Modern Space Privacy Policy

Last updated: August 2022

1. Introduction

We know that maintaining your trust requires that we protect your privacy. This privacy policy (the Privacy Policy) sets out the basis on which Modern Space will process any personal data that we collect from you when you use our Site, our pages and applications on third-party social networking services, our emails, our mobile applications, or, if you otherwise interact with us online (Media Platforms). This Privacy Policy explains our online information practices and the choices that you can make about the collection and use of your information.

Please read the following Privacy Policy carefully to understand how we use and protect the personal data that you provide to us. In this Privacy Policy, personal data means any information about you personally from which you can be identified.

We strive to ensure that we are clear about how we will use the personal data that we collect. We process personal data in accordance with the UK General Data Protection Regulation (GDPR), Data Protection Act 2018 and other applicable laws that regulate protection and privacy of your personal data, each as amended from time to time (Data Protection Law).

2. Who is collecting your personal data

Modern Space Creative Ltd (t/a Modern Space) is the controller in respect of any personal data that you submit to us or that we collect from you. This means that we decide what personal data we collect and what it is used for.

We are a company registered in England and Wales under company number 13792175. Our registered office address is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

To contact us, or to exercise your rights in relation to this Privacy Policy, please email: [datacontoller@modernspace.com]

3. Changes To Our Privacy Policy

We keep this Privacy Policy under regular review and we may change or replace this Privacy Policy at our sole discretion at any time. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy when using any Media Platforms. Unless stated otherwise, our current Privacy Policy applies to all information collected from a location that displays an authorised link to this Privacy Policy. If appropriate we may contact you with the details of any significant changes to this Privacy Policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal details that you have previously provided change during your relationship with us.

4. The personal data we collect about you and how it is collected

We will collect any personal data or other information about you (including information on the computer device you are using) that you provide to us directly via any Media Platforms or when you contact us. For example, if you contact us with a complaint or enquiry, we may keep a record of that correspondence. We may also ask you for information when you report a problem with our Site.

We may receive your personal data from third parties, such as from social networking platform that you have chosen to allow to share your information with us, and from third party advertising partners when you view our online adverts.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data – your name, social media account user name, date of birth.

Contact Data – your billing address, delivery address, email address, phone number.

Financial Data – your bank account and payment card details.

Technical Data – your IP address, login data, browser type and version, operating system and platform, and time zone setting and location.

Profile Data – your preferences, interests, feedback and survey responses, other social media account user information.

Usage Data – information about how you use our Site, products and services.

Marketing and Communications Data – your preferences in receiving marketing from us and our third parties and your communication preferences. Where this marketing is conducted by electronic means (such as email, SMS and/or MMS) we will only send these where we have your prior consent or, if you are an existing customer, where communications are in relation to the same products or services that you purchased previously (or you looked to purchase with us).

We do not collect any special categories of personal data about you (this includes details about your ethnicity, political opinions or information about your health).

We may collect certain information about your visits to our Site and how you use it using ‘cookies’ or similar tracking technology. This may include your geographical location, IP address, device information, browser type, referral source, length of visit and number of page views and similar information. Please see our Cookies Policy below for more information on how we use cookies.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity, however if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

