personal information about you is passed on to us for events being hosted on SpaceIn and organised by third parties. This information is required for allowing you to attend the event.
We may collect the following information by automated means whenever you visit and browse our Sites or use our Apps. This information is primarily needed to maintain the security and operation of our Sites and Apps, and for our internal analytics and reporting purposes.
We may collect the following information when you use our support services or participate in surveys.
You give us your Personal Information if you enter your details into the “Join” section of our Sites where we provide individuals the opportunity to be contacted by us and find out more about the SpaceIn Services, providing the following details:
We also maintain a database of prospective clients justified under a Legitimate Interest Assessment where we collate names and contact details of business to business decision makers who are known buyers of our Services.
Our services are not intended for children and we do not knowingly collect data relating to children. By using the Sites or Apps, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps.
We use the information held about you in the following ways and on the following legal bases. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Where more than one ground has been set out in the list below, details of the specific legal ground we are relying on are available upon request.
We only share and disclose your Personal Information with clients (where the data has been collected on their behalf in the first instance) and/or with the following third parties and suppliers where required operationally, and in order to provide our Services:
We reserve the right to share your Personal Information with parties other than those identified above under the following circumstances:
We operate globally, which means personal data may be stored and processed in any country where we or our service providers have facilities or hold events. By using our Sites, Apps or Services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the UK or in other countries around the world. Such countries may have data protection rules that are different and less protective than those of your country.
If you are a resident of the European Economic Area (EEA), and your personal data is transferred outside of the EEA, we will:
We will retain your information for as long as you are our client or as needed to provide our Services – and where required to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your data until any such time that we receive a request to opt-out.
Details of retention periods for different aspects of your personal data are available upon request.
We use physical, electronic, and procedural safeguards to protect personal information – our IT arrangements aspire to “Data Protection by Design” and should be able to detect a significant data breach. Where such a breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage we will notify the ICO, if we are the Controller, or our client, in the event they are the Controller. Where a breach is likely to result in a high risk to the rights and freedoms of individual data subjects, we will also notify those concerned directly and at the earliest practical opportunity. We shall then fully investigate a data breach and implement corrective action to prevent recurrence.
By using our Services or providing personal information to us, you are consenting to MCCGLC communicating with you electronically regarding security, privacy, and administrative issues related to your use of our services. We may email you if a security breach occurs at the email address you have provided to us.
Data transmissions over the Internet are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.
By law, you have a number of rights (subject to certain conditions) when it comes to your personal information.
In relation to personal information we process for the purposes of providing services to you on behalf of your company or event organiser, you will need to contact them to exercise or enquire about these rights.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
(A) Right to be informed
We strive to ensure that all those engaging with us are informed of our arrangements for processing personal data through this Notice.
We will respond to data requests within 1 month and will only charge for requests that are manifestly unfounded or excessive. If we have grounds to refuse a request we will inform the data subject and make them aware of their right to complain to the ICO or to seek civil action – again within 1 month of receiving the request.
For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will correct any inaccuracies in a data subject’s personal data upon receipt of a request. For personal data held under the legal basis of “Contract” or “Legitimate Interest” or “Legal Obligation” we will endeavour to correct the data upon request but may not be able to do so if changing the data may conflict with our legal obligations or disadvantage us in a future legal action. In cases where we cannot rectify the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.
For personal data obtained directly from a data subject under the legal basis of consent – and obtained indirectly from a data subject under the legal basis of legitimate interest – we will erase a data subject’s personal data upon receipt of a request / opt-out notification. For personal data held under the legal basis of “Contract” or “Legitimate Interest” or “Legal Obligation” we will endeavour to erase data upon request but will not be able to do so if holding the data is necessary to fulfil our legal obligations or may be necessary as evidence in a future legal action involving us. In cases where we cannot erase the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.
For personal data obtained directly from a data subject under the legal basis of “Consent” – and obtained indirectly from a data subject under the legal basis of “Legitimate Interest – we will restrict the processing of a data subject’s personal data upon receipt of a request / opt-out notification. For personal data held under the legal basis of “Contract” or “Legitimate Interest” or “Legal Obligation” we will endeavour to facilitate the requested restriction upon request but will not be able to do so if restricting the processing of the data prevents us from fulfilling our legal obligations or the current processing of the data may be necessary as evidence in a future legal action involving us. In cases where we cannot restrict the processing of the data for these reasons we shall inform the data subject and make them aware of their right to complain to the ICO or to seek civil action.
For personal data obtained directly from a data subject under the legal basis of consent – we shall provide, upon receiving a request, the data that we hold in a standard, widely accessible format.
For personal data obtained directly from a data subject under the legal basis of “Consent” – and obtained indirectly from a data subject under the legal basis of “Legitimate Interest” – we will cease to process a data subject’s personal data upon receipt of a request / opt-out notification.
You have the right to withdraw consent to marketing at any time by sending an email to firstname.lastname@example.org. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
To exercise any of the rights above, email us at email@example.com. You may also submit a request to the following address:
FAO: Data Protection Officer
21-33 Great Eastern Street
London EC2A 3EJ
Please identify yourself and specify your request. If you have a password protected SpaceIn account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.
We usually act on requests and provide information free of charge. Where legally permitted, we may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Further, we may be entitled to refuse to act on the request, if deemed to be unreasonably repetitive or systematic, requires disproportionate technical effort, or jeopardises the privacy of others.
“User Content” is the “in-event” & ”in-space” information you give us directly through your use of the Sites and Apps, such as meeting recordings, files and chat logs, and any other information shared or uploaded while using the Sites and Apps. SpaceIn uses User Content only in connection with providing the Sites and Apps e.g. optimising an event – we do not monitor, sell or use customer content for any other purposes.
We cannot and do not (a) control the information a user may choose to share during a meeting or event, (b) control the actions of anyone with whom you or any other user may choose to share information when using the Sites and Apps and (c) guarantee that any User Content you or any user provides will not be viewed by unauthorised third parties. SpaceIn users and account holders should be cautious about the access granted to others and the information shared when using the Sites and Apps and be aware that no security measures are perfect or impenetrable. SpaceIn is not responsible for circumvention of any security measures contained in the Sites or Apps.
MCCGLC reserves the right to revise, modify, or update this notice at any time. We will notify you via email about material changes in the way we treat personal data or by placing a prominent notice on this website.
If you have a privacy concern regarding MCCGLC or this notice, you may contact us at firstname.lastname@example.org.