Fora Websites & App Privacy Policy

Last Updated: May 2020

1       WHO ARE WE?

Fora Space Limited, its affiliated and group companies (“We” “us“, “our” or “Fora“) provides flexible workspace (our “Space“) and related services (our “Services“). Fora publish a website at www.foraspace.com and www.foratailoredoffice.com (the “Websites“) and web mobile applications (“Apps“) in connection with our Services.

The term “Services” refers to those Services as such term is defined in our Residency Agreement, our online services (including our pages on third party social media platforms such as Instagram and LinkedIn) and the maintenance, use of and access to our Space including any meeting rooms, communal areas and items available therein from time to time.

If you use any of our Services, we will refer to you using the terms “resident”, “you”, “your”, “yours” in this privacy policy (the “Privacy Policy“).

2       WHAT IS THIS DOCUMENT?

We process certain information about you when you apply to use our Space, visit our Websites, use our Apps or use our online portal (“Residents’ Room”) and when you utilise the Services we provide as a member of our Space. Some of the information we collect may be classed as personal data under data protection legislation, that is, “any information relating to an identified or identifiable natural person” (“Personal Information”). This Privacy Policy explains how we process that Personal Information.

3       WHAT PERSONAL INFORMATION DO WE COLLECT FROM YOU?

We collect Personal Information relevant to the activity you choose to undertake with us, including:

3.1             General correspondence

If you correspond with us in any form, we will process and store your name and contact details and any query you might have through our contact form.

3.2             Resident details

We process Personal Information, including your name, address, e-mail addresses and contact telephone numbers when you or the Company for which you work submit a residency application. We may also collect a variety of additional Personal Information from you, including your birthday, gender, qualifications, job title, company name and/or industry.

3.3             Resident due diligence

Pursuant to our obligations under certain money laundering regulations applicable in the UK, we may process Personal Information, including but not limited to your photograph, utility bills, bank statements and certain other government issued documents (e.g. your passport) in order to verify your identity.

3.4             Payment details

We process Personal Information about your debit/credit card, bank account information and payment status that we require for the purpose of recording and processing your membership application and administering your membership. This may include information about you received from our payment processor or bank, for example whether payment has been declined.

3.5             Use of our Space

We process Personal Information about your use of our Space, including location data for example, the times and dates of your access to our Space, who you are visiting or who is visiting you, events you attend and what Services you make use of.

3.6             CCTV

CCTV is installed at our Space to protect the safety of our Residents, employees, guests and their property, as well as to analyse the use of our Space. CCTV footage may be considered Personal Information and will therefore be handled in accordance with this Privacy Policy. In particular, recordings may be accessed by Fora and may be shared with competent authorities or other interested third parties in accordance with applicable laws. The recordings are retained for a limited period of time, but may be kept longer for the investigation of an incident or when competent authorities request us to retain them longer.

The functionality of our CCTV cameras may include the ability to thermally scan individuals, allowing us to identify individuals who are exhibiting symptoms of fever. The purpose of thermal scanning is to identify individuals who may represent higher risk of transmission of certain viruses, for example COVID-19, and we reserve the right to refuse entry to any person who presents with an elevated body temperature consistent with fever. This data will be stored for a limited period of time with CCTV recording data as outlined in the paragraph above.

3.7             Use of our Residents’ Portal

We will process your Personal Information when you use our Residents’ Room. This may include Personal Information:

• that you choose to submit through any discussion forum; and
• profile information such as a short biography, your location, your website, date of birth, or photograph.

We will process and store this information along with any comments, posts or submissions that you make.

3.8             Use of our Apps

We will process your Personal Information when you use our Apps, which may include the information that you submit to the Apps as well as information about how and when you use the Apps, and technical and statistical information about the device from which you access our Apps.

3.9             Use of our Websites

If you visit our Websites we collect some technical and statistical information about your use of our Websites, including:

• the Internet protocol (“IP”) address used to connect your computer or device to the internet;
• your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (as applicable to the device you are using);
• information about your visit, including the website that referred you to our Websites (if applicable), the path that you take through and from our Websites (including date and time), pages that 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
• we collect this information about you using cookies. Please refer to the section on Cookies below.