5. How we use your personal data

We will use the personal data that we collect from you in accordance with this Privacy Policy.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Activity	Type of data	Lawful basis for processing (including basis of legitimate interest)
Dealing with any enquiries you make to us	Identity; Contact	Performance of a contract with you Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Communicate with you regarding our products, services, and promotions	Identity; Contact; Profile; Usage; Marketing and Communications	Necessary for our legitimate interests (to keep our records updated, to grow our business and to study how customers use our products/services)
Provide you with services, products or other materials you request	Identity; Contact; Financial	Performance of a contract with you
Processing and fulfilling any orders you place with us	Identity; Contact; Financial; Usage	Performance of a contract with you Necessary for our legitimate interests (to collect money owed to us)
Dealing with any specific requirements you have given in relation to a particular order you have placed with us	Identity; Contact; Financial; Usage	Performance of a contract with you Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Providing customer services to you (including any after-sales services, complaints or where we have changed our services)	Identity; Contact; Technical; Usage	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, for the provision of administration and IT services, and for network security)
Customising your interactive experience when using our Site, or other Media Platforms Improving our Site, products, service offerings, or otherwise responding to any feedback you have provided us	Identity; Contact; Technical; Profile; Usage; Marketing and Communications	Necessary for our legitimate interests (for running our business, to keep our records updated, to study how customers use our products/services, provision of administration and IT services, network security)
Ensuring that content from our Site is presented in the most effective manner Developing, improve the Site so as to improve your browsing and viewing experience	Technical; Profile Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, for the provision of administration and IT services, to develop our business and to inform our marketing strategy)
Using data analytics to improve our Site, marketing and customer relationships	Technical; Profile; Usage; Marketing and Communications	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
Providing you with marketing communications about our products, services and/or events	Identity; Contact; Technical; Usage; Profile; Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

You can ask us (or a third party) to stop sending you marketing communications at any time by following the opt-out links on any marketing communications you receive or by contacting us at any time. Where you opt out of receiving marketing communications, please note that this will not apply to necessary communications from us in relation to your use of the Site and/or as a result of your purchase of a product or service.

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. 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 applicable law.

6. When we will disclose your personal data to third parties

Other than as expressly set out in this privacy policy or as otherwise permitted under Data Protection Law, we will not share, sell or distribute any of the personal data you provide to us without your consent.

We may disclose your personal data in the following circumstances:

• to our service providers, who handle that data on our behalf and in accordance with our instructions under contract (called data processors). These include IT suppliers, third party data analysis providers and data hosting providers
• to any affiliate or third-party companies and/or organisations to whom disclosure is necessary to enable us to provide you with the services or products you have purchased
• if we are under a duty to disclose or share your personal data to comply with any legal obligation (e.g. where we have a duty to provide data to the police or courts)
• if our business or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets although your data will continue to be used for the same purposes; and
• where disclosure is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be required by law (including without limitation to any legal adviser, court, regulator or other relevant authority).

Media Platforms may contain content and links to other websites that are operated by third parties. In addition, advertisements contained on our Site may operate as links to that advertiser’s website, and such advertisers and third parties may also use and place cookies on your device.

We do not control these third-party websites, advertisements and cookies and this privacy policy does not apply to them. Any information such third parties collect by virtue of you clicking on a third-party link via a Media Platform will be collected and used in accordance with the privacy policy of that third party. It is your responsibility to review any terms and conditions and privacy policy of such third-party websites to find out how they collect and use your personal data and to establish for what purpose they use any cookies.

7. Data security

We employ appropriate technological and operational security measures to protect personal data we hold against any unauthorised access, any unlawful processing or loss. We have procedures in place to deal with any suspected personal data breach and we will notify you and any applicable regulator of a personal data breach where we are required to do so under Data Protection Law.

Data transmission over the internet is not 100% secure, and although we employ appropriate technological and organisational security measures to protect your data from unauthorised access we cannot guarantee the security of any data sent over the internet or by public communications services.

8. International transfers

We may share your personal data within the Modern Space group. This will involve transferring your personal data outside of the UK or EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

In addition, many of our external third parties (such as certain IT systems and data analysis services) are based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.

In order to safeguard your personal data, we will only permit such a transfer of your data outside the UK and/or the EEA under a contract or another appropriate mechanism which is authorised under Data Protection Law. This is to make sure that your personal data is safeguarded in accordance with the same legal standards that apply to us and to your personal data in the UK and EEA.

9. How long we will keep your personal data for

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for.

The criteria we use for determining relevant data retention periods are based on:

• whether we need to keep data to comply with a contract obligation, deal with any potential claims or to enforce our rights (usually the limitation period for dealing with any claims under a contract is 6 years);
• various legislative requirements or guidance issued by any relevant regulatory authority under the Data Protection Law; and
• the purpose for which we collected that personal data and where we have identified a continued legitimate need to hold that personal data to serve such purpose.

