Last updated: 20 October, 2020 20:57
PRIVACY POLICY
This privacy policy was last updated on 12th October 2020
This privacy policy is for StonesThrow Cowork and should be read in conjunction with StonesThrow’s Website Terms of Use and Membership Agreement. Both this Privacy policy and our Terms of Use can be found at the bottom of every page of https://stonesthrow.work
Our Membership Agreement is provided at the point of sign up to those who join our coworking community.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOUR PERSONAL DATA WITH
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
11. QUERIES, REQUESTS OR CONCERNS
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of our service, including any data you may provide through this website or our service management tool when you signing up to use our service.
This website and our service is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller(s)
Stonesthrow Cowork is the controller and responsible for your personal data (collectively referred to as “StonesThrow”, "we", "us" or "our" in this privacy notice). Our contact email is info@stonesthrow.work. For all data matters contact our data protection representative using the email address noted
Third-party links outside of our control
Our website includes links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
We use 3rd party service management tools linked from our website to manage our space including sign up to use our service, automated payment, booking and events. More details are provided about these 3rd parties below.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes your full name, username, date of birth and your company name if applicable
• Contact Data includes your email address, telephone numbers and billing address
• Profile Data includes your username, password, purchases or orders made by you, your interests, preferences and feedback
• Financial Data includes bank account or payment card details
• Transactional Data includes details about payments to and from you and other details of products and service you may have purchased from us
• Usage Data includes information about how you use our website, products and services
• Technical Data includes browser type and version, location, operating system, platform and other technology on the devices you use to access our website and service.
• Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect your 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 the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
• Directly. You may give us your identity data, contact information and marketing permission when you sign up to our service either through our website and management tool or directly with us.
You may also provide this information when filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Subscribe to our service or publications
• Request marketing to be sent to you
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels and other similar technologies. Please see our Cookie Policy for further details.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. For example, our contract with you to provide the service once you have signed up and made payment.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details provided on the contact page of our website.
• Consent this means processing your data where you have given us consent to do so. For example by consenting to the use of cookies on our website. For more information on this example please refer to our cookie policy.
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by using the unsubscribe link within our emails or alternatively by contacting us using the contact details provided on the contact page of our website.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a list, a description of all the ways we plan to use your personal data, with the legal basis we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details noted on the contact page of our website if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
1.
Purpose/Activity: Signing up to use our service
Type of data: Identity, Contact, Financial and Transactional
Lawful basis for processing: Performance of a contract or agreement with you
2.
Purpose/Activity: Marketing or registering your interest in our service - To send you relevant emails which may include offers or services and to show you relevan advertisements across other platforms such as Facebook
Type of data: Identity, Contact, Usage, Technical and Marketing and Communications
Lawful basis for processing: Consent provided by you where applicable
3.
Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy. (b) Asking you to leave a review or take a survey
Type of data: Identity, Contact, Profile, Usage and Marketing and Communications
Lawful basis for processing: (a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
4.
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: Identity, Contact, Profile, Transactional, Usage and Technical
Lawful basis for processing: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation
5.
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: Technical and Usage
Lawful basis for processing: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
When signing up to our service either through our website/service management tool or in correspondence with us you will be subscribed to our mailing list and will be given the option to consent to marketing sent from us.
We will send you information on our news, events and services and may include promotional offers relating to our services.
Third-party marketing
We will get your consent before we share your personal data with any company outside StonesThrow for marketing purposes.
Opting out
You can opt out of our marketing email communications at any time by clicking the unsubscribe link within each email or by contacting us through the contact details noted on the contact page of our website. If you are a member of our service this will not affect the service emails we will send about important updates or changes to the service.
Cookies
We use cookies on our website for a variety of purposes. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us through the contact details provided on the contact page of our website.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• External Third Parties Service
• Providers acting as processors who provide IT and system administration services.
• Specific third parties listed in this section below.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
3rd parties that we share your personal data with:
Cobot is our chosen coworking service management tool. The Cobot applications allows you and us to manage many of the online administration elements of our service such as signing up to our service, managing your membership, making payment, using the booking facilities, using printing facilities, managing your community profile or viewing upcoming events. Cobot is a dedicated tool for use by coworking spaces and is provided to you to ensure your ease of use of our service. When signing up to our service you will be provided with both ours and Cobot’s Privacy Policy. Cobot’s Privacy Policy can also be found here: https://www.cobot.me/privacy-policy
Stripe is our chosen payment provider and integrates with Cobot. When signing up you provide your payment card details to Cobot who in turn pass them to Stripe. Stripe processes the payment from your card and informs Cobot when payment has been received. We have chosen a payment provider that integrates with Cobot to ensure payment is a simple process and provide further ease of use for you. Stripe’s Privacy Policy can be found here: https://stripe.com/gb/privacy
Ezeep is our chosen print management software. Ezeep manages our printing solutions within our service and integrates with Cobot. Cobot will pass the required information to Ezeep to create an account to allow you to use the printing services in our space. The integration with Cobot has been important to us as it allows you to access printing services with ease and for payments associated printing to be integrated with Cobot and added to your next monthly invoice managed by Cobot. Ezeep’s Privacy Policy can be found here: https://www.ezeep.com/wp-content/uploads/ezeep-privacy-data-protection-policy.pdf
MailChimp is our online marketing platform and when signing up to our service you are given the option to consent to our marketing communications. By providing this consent your personal details, such as name and email address are sent to MailChimp in order for us to send you marketing email communications. You can read Mailchimp’s privacy policy here: https://mailchimp.com/legal/
Calendly is an online booking tool that we integrate with our website to allow potential members to book a free trial day with us. Calendly will process Profile and Contact information and share that information with StonesThrow to enable users to book in for their trial day. No Financial data is collected via Calendly. You can read Calendly’s Privacy Policy here: https://calendly.com/pages/privacy
Facebook We use Facebook Pixel on our website. Facebook Pixel is a tracking code which in conjunction with cookies allows us to collect non-personally identifiable information to track and monitor the success of advertisements we use on Facebook and to improve the effectiveness of those advertisements. Facebook Pixel also allows us to create retargeting advertisements and custom audiences for our advertisements on Facebook. For example, if you visit our website you may then see an advertisement on Facebook for our product. Refer to our Cookie Policy for more information on opting out of Facebook Pixel. You can also view Facebook’s Data Policy here: https://www.facebook.com/about/privacy
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. These 3rd parties are detailed in section 5 above. Please see each 3rd parties specific privacy policy for more information about how they manage your data.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes. We will also retain this data for the same period to be able to manage any customer complaints received after they cease being customers.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact our data protection representative by email at info@stonesthrow.work
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We will inform our members by email when we make changes to our privacy policy.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection representative by email at info@stonesthrow.work
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
