Privacy Policy

Last Updated: January 12, 2024

About This Privacy Policy

This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by Spaciv GmbH (“we”/ “us” / “our”). This Policy applies where we are acting as a Data Controller, where we determine the purposes and means of the processing of that personal data, for example with respect to the personal data of our website visitors, service users, clients, partners etc.

This policy sets out how we will collect, store and process the information that you provide to us, information we collect as a result of our interaction, the information we collect about you from other sources, or information we service about you by using the information we hold.

The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process, and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully;
• Be obtained only for specific, lawful purposes;
• Be adequate, relevant, and not excessive;
• Be accurate and kept up to date;
• Not be held for any longer than is necessary;
• Processed in accordance with the rights of the data subjects;
• Be protected in appropriate ways;
• Not be transferred outside the EU/UK, unless that country or territory also ensures an adequate level of protection.

We take these responsibilities seriously; this document describes our approach to data protection. 

This policy helps to protect us from data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately;
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them;
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data;
• Any other risks inherent in the collection, storage, or processing of your data.

Data Controller

Responsible for data processing in terms of data protection is: spaciv GmbH

spaciv GmbH is registered in Germany.

You can contact us in any of the following ways:

Name of Data Protection Lead: Charles Fergusson

Company name: spaciv GmbH

Data Protection Lead Address: Luise-Ullrich-Straße 14, 80636 Munich, Germany

Data Protection Lead e-mail address: charles.fergusson@spaciv.com

Data Protection Officer

In accordance with the requirements from Article 37 from the GDPR, Spaciv GmbH has appointed a data protection officer for you to contact if you have any questions or concerns about Spaciv GmbH personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to spaciv GmbH Data Protection Officer:

Adam Brogden
GDPR Local Ltd‍
dpo.support@gdprlocal.com
Tel + 441 772 217 800
1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

Who this privacy policy applies to

This policy relates to data subjects of Spaciv GmbH including clients, customers, suppliers, partners, employees, and all other individuals. Processing of your data is required in order to offer you our products and services and to run our company. It applies to all data that the company holds relating to identifiable individuals.

Types of information we collect

1. Personal Information: We may collect various types of personal information, including but not limited to:

• Name
• Contact Information (email address, phone number, address)
• IP address
• Location data
• User-generated content
• User preferences and settings

1. Usage Data: We may collect information about how you use our website and Spaciv software, including your interactions and activity.
2. Cookies and Tracking Technologies: We use cookies and similar tracking technologies to collect information about your browsing behaviour. You can manage your cookie preferences through your browser settings.

Age Limitations

We do not knowingly collect or maintain Personally Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted.

If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally Identifying Information to the Website, please contact us using our contact information below to have that child’s account terminated and information deleted.

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

• The Information you provide when you contact us
• When you contact us in order to discuss using our services
• Information we collect about how you use our website
• Information relating to services we offer to you and other transactions including financial and other personal information required to complete these transactions
• Information that is given and stored as part of our ongoing relationship
• Information we collect as a result of our interaction,
• The information we collect about you from other sources,
• or information we service about you by using the information we hold.

We do not routinely collect or process sensitive data about you. However, where this is the case we will ensure we take appropriate precautions to protect your data.

How your information will be used

We may use your personal information for the following purposes:

• To provide and maintain our services
• To improve our website and Spaciv software.
• To personalise your user experience
• To communicate with you, including responding to inquiries and providing updates
• To ensure the security and integrity of our services
• To comply with legal obligations.

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	a. Identity b. Contact	a. Performance of a contract with you b. Consent
To process and deliver the products and services you request including digital signages, and to manage payments, fees and charges.	a. Identity b. Contact c. Financial d. Transaction e. Marketing and Communications	a. Performance of a contract with you b. Necessary for our legitimate interests to recover debts owed to us c. Consent
To manage our ongoing relationship with you which will include notifying you about changes to our terms, services or privacy policy, to maintain our records	a. Identity b. Contact c. Profile d. Marketing and Communications	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 services d. Consent
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	a. Identity b. Contact c. Technical	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 c. Consent
To use data analytics to improve our website, services, marketing, customer relationships and experiences	a. Technical b. Usage	a. Necessary for our legitimate interests to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy b. Consent
To make suggestions and recommendations to you about services that may be of interest to you	a. Identity b. Contact c. Technical d. Usage e. Profile	a. Necessary for our legitimate interests to develop our services and grow our business b. Consent

 

We may collect and process information about you, including your name, address, date of birth, contact details (including email address and mobile phone number), payment and invoice information, device information, IP address, and website traffic if cookies are consented to be used during your browsing session.

We may take personal information from a range of sources. For example, when you visit our website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.

– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number.

We refer to this information as “Order Information.”

We will use your data for the purpose it was collected and where we have your consent or an appropriate lawful basis we may use your personal information to provide you with marketing information about services, promotions and offers that may be of interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any services we provide to you.

You will only receive marketing communications from us if you have:

• Requested information from us
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
• You have not opted out of receiving marketing
• Where we have an appropriate lawful basis

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

How to change your preferences

We operate in line with the GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities. Where possible any requests or objections should be made in writing to the Data Controller, or you can visit our website, call, or email us to contact us to exercise your rights, make a complaint, or change your preferences at any time.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.

Do not track

We do not alter our website data collection and use-case practices when we see a Do Not Track Signal from your browser.

How we store and process your data

Your data will be collected, stored and processed securely, where we transfer your data internationally, we will ensure we take appropriate precautions to protect this data. Your data will normally be stored as long as necessary in order to meet our legal obligations and protect our interests. For more information please refer to our Data Retention Policy.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Our obligations and Your Rights

We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data;
• Request correction of your personal data;
• Request erasure of your personal data;
• Object to processing of your personal data;
• Request restriction of processing your personal data;
• Request transfer of your personal data;
• Right to withdraw consent.

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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

We aim 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.

Third Parties

We may have to share your personal data with selected third parties in order to meet our obligations to you and for the purposes described in this document:

• Service providers who provide IT and system administration services;
• Third parties including data processors, suppliers, service providers, equipment providers, and other third parties as required to run and grow our business;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services;
• Other technology companies providing tracking, analytics, and advertising companies;
• Social media companies;
• Partners and other organisations involved in the provision of our services to you and as required to operate our company;
• Government organisations, legal authorities when required by law or to protect our rights;
• Third parties to whom we sell, transfer, or merge parts of our business or our assets;
• Other companies as required to meet our obligations to you and run our business.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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 such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Where required under GDPR will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

Our website may include links to third-party websites, plug-ins 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.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine.

Contacting us, exercising your information rights and Complaints

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact us at: support@spaciv.com, contact Charles Fergusson from spaciv GmbH:  charles.fergusson@spaciv.com , or our designated Data Protection Officer:

Adam Brogden from GDPR Local Ltd‍.

E-mail address: dpo.support@gdprlocal.com

We aim to process data protection requests within 30 days, SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

If you remain dissatisfied, then you have the right to apply directly to your local data protection authority.  You can find the list at:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We will update the “Last Updated” date at the top of the policy.

Consent

By using our website and Spaciv software, you consent to the terms of this Privacy Policy.