Personal data that we no longer need to hold is securely disposed of and/or anonymised, so you can no longer be identified from it. Where personal data is anonymised, we may use this information for research or statistical purposes indefinitely without further notice to you.

10. What are your legal rights regarding your personal data

Under Data Protection Law, you have a legal right to request information about the personal data that we hold about you, what we use that personal data for; who it may be disclosed to, as well as certain other related information (called a subject access request). We try to respond to all legitimate subject access requests within one month, although in the case of complex requests, we may require longer to respond.

We may refuse or charge for administrative time in dealing with any manifestly unreasonable or excessive subject access requests.  We may also ask for further information to locate the specific information you seek before and may apply certain legal exemptions to some of the information we disclose when responding to a subject access request.

You also have a number of additional rights under Data Protection Law, which are exercisable by making a request to us in writing. These rights include:

• that we correct personal data that we hold about you which is inaccurate or incomplete;
• to object to any automated processing (if applicable) that we carry out in relation to your personal data;
• to object to our continued use of your personal data for direct marketing purposes;
• that we erase your personal data without undue delay and/or to object to and/or to restrict the use of your personal data by us for any purpose unless we have a legitimate reason for continuing to hold or use that data (for example, where you have requested that we do not send you marketing materials, we will need to keep some limited information about you to ensure that you are not contacted by us in the future); or
• that we transfer your personal data to another party (i.e. another service provider) where the personal data has been collected with your consent or is being used to perform contract with you and we are processing that data by automated means (i.e. on computer).

If you are unhappy with the way in which we have handled your personal data, please contact us using the contact details above. If you make a request and are not satisfied with our response or believe that we are illegally processing your personal data, you are also entitled to complain to the UK’s data protection regulator, the Information Commissioner’s Office – see: https://ico.org.uk/concerns/

 

Modern Space Cookies Policy

Last updated: August 2022

How We Use Cookies

We (and third parties that provide content, advertising, or functionality on our Site) may use cookies, to facilitate website administration and navigation; to better understand and improve our Site; to determine and improve the advertising shown to you here or elsewhere; and to provide you with a rich online experience. Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

Cookies are essential in order to enable you to move around our Site and use its features, such as accessing secured areas. Other cookies collect information about how visitors use the Site (for instance, which pages visitors go to most often, and if they get error messages from web pages). When combined with information collected when you register on a website, cookies allow us to welcome you back to the site or otherwise provide enhanced, more personal features.

Most browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies or visit please visit www.allaboutcookies.org for further information. Please note that if you disable cookies, you may be unable to access some customised features on our Site.

We use the following cookies and related technologies:

• Performance Cookies – these cookies are used to gather statistical information about the use of our website, also called analytics cookies. We use this data for performance and website optimization.
• Functional Cookies – these cookies enable more functionality for our website visitors, such as by enabling us to personalise our content for you and to remember your preferences. These cookies can be set by our external service providers or our own website. The following functionalities may or may not be activated when you accept this category.- Live chat services- Watch online videos- Social media sharing buttons- Login to our website with social media.
• Advertising / Tracking Cookies – these cookies are set by external advertising partners and are used for profiling and tracking data across multiple websites. If you accept these cookies, we may show our advertisements on other websites based on your user profile and preferences. These cookies also save data about how many visitors have seen or clicked on our advertisements in order to optimize advertising campaigns.
• Analytical Technologies – we also use analytical technologies, such as Google Analytics to collect information about how visitors use our Site. We may use Google Analytics cookies to collect information about how users use our Site in order to improve our Site. Please note that Google Analytics does not track your internet activity after leaving our Site.
• Social Media Platform Cookies – our Site may contain buttons and content from social media sites (such as Instagram, Twitter or Facebook), to enable you to share content from our Site with your social media networks. If you use these features, these social media sites may use their own cookies. Information on how these are used can be found in the respective social media site’s terms and conditions.