Privacy Notice This is the privacy notice of OrcaSpaces Ltd. In this document, “we”, “our”, or “us” refer to OrcaSpaces Ltd. Our registered office is at 63 Victoria Road, Burgess Hill, West Sussex, RH15 9LN
Introduction This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you. We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate. Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or other means.
- Data Protection Officer We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, via firstname.lastname@example.org.
- Data we process We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows: Your identity includes information such as first name, last name, title, and other identifiers that you may have provided at some time. Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting. Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us. Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services. We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. For example, we may aggregate profile data to assess interest in a product or service. However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
- Special personal information We do not collect any special personal information about you.
- If you do not provide personal information we need 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 that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time. The bases on which we process information about you The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you When you buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may use it in order to: • verify your identity for security purposes • sell products to you • provide you with our services • provide you with suggestions and advice on products, services and how to obtain the most from using our website We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
- Information we process with your consent Through certain actions when otherwise there is no contractual relationship between us, such as when you ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us at email@example.com . However, if you do so, you may not be able to use our services further.
- Information we process for the purposes of legitimate interests We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to: • whether the same objective could be achieved through other means. • whether processing (or not processing) might cause you harm. • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so. For example, we may process your data on this basis for the purposes of: • record-keeping for the proper and necessary administration of our business. • responding to unsolicited communication from you to which we believe you would expect a response. • protecting and asserting the legal rights of any party. • insuring against or obtaining professional advice that is required to manage business risk. • protecting your interests where we believe we have a duty to do so.
- Information we process because we have a legal obligation Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information. Specific uses of information you provide to us
- Job application and employment If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
- Communicating with us When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business organisation. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
- Complaining When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person. Use of information we collect through automated systems when you visit our website
- Personal identifiers from your browsing activity Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. Disclosure and sharing of your information
- Information we obtain from third parties Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
- Credit reference To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
- Data may be processed outside the European Union Our websites are hosted in the United States of America. Control over your own information
- Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
- Access to your personal information To obtain a copy of any information you should contact us to make that request. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
- Removal of your information If you wish us to remove personally identifiable information from our data, you should contact us to make your request. This may limit the service we can provide to you.
- Verification of your information When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information. Other matters
- Use of site by children We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian
- Encryption of data sent between us We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
- Retention period for personal data Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us: • to provide you with the services you have requested; • to comply with other law, including for the period demanded by our tax authorities; • to support a claim or defence in court.