WEBSITE PRIVACY POLICY

Last updated 2021/03/24

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

These terms and conditions of use (Terms) explain how you may use this website (www.recentspaces.com) and any of its content (Site). These Terms apply between Recent Spaces Limited (we, us or our) and you, the person accessing or using the Site (you or your).

You should read these Terms carefully before using the Site. By using the Site or otherwise indicating your consent, you agree to be bound by these Terms. If you do not agree with any of these Terms, you should stop using the Site immediately.

About Us

We are Recent Spaces Limited, a company registered in England and Wales under company registration number 10144626. Our registered office is at Studios 4.3 and 4.4, Battersea Studios 2, 82 Silverthorne Road, London, SW8 3HE. Our VAT registration number is 239790564.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

Our Website

This privacy policy relates to your use of our website, https://www.recentspaces.com, only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties including our social media accounts with Facebook, Instagram, LinkedIn and Twitter. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, contact us, and send us feedback.

We collect this personal information from you either directly, such as when you contact us or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).

The personal information we collect about you depends on the particular activities carried out through our website. This information includes:

• Personal information: your name and contact information, including email address and telephone number and company details

• Information regarding your location and use of our Site.

• details of any feedback you give us by phone, email, post or via social media

• information about the services we provide to you

• Cookies and usage data. Usage data may include information relating to your computer’s IP address, time, date, and length of time of your visit to our Site

• details that you provide to us relating to your professional background and your professional online presence (e.g. LinkedIn Profile, personal portfolios)

• Your billing information, transaction, and payment card information

• Information to enable us to undertake credit or other financial checks on you

We use this personal information to:

• verify your identity

• assist in providing services to you

• keep you updated with news and information we consider relevant to you

• customise our website and its content to your particular preferences

• notify you of any changes to our website or to our services that may affect you

• improve our services

• process your job application if you have applied for a position with us

This website is not intended for use by children, and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose

• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)

• legitimate interests: A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

Use of Information

For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our contract with you or to take steps at your request before entering into a contract. To address queries and to contact you with marketing and/or promotional materials and any information that may be relevant to you.
To prevent and detect fraud against you	For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for us and for you
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, service range or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
When conducting our marketing campaigns: - to deliver relevant advertisements and information for you - to recommend services and offers that may be of interest to you - to measure the effectiveness of the advertising provided - to improve our website, services, marketing, customer experiences - for market research and survey purposes	We rely on your consent to use your personal data when conducting our marketing campaigns. For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to satisfy invoices for our services.
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations

Marketing

We may use your personal data to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions, or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘Use of Information’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting us at studio@recentspaces.com.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

Who we share your personal information with

We routinely share personal information with:

• third parties we use to help deliver our products and services to you, e.g., payment service providers, film makers, designers, and photographers.

• other third parties we use to help us run our business, e.g., marketing agencies, accounts payable or website hosts;

• third parties approved by you, e.g., social media sites you choose to link your account to or third party payment providers; and

• credit reference agencies.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

How long your personal information will be kept

We will keep your personal information while you have an account with us, or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;

• to show that we treated you fairly;

• to keep records required by law.

Transferring your personal data out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.:

• if you are based outside the UK;

• where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:

• the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);

• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

• a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);

• Gibraltar; and

• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;

• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;

• the transfer is necessary for a contract in your interests, between us and another person; or

• the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights, and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

European Commission adequacy decision

The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from the UK to that country without any further safeguards being necessary.

It can take several years for the European Commission to issue an adequacy decision and only a small number of countries currently benefit from one.

Further information

If you would like further information about data transferred outside the UK, please contact our us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us —see below: ‘How to contact us’;

• let us have enough information to identify you;

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 15 March 2021 and last updated on 15 March 2021.

We may change this policy from time to time, when we do we will inform you via email.

How to contact us

If you wish to contact us, please send an email to studio@recentspaces.com or telephone +44(0) 203 637 9745.

Do you need extra help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g., computer, smartphone or other electronic device) when you use our website. We use cookies, web beacons, tracking pixels and other tracking technologies on our website including other media channels, mobile website, or mobile application related or connected to our Site. This helps us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies and web beacons, tracking pixels and other tracking technologies on our website, and our use of such tracking technology, when we will request your consent before placing them and how to disable them, please see our Cookie Policy: www.recentspaces.com/cookie-policy.