- Important information and who we are
- The data we hold about you
- How is your personal data collected and used
- Access, sharing and disclosures of your personal data
- Data retention and disposal
- Changes to this privacy notice
- Your rights
- Your acceptance of this privacy notice
- Contacting us or making a complaint
- Important Information and who we are
Purpose of the Privacy Notice
First, we should tell you who “we” are. Our registered company name is Cowork Ventures Ltd (company no. 10136014; The Gallery, Kings Wharf, The Quay, Exeter, Devon, England, EX2 4AN). We are VAT registered (no. GB243133835) and registered as a data controller with the UK Information Commissioner’s Office (ICO; no. ZA631931). Cowork Ventures Ltd is referred to by its business name The Generator Hub (The Generator Hub, we, our, or us). If you have any questions about this privacy notice, including any requests to exercise any of your legal rights, please contact us by emailing [email protected].
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 practices. When you leave our website, we encourage you to read the privacy notice of every other website you visit.
- The data we hold about you
Personal data refers to any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity data includes first and last name, date of birth, gender, social media accounts, employer, company name, skills and interests, and image;
- Contact data includes email address, home or registered office address and personal and/or work phone numbers;
- Financial data includes bank account and payment card details;
- Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone settings and locations, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
- Usage data includes information about how you use our website and services;
- Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
Other than as captured incidentally via our CCTV systems, we do not collect, via any means, any Special Categories of Personal Data about you, such as but not limited to, your race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health / medical information (unless you voluntarily disclose this information to us for health & safety purposes, for example a severe allergy or a heart condition we should be aware of).
Control of your personal data
Customers who access our services and/or buildings have the option to provide us with personal data when they contact us or when using our desk or meeting room booking applications. Aside from mandatory information (name, email address, physical address, company name and phone number), customers have control over what information they provide to us and whether they consent to some of this personal data being shared with others via third-party applications, for example WhatsApp and Slack. Customers can always refuse to supply personal identification information, except this may prevent them from engaging in certain Generator Hub related activities.
Your duty to inform us of changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your associated time with us.
- How is your personal data collected and used?
Data collection methods
We use a number of methods to collect personal data from you. These collection methods include:
- Direct interactions with you; in person, on the phone, via email, by telephone, by post and through any of our social media platforms, for example Instagram, LinkedIn, Facebook and Twitter;
- Photo identification; we may ask you to provide photo identification (e.g. driver’s licence / passport) to prevent fraudulent use of our services. Images must be sent securely to our private and password protected email and will be stored on a secure server (Dropbox) which is also private and password protected.
- Data capture forms; via our website or third-party applications;
- CCTV; we use CCTV in various locations around the cowork space to ensure the space remains safe. We adhere to the ICO’s code of practice for the use of CCTV and do not need to ask individuals’ permission to use CCTV. Security cameras are clearly visible around the office across several vantage points. CCTV footage is stored on an external hard drive, which will keep footage on record for up to 20 days. After this period, footage is overwritten. Should any legal authorities request our CCTV footage, we have the right to hand the relevant footage to them.
- Interactions with our website or third-party desk / meeting room booking apps; these may include, but not limited to, Coherent, Mailchimp, Hubspot, Xero, Stripe, AndCards, and internal contact forms. All personal information is stored by The Generator Hub, or trusted third-party, in accordance with their own Privacy Policies (see individual websites for more information). Information will also be collected by signing up for any Generator Hub service, including but not limited to, visitors, dedicated desk / private office plans, meeting rooms, day desk plans and virtual office services.
- Network monitoring; The Generator Hub uses a third-party network management system that monitors network usage (Switch Systems, UK). This platform stores IP addresses and network upload/download usage. This information is kept private at all times. The Generator Hub does not store user history or track Internet activity. Should this change, users will be notified. At any time, The Generator Hub has the right to block IP addresses that are either a threat or nuisance. We operate a fair use policy, therefore if internet bandwidth is being restricted due to a customer’s activity, we may restrict network usage.
- From you or third parties such as your employer, our members whose offices you are entering or contacting, analytics providers, electronic payment providers or data aggregators;
- Photos and videos; as part of The Generator Hub community activities, we may take photos or videos. Should promotional photos be taken during or out of office hours, The Generator Hub will aim to give prior notice, ask for permission and give customers the opportunity to remove any confidential information they may have on their screens / desks. Should any photo or video published include confidential information or anything that may cause the customer distress, The Generator can be requested to remove the photo/video where possible. Once photos and videos have been consented by any customer, these may be used longer term as promotional materials by The Generator Hub and therefore must be objected to in writing if consent is withdrawn.
Reasons for Data Collection
The main basis for use of your personal information includes:
- Contracting reasons;
- Legitimate interests; to run our business, to protect us, for the security of our assets and other customers, to administer our IT systems, finance systems, desk booking systems and meeting room booking systems, and to run our website.
Purposes for Data Collection
The purposes for which we need to collect your personal data include:
- To contact and communicate with you;
- To allow you to be contacted by relevant third-parties;
- To provide you (or your employer / employee) with our products and services;
- To provide you with marketing materials;
- To ensure security and to investigate responsibility in the event of any crime, damage or injury;
- To keep our online avenues working, up to date and effective;
- To take and verify payments from you;
- To efficiently run our website, booking apps and social media pages;
- To invite and assist your use of booking apps;
- To allow for payments of products and services;
- To facilitate networking and community building between members and their employees;
- To allow us to monitor and record use of our services (e.g. booked meeting rooms);
- Ancillary purposes, such as maintenance, backups and archiving.
As a customer, we may contact you from time to time by phone or email to provide information about our products or services. You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us, if appropriate, at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.
We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing unrelated to our own company.
- Access, sharing and disclosure of your personal data
Within The Generator Hub, your personal data will only be seen or used by our directors, employees or temporary staff (for example work experience persons), who will have a legitimate business need to access your personal data for the purposes set out in the privacy notice. We take your privacy seriously and have implemented appropriate physical, technical and organisational security measures designed to secure your personal data against accidental loss, destruction or damage and unauthorised access, use, alteration or disclosure.
Except as explained in this privacy notice, we will not share your personal data without your consent, unless required to do so by law. However, we may share your personal data with the third-party service providers highlighted below, who assist us with administering the provision of our services to you, including:
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If this happens, the new owners may use your personal data in the same way as set out in this privacy notice;
- HM revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
- Professional advisors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
- Service providers acting as processors, including:
- Phone provider (Ring Central, UK)
- IT assistance (Switch Systems, UK)
- Meeting room booking application (AndCards, Poland, EU)
- Desk booking application (Coherent, UK)
- Online payment provider (Stripe, Xero, Coherent)
- Analytics and search engine providers that assist with our website (none of this info will be able to identify you personally).
- Agents we engage to perform functions on our behalf, including sending customer communications, analysing data, providing technical support, providing marketing assistance (including market research), processing payments and providing customer support.
In all cases, these third-party providers can only use your personal data for the specific business purposes intended and not for any other reason.
- Data retention and disposal
We will keep your personal data for no longer than necessary, for the purposes set out above. We will retain your information for as long as needed in order to provide the relevant services to you, and for a maximum of 5 years after our last communication with you once you are no longer a customer.
Personal data stored by The Generator will be disposed of to the best of our ability. Personal data may be stored on third-party applications. The Generator Hub can delete personal data information we store internally (Google Drive, Dropbox, social media), however we cannot guarantee this will be deleted by external third parties, therefore in some cases these third-parties may need to be contacted directly by the customer.
- Changes to this privacy notice
- Your rights
You have a number of rights in relation to your personal data. There are circumstances in which your rights may not apply. You have the right to request that we:
- Update any of your personal information if it is inaccurate or out of date;
- Delete the personal data we hold about you – if we are providing services to you and you ask us to delete personal data we hold about you, we may not be able to continue to provide some or all services to you;
- Restrict the way in which we process your personal data;
- Stop processing your data if you have valid objections to such processing; and
- Transfer your personal data to a third-party.
For more information on your rights and how to use them, or to exercise them, please contact us at [email protected] and we will respond to such requests within the time frame permitted by law.
- Your acceptance of these terms
By using this site and services, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our site and services. Your continued use of the site and services following the posting of changes to this policy will be deemed your acceptance of those changes.
- Contacting us or making a complaint
If you have any questions about this privacy notice, the practices of this site, or your dealings with this site, please contact us at: [email protected]; 01392 427111; The Generator Hub, The Gallery, Kings Wharf, The Quay, Exeter, Devon, EX2 4AN.
If you are unsatisfied with our response to any data protection issues you raise with us, you have the right to make a complaint to the Information Commissioner’s Office (ICO). The ICO is the authority in the UK which is tasked with the protection of personal data and privacy. You can contact them through their website: https://ico.org.uk/.