Privacy Policy

1. Introduction

This privacy policy (“Privacy Policy”) has been implemented on behalf of COWORK UK Limited (“Venture X”, “we”, or “us”). It is designed to help you understand the personal data (as described in Section 2, below) we collect from you in relation to our interactions with you online, when you visit our premises (“Workspaces”), why we collect it, what we do with it and how you can update, manage, export and delete your personal data. In the event your personal data is shared within Venture X, this is done so in accordance with Sections 8 and 12 of this Privacy Policy. If you have any questions or concerns about our use of your personal data, please do not hesitate to contact us at the contact details set out in Section 15 of this Privacy Policy.

2. Websites covered by this Privacy Policy

This Privacy Policy applies to all our websites and domains including all location or country-specific sites (collectively, the “Websites”). This Privacy Policy does not cover any personal data that you choose to give to unrelated third parties. We do not monitor or control the information collected by such sites or the privacy practices of any third parties, and we are not responsible for their practices or the content of their sites.

3. The Types of Personal Data that We Collect

Personal data is information that relates to an identified or identifiable individual, and it could be as simple as a name or a number, or could include other identifiers such as an IP address, a cookie identifier, or other factors.

We collect personal data to provide our services to you; maintain communications with you; and/or in order to comply with applicable law. Please note that if we have requested personal data from you and you decide that you do not want to share certain personal data with us, then this may prevent us from: (i) providing our services to you; or (ii) entering into a contract to provide services to you. In these circumstances, we will ensure we notify you when reasonably possible to do so.

We collect different types of personal data for different reasons, including:

Contact Information and other personal identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you;

 

Contact and employment-related information of the employees you register to use our Workspaces. This includes name, role, company name, title, business contact details (telephone, mobile phone, e-mail address, postal address).

Utilisation Information, including frequency of visits and services that you use when you visit our Workspaces, such as WiFi usage or room bookings.

Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;

Email Calendar Information, when we integrate with your corporate email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding your conference room bookings;

 

Technical Data: when you visit our website, geolocation information in order to allow us to ensure that we comply with applicable data protection laws and any contact information you provide to us when completing a contact or registration form. Other technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Other Personal Information, including in addition to the information described above, usernames and passwords, relationship to emergency point of contact, vehicle identification, and other details such as the time and purpose of your visit, photos of you, and data or files that you input, upload, or store with our services via our member portal. We will also process personal data included in content and information that you add to the member portal.

CCTV: We use CCTV in our premises for the prevention and detection of crime and for safety and security reasons. Venture X buildings and facilities have CCTV installed to meet our legitimate business interests in protecting the safety of staff, members, and guests and their property. These recordings may be accessed by Venture X. Venture X may also make CCTV footage available to members and other third parties authorised by us. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are generally retained for a limited period of time but may be kept longer where we or an applicable member determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request us to retain them.

 

4. How do we Get Your Personal Data

Most of the personal data we process about you is provided to us directly by you for one of the following reasons:

• when you contact us on our website;
• when you visit one of our Workspaces;
• when you complete a registration form or booking on our website;
• when you contact us via LinkedIn or other social media;
• when you phone us;
• when you provide us with details in order to set up a contract for the provision of our services; and
• when you opt-in to receive marketing and service-specific communications from us.

 

Personal Data from a Third Party

We may also receive personal data indirectly from our third-party sources in order for us to send marketing material to individuals: (i) that have consented to their details being shared with us and to receive marketing material, or (ii) where we have a legitimate interest in sending you our marketing material and our legitimate interest does not override your data protection interests or your fundamental rights and freedoms.

We provide you with choices about how we use your personal data, in accordance with applicable law, by allowing you to opt-out of receiving all such communications (unless they are transactional solely related to the provision of our services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where permitted by applicable law, you may have the right to object to our uses of your personal data as further described in Section 8 of this Privacy Policy.

We ensure that, where we receive your personal data indirectly, the third party providing your personal data has the necessary lawful basis to share your personal data with us.

5. Electronic Communications

Once you register with one of our Workspaces, we will send you a welcome email to verify your username and password to access our member portal. We will also respond to your enquiries, provide services you request and manage your account. We will communicate with you by email and will make every effort to honor your preference.

Subject to the marketing preferences which you give us, we will also send you information on new products, services, and general information. If you do not want to receive this information, you can opt-out of receiving future mailings in accordance with Section 6 below.

If you ask to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. You may unsubscribe at any time. When necessary, we will send you service-related announcements, which are not promotional in nature. If you do not wish to receive them, you can opt-out of receiving these announcements.

If you subscribe to the online community network, we will use your name, email address and password to activate such subscription. You may unsubscribe at any time. When necessary, we will send you service-related announcements, which are not promotional in nature. If you do not wish to receive them, you can opt-out of receiving these announcements.

6. Your rights to Opt-out

 

We give you the choice of receiving a variety of communications that complement our products and services as outlined above. You can subscribe to receive certain product or service-specific information and group-wide marketing communications. Such communications may include upcoming events, introductions to new members and Venture X news. If you no longer wish to receive our newsletters and/or promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communications including by contacting us at hellow@venturex.uk.

7. Why do we Have Your Personal Data

We use your personal data in order to, where applicable:

• respond to any questions or requests;
• communicate with you and provide any further information about our services;
• maintain a business relationship with you;
• undertake our contractual obligations;
• provide our services to you;
• manage any complaints or claims relating to services you provide to us, or our services we provide to you;
• undertake direct marketing, advertising and public relations activities, in connection with Venture X business activities and our services (including to make recommendations about our services, events and/or webinars), and to inform you about developments within the Venture X;
• where necessary, comply with laws and regulations, under judicial authorisation, or to exercise or defend the legal rights of the Venture X; and
• help us conduct our business more effectively and efficiently or improve our services.

