The Smith, Kingston – Privacy Policy

Effective 17th August 2018

The Smith, Kingstonmpany Limited and Ventia Ltd, (“we“, “us”, “our”) are committed to protecting and respecting your privacy.

This privacy policy (“Privacy Policy”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be controlled by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (“Act”) and the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the data controller is The Smith, Kingstonmpany Limited, and or Ventia Ltd located at Central House, 47 St. Pauls Street, Leeds, United Kingdom, LS1 2TE.

Information we may collect from you

We may collect and process the following data about you:

Information you give us. You may give us information about you or your company by completing forms or forms within applications on our websites or social media channels connected to our websites (altogether, our Sites) by corresponding with us via phone, e-mail or other means of communication. This includes information you provide when you register interest on our Sites, apps (including Intercom), subscribe to our service, search for a product or service, company, location or tenant, place an order or purchase a product on our Sites, participate in discussion boards or other social media channels/functions on/via our Sites, enter a competition, promotion or survey, enter profile information on our Sites, register with or link to a third party account such as LinkedIn, Facebook or Google and when you report a problem with our Sites. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, registered office information, personal description and photograph, company name, skills, interests, occupation, job title, links to your accounts with third party applications such as LinkedIn, Facebook and Google.

Information we collect about you. With regard to each of your visits to our Sites we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform and device type;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Sites (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. We also use applications which take anonymised recordings of user sessions.

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Sites. We are also working closely with third parties (including, for example, business partners, commercial property agencies/brokerages, payment and delivery services, advertising networks, analytics providers, search information providers, recruitment agencies, credit reference agencies) and may receive information about you from them.

If you registered through LinkedIn, we collect basic profile information (outlined here https://developer.linkedin.com/docs/fields/basic-profile). If you registered through Facebook, we collect basic profile information (including but not limited to first name, last name, profile picture, gender, age range and access to your list of friends that also use our app or email address). If you registered with Google we collect basic information including but not limited to first name, last name and profile image.

Cookies

We use cookies on our Sites to distinguish you from other users of our Sites. This helps us to provide you with a good experience when you browse our Sites and also allows us to improve the Sites. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the websites.

We use persistent cookies and session cookies on our Sites. We use persistent cookies to save your login information for future logins to the Sites. We use session cookies to enable certain features of the Sites, to better understand how you interact with the Sites and to monitor aggregate usage by users and web traffic routing on the Sites. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Sites and then close your browser.

Please find explanation for each cookie used on our website below.

Bing: used to track users on Microsoft domains

Google: used to track users on android domains

LinkedIn: used to track web use for marketing purposes

Google analytics: These cookies are used to collect information about how visitors use our Sites. We use the information to compile reports and to help us improve the Sites. The cookies collect information in an anonymous form, including the number of visitors to the Sites, where visitors have come to the Sites from and the pages they visited.

YouTube: We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.

Intercom: We use Intercom to anonymously track sessions. These sessions are not associated with any specific user. Intercom cookies will expire after one week. The cookies collect information including the number of visitors to the Sites, the pages the visited, and what features they have interacted with on the Sites.

You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use the whole of the Sites or all functionality of the services.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Uses made of the information

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about our products and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you with information about goods or services we feel may interest you following your visit to our Sites, and or completed forms on our Sites. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way please tick the relevant box situated on the form on which we collect your data;
• to notify you about changes to our service;
• to carry out surveys relating to the service we provide; and
• to ensure that content from our Sites is presented in the most effective manner for you and for your computer,

The legal basis for processing your information

We will process the information outlined above on the following bases:

• processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; or
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Information we collect about you. We will use this information:

• to administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Sites safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our Sites about goods or services that may interest you or them; and
• to undertake our obligations in any contract, and or licence agreement

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Information we share with third parties. We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you
• Commercial property agencies to help resolve your requirement but only if you have provided written authorisation or opted into the third party.
• Account managers within our outsourced marketing partner that manage our SEO and social media channels that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 250 women aged over 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men living in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
• Analytics and search engine providers that assist us in the improvement and optimisation of our Sites.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

Personal information we disclose to third parties. We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If The Smith, Kingstonmpany Limited and / or Ventia Ltd, or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any other agreements; or to protect our rights, property, safety, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The personal data that we collect from you will be stored only at destinations inside the European Economic Area (“EEA“) and the United Kingdom if the United Kingdom is not considered to fall within the EEA. To comply with our legal or contractual requirements it may also be transferred to and processed by staff operating outside the EEA or the United Kingdom who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

When making such transfers, we will take steps to ensure that your personal information is adequately protected and transferred in accordance with the requirements of the Act and the GDPR. This typically involves the use of data transfer agreements in the form permitted under data protection law (i.e. the European Commission’s Standard Model Clauses). If there is no data transfer agreement in place, we may use other mechanisms recognised by data protection law as ensuring an adequate level of protection for personal information transfer outside the EEA and the United Kingdom.

Any payment transactions will be encrypted using SSL/TLS technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Sites, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.

We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

• all information you provide to us is stored on our secure servers and designated database system;
• we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and
• we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at the address given at the end of this Privacy Policy.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Data subject access rights

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. We’ll usually share this with you within 30 days of request. Where applicable, other data subject rights will be available to you, including where you are able to:

• access and obtain a copy of your personal data on request;
• require us to change incorrect or incomplete personal data;
• require us to delete or stop processing your personal data, for example where the personal data is no longer necessary for the purposes of processing;
• object to the processing of your personal data where we are relying on its legitimate interests as the legal ground for processing; and
• ask us to stop processing personal data for a period if that personal data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing personal data; and
• exercise the right to data portability, where the processing is carried out to enter into a contract with you and is in respect of the processing carried out by automated means (as elaborated upon below).

Please note that if we ever rely on your consent in order to lawfully process your personal data and then you subsequently withdraw your consent to the use of your personal data for purposes set out in this privacy policy, we will stop processing that personal data and we and we may not be able to provide you with access to all or certain parts of our services.

If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk

Age of users

Our Sites are not intended for anyone under the age of 18, although we acknowledge that we may inadvertently process such personal data.

Changes to our privacy policy

Any changes we may make to our Privacy Policy in the future will be posted on our website www.theboutiqueworkplace.co or available via email upon request. Please check back frequently to see any updates or changes to our Privacy Policy. This Privacy Policy is effective 17th August 2018 and replaces any other Privacy Policy previously applicable from this date.

Retention and deletion policy

Data about you:

Contracts and general correspondence (emails, post and other communications) obtained in the course of providing our services will be stored for 12 years following completion of the services or termination or expiry of the contract with our client (whichever is later).

Contact details for marketing purposes relating to clients and contacts will be held for so long as we believe the information to remain accurate and the individual concerned remains a genuine connection of ours, or of one of our directors and staff. We have a programme for reviewing our contacts regularly, and removing any information which is considered to be out of date or no longer relevant.

Contact

Address: The Smith, Kingstonmpany Limited, and or Ventia Ltd, Central House, 47 St. Pauls Street, Leeds, United Kingdom, LS1 2TE.

Telephone: 020 3405 7000

Email: enquiries@theboutiqueworkplace.co