This technical and statistical information is typically anonymous but may identify you in certain circumstances (“Technical Data”). Where it does, we treat it as Personal Information.

3.10          Cookies

Our Websites uses various cookies. Cookies enable us and others to monitor your browsing behaviour. Information generated by the use of cookies may constitute Personal Information. We may use the Personal Information collected in this manner for the purposes as stipulated in this Privacy Policy. If you want to know more about our use of cookies, read our Privacy Policy.

3.11          Research Data

Your Personal Information may be shared with third party research institutions for research purposes, for example, to better understand the relationship between organisational culture, collaboration and innovation. Personal Information used for research will include information you have submitted as part of interviews with researchers, or information collected as part of a shadowing and observation exercise. Where your Personal Information will be used for research purposes, you will be informed of the specific nature of the relevant research project.

4       HOW WE USE THE INFORMATION COLLECTED FROM YOU

As well as the uses of your Personal Information for the purposes noted above, your Personal Information may be processed in the following ways:

We use your Personal Information only when and to the extent the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include:

1. a. where we need to comply with a legal or regulatory obligation; and
2. h. where you have provided your consent.

Where your Personal Information has been anonymised, but still could be attributed to you when combined with additional information, we will still treat such data as Personal Information, whilst making every effort to keep the anonymised data in a pseudonymised state.

5       WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share your Personal Information:

• Third Parties Designated by You: we may share your Personal Information with third parties where you have provided your consent to do so. This includes with our online and offline resident communities, forums and networks to allow you to share and connect with other residents;
• Research Partners: your Personal Information may be shared with research partners. Our research partners will be required to comply with appropriate security measures to protect your Personal Information. Our research partners are also subject to confidentiality obligations and may only use your Personal Information in relation to the defined research project and not for any other purposes;
• Our Third Party Service Providers and Affiliates: we may share your Personal Information with our group or third party service providers as part of the operation of our business (for example, to provide our Services, enhance the functionality of our Services, to obtain information necessary to reply to your correspondence, [to provide payment processing] or to process your membership enquiries). We may also share your Personal Information with our third party service provider to enhance our Services (for example, to source the right products for you, to obtain effective targeting of our marketing campaigns and develop new products. These third parties are only permitted to use your Personal Information to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Information. Third parties are subject to confidentiality obligations and may only use your Personal Information to perform the necessary functions and not for other purposes;
• Corporate Restructuring: we may share your Personal Information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding;
• Other Disclosures: we may share Personal Information as we believe necessary or appropriate:

1. a. to comply with applicable laws;
2. b. to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements;
3. c. to enforce our Privacy Policy; and
4. d. to protect our rights, privacy, safety or property, and/or that of you or others.

6       MARKETING COMMUNICATIONS

With your consent, Fora may use your Personal Information for the following purposes:

• Targeted Advertising: in order to serve offers and advertisements that may interest you, we may display targeted advertisements on the Websites, or other digital properties or applications in conjunction with our content based on your use of our Services, information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide your Personal Information to advertisers when you interact with an advertisement.
• Your Ad Choices: some of the third party services providers and/or advertisers may be members of the Network European Interactive Digital Advertising Alliance (“EDAA“) Self-Regulatory Program for Online Behavioural Advertising. To learn more, visit http://www.edaa.eu/what-we-do/for-consumers/ which provides information regarding targeted advertising and the “opt-out” procedures of EDAA members.

You may also opt-in to receive marketing emails from third-parties, in which case Fora will, with your consent, provide your Personal Information to these third parties who may directly contact you about non-Fora products and services.

If you do not wish us to use your Personal Information in the manner prescribed above, you may change your preferences at any time by contacting us using the details below. If you choose to opt-out of receiving marketing emails from third parties, please contact the third party directly and/or follow the instructions in their marketing emails.

7       WHERE IS YOUR INFORMATION STORED AND PROCESSED?

We will process and store your Personal Information in our IT systems, which includes cloud hosted IT systems. We employ organisational and technical methods to secure your Personal Information, and require that our service providers do the same.

If you are based in the European Economic Area (“EEA”) note that your Personal Information may be transferred, processed and stored outside of the EEA, for example in connection with our use of cloud hosted IT systems. In the event that your Personal Information is transferred to, maintained or processed by other parties located in the United States or otherwise outside of the EEA, all such transfers will be made in compliance with applicable law to afford you the same levels of protection as you enjoy within the EEA.

8       SAFEGUARDING YOUR PERSONAL INFORMATION

Fora will take reasonable care to protect your Personal Information by maintaining appropriate safeguards against the information you provide to us. We employ effective data security through the use of secure servers and encryption to protect your Personal Information from unauthorised use where we have given you or you have chosen a password which enables you access to our Services, you are responsible for keeping this confidential. Whilst we take such measures to safeguard your Personal Information, we cannot guarantee absolute security of your Personal Information.

9       HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will not keep your Personal Information longer than reasonably necessary to fulfil the purposes described in this Privacy Policy or as we reasonably need to in order to meet our legal and governance obligations.

10     YOUR CHOICES AND RIGHTS

You have the right to:

• Request Access: you have the right to ask us for a copy of the Personal Information we hold about you, and further details about how your Personal Information is processed and with whom it is shared. The request must be made in writing and will require you to supply acceptable identification. We undertake to provide a response within 30 days of receiving your request and proof of your identity. In some circumstances it may not be possible to release some or all of the information. In this case, we will provide you with a valid reason why we cannot release it, within the 30 day period;
• Request Correction: the accuracy of your Personal Information is important to us. If you wish to inform us of any changes to your Personal Information or you believe any information we hold is inaccurate, incomplete or out of date, please contact us so we can make the necessary changes. In the unlikely event we are unable to comply with your requested changes, we will provide you with a valid reason;
• Request Erasure: you can also, where appropriate, have your Personal Information erased, or ask us to stop or limit our processing of it;
• Object to Processing: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes;
• Request the Restriction of Processing: this enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it;
• Request the Transfer: of your Personal Information to another party; and
• Right to Withdraw Consent: if we process Personal Information on the basis of your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.

11    LINKS TO OTHER WEBSITES

This Privacy Policy does not cover the links within our Websites linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

12    THIRD PARTY SERVICES

We may make third party services available through our Space or Services.  This Privacy Policy does not cover those third party services.  If you choose to use those third party services we encourage you to read the privacy statements made available by their providers.   We may share your Personal Information with such third parties when the facility exists to do so and you ask us to, for example, when you request such services through our App, in order to save you from having to provide your Personal Information again.

13    THIRD PARTY PERSONAL INFORMATION

If you submit the Personal Information of any third party to us in any manner, you must ensure that they are aware of and agree with the processing of their Personal Information by Fora according to this Privacy Policy.

14     CHANGES

We may update this Privacy Policy at any time, and we will notify you if we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Information.

15    REGISTRATION

Fora Space Limited is registered with the Information Commissioner’s Office under registration number ZA203799.

16    CONTACTING US

Please contact us if you have any queries about this Privacy Policy at:

Data Protection Administrator
Fora Space Limited
89, Wardour Street,
London
W1F 0UB

 Email: gdpr@foraspace.com

At all times, we will offer you the opportunity to unsubscribe from any service or marketing communication to which you have subscribed. Any direct marketing you receive from us, will tell you how to unsubscribe and opt out of direct mail. If you have any further enquiries, please contact us at the above details.

In some cases you may have the legal right to access, correct, remove, or prevent processing of any of your Personal Information. If you would like to exercise this right, please refer to and submit the ‘Data Subject Request’ form available on the Websites and App. Please be aware that in some cases we may not be able to process your request, for example, if it is technically impractical, risks the privacy of others, or causes a disproportionate burden on us.

17    COMPLAINTS

Should you wish to make a further enquiry or complain about how your Personal Information is being handled, you may raise your concern with the Information Commissioner’s Office (the “ICO“). Further details on reporting a concern can be found on the ICO’s website at https://ico.org.uk/concerns/handling/.