In all circumstances we only use your personal data for the purpose it was collected unless we reasonably believe that we need to use such personal data for another, related purpose, and it is legally possible to do so. If we need to use your personal data for any other purpose, we will notify you and let you know the lawful basis on which we propose to rely.

8. Sharing Your Personal Data

We only share your personal data if it is necessary to do so in order to provide our services to you or enhance our relationship with you. Whenever we share your personal data with a third-party provider, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions and we ensure that this is done so in accordance with applicable data protection laws by implementing appropriate measures to maintain the security and confidentiality of your personal data, and to ensure that your personal data is used in accordance with this Privacy Policy. We may share your personal data with the following categories of recipients:

• corporate group companies;
• third-party service providers that: (i) provide a variety of services on our behalf to help improve our services; (ii) building management or facility services; (iii) provide hosting services; (iv) provide data processing services; or (v) process personal data for other purposes detailed in this Privacy Policy. These include but are not limited to:

• professional advisors, for example insurers, lawyers and other applicable professional bodies;
• IT service providers:

• Xero
• Nexudus,
• Hubspot
• Microsoft 365
• DropBox; and
  • subcontractors;

• to any law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary, for example to exercise, establish or defend our legal rights, or we are compelled to disclose such personal data to comply with the law;

• to a potential purchaser or franchisee (and its agents and advisors) in connection with a proposed merger or acquisition of any part or all of our business, provided that the purchaser may not use your personal data for any purpose other than for the purposes detailed in this Privacy Policy; or

• to any other person you have consented to us to share personal data with.

In all circumstances that we share personal data with a third party we only do so to the extent that it is required for them to provide their services to us. At all times your personal data must be processed in accordance with (i) this Privacy Policy; and (ii) any additional data protection terms, incorporated into the agreement that we have with them, which are no less stringent than the protection afforded by this Privacy Policy.

9. Lawful Basis for Processing your Personal Data

Under the Data Protection Act 2018 (“UK GDPR”), the lawful bases that we normally rely on for processing your personal data, detailed above, are:

• Consent. You are able to withdraw your consent to receiving any electronic or marketing communication from us at any time. You can do this in accordance with Section 6 above.
• Contractual Obligation. Where processing is necessary for the performance of our contractual obligations to you.
• Legitimate Interest. Where we have a legitimate interest in processing your personal data, if this is the case we will inform you of what our legitimate interest is at the time of collecting your personal data.
• Compliance with law. When processing your personal data is required to fulfil compliance for legal, regulatory or investigative purposes, e.g. for government agencies and law enforcement.

Other Lawful Bases for Processing your Personal Data

We may need to process your personal data in order to comply with applicable laws, in these circumstances we have a legal obligation to process your data, but we will inform you if this is the case.

In the event we store any Special Category Data (as defined by the UK GDPR) the lawful basis for processing is determined by the category of personal data being processed.

Where we undertake direct marketing, we only do so with your consent and/or where we have a legitimate interest to do so, but in any event, you have the option to opt out of any direct marketing at any time by clicking the unsubscribe link in our marketing material as described above.

10. How we Store Your Personal Data and for How Long

Venture X will retain your Personal Data only as long as necessary for the purposes for which it was collected; to provide you with services in accordance with our contractual obligations to you; and where required or permitted under law. Generally, this means your Personal Data will be retained until the end of your contractual relationship with us. In addition, such data may also be retained whilst Venture X has a legitimate business need to do so.

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

In relation to direct marketing, we will retain Personal Data (only to the extent necessary) in order to ensure we respect your direct marketing opt-out preferences.

11. Security

 

In order to maintain the confidentiality and security of your personal data including against unauthorised or unlawful processing and accidental loss, destruction, or damage. we have implemented appropriate technical and organisational measures.

By using our services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending an email to you.

 

12. International Data Transfers

 

In order to provide our services to you it may be necessary to transfer your personal data to a country that is different to the country in which we collected your personal data, and such country may not apply the same level of data protection.

In the event we need to make an international transfer to a third party we ensure that we do so in accordance with applicable data protection legislation.

 

13. Your Data Protection Rights

 

When you subscribe to our services, you trust us with certain personal data. We understand that it is essential we work hard to protect your personal data and provide you with the access you need to feel in control of your personal data you provide to us.

Under data protection law, you have rights including:

• your right of access – you have the right to ask us for copies of your personal data;
• your right to rectification – you have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
• your right to erasure – you have the right to ask us to erase your personal data in certain circumstances;
• your right to restriction of processing – you have the right to ask us to restrict the processing of your personal data in certain circumstances;
• your right to object to processing – you have the right to object to the processing of your personal data in certain circumstances; and
• your right to data portability – you have the right to ask that we transfer your personal data you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you do make a request, we will respond to you within one month. Please contact us by email at hello@venturex.uk or by post at COWORK UK Limited, Venture X Chiswick Park, Fifth Floor, Building 7, 566 Chiswick High Road, London W4 5YG.

 

14. Updates to this Privacy Policy

 

This Privacy Policy may be updated from time to time, please note that any changes to the Privacy Policy shall not materially reduce the level of protection afforded hereunder.

 

15. Our Contact Details

Name:	Privacy Team
Address:	COWORK UK Limited, Venture X Chiswick Park, Fifth Floor, Building 7, 566 Chiswick High Road, London W4 5YG.
Email:	hello@venturex.uk

 

 

16. How to Complain

 

If you have any concerns about our use of your personal data, you can make a complaint to us by email at hello@venturex.uk.

You can also complain to the ICO (the data protection supervisory authority in the UK) if you are unhappy with how we have used your personal data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk