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Website Privacy Policy

Last Updated: 22nd May 2018

  1. Introduction

    HeadBox respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

    Our Privacy Policy is incorporated into our Terms and Conditions.

    Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  2. Important information and who we are

    Purpose of this privacy notice

    This privacy notice aims to give you information on how Headbox collects and processes your personal data through your use of this Site, including any data you may provide through when you sign up to an account/create an account or subscribe to mailing lists or marketing.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

    Controller

    HeadBox is the controller and responsible for your personal data (collectively referred to as "HeadBox", "we", "us" or "our" in this privacy notice).

    We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

    Contact details

    Our full details are:

    Full name of legal entity: HeadBox Solutions Ltd (reg no: 09410663)

    Email address: terms@headbox.com.

    Postal address: 25 Holywell Row London EC2A 4XE

    Telephone number: 020 3642 9353

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

    Changes to the privacy notice and your duty to inform us of changes

    We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Site or by sending an email to you. We will also update the “Last Updated Date” at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

    It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Site to you, and your only option will be to stop accessing the Site and deactivate your HeadBox account.

    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 relationship with us.

    Third-party links

    The Site will contain links to other websites not owned or controlled by HeadBox. HeadBox does not have any control over third party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

    Some portions of the Site implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at http://www.google.com/intl/en_uk/help/terms_maps.html) and Google’s privacy policy (located at http://www.google.com/privacy.html), as may be amended by Google from time to time.

    We do not control these third-party websites and are not responsible for their privacy statements.

  3. The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

    • Contact Data ncludes billing address, delivery address, email address and telephone numbers.

    • Financial Data includes bank account and payment card details.

    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

    • 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. When you use certain features of the Site, in particular any mobile applications we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Site or specific features of the Site). If you access the Site through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, and feedback responses.

    • Usage Data includes information about how you use our website, products and services.

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

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail to provide personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  4. How is your personal data collected?

    We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

      • fill in any form on the Site such as when you register or update the details of your user account;

      • access or use the Site, such as to search for venues and Spaces, make or accept bookings, pay for Spaces or venues, book or pay for any associated services that may be available (such as but not limited to cleaning, food and insurance), post comments or reviews, or communicate with other users;

      • create an account on our website;

      • subscribe to our service or publications;

      • request marketing to be sent to you;

      • enter a competition, promotion or survey; or

      • give us some feedback.

    • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. We may also receive, store and process the date and time you access or use the Site, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.

    • Third-party social plugins. Our Site may use social plugins that are provided and operated by third-party companies, such as Facebook’s Like Button. As a result of this, you may send to the third-party company the information that you are viewing on a certain part of our Site. If you are not logged into your account with the third-party company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our Site to your account with them. Similarly, a third party may record your interactions with the social plugin. Please refer to the third party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.

    • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

      • Technical Data from the following parties:

        1. analytics providers such as Google based outside the EU;

        2. advertising networks such as Google Adwords based inside and outside the EU; and

        3. search information providers.

      • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

      • Identity and Contact Data from publicly availably sources such as Companies House.

  5. How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HeadBox or our business partners;

    • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;

    • where we need to perform the contract we are about to enter into or have entered into with you; and

    • 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.

    See below to find out more about the types of lawful basis that we will rely on to process your personal data.

    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

    How HeadBox Uses and Processes User Communications

    We may review, scan, or analyse your communications with other users exchanged via the Site for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Site may scan and analyse messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Site, such as by bank transfer or other money transfer methods. We may also scan, review or analyse messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug product offerings.


    We will not review, scan, or analyse your communications for sending third party marketing messages to you. We will also not sell these reviews or analyses of communications to third parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Site, you consent that HeadBox, in its sole discretion, may review, scan, analyse, and store your communications, whether done manually or through automated means.

    Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity Type of data Lawful basis for processing including
    basis of legitimate interest
    To enable you to access and use the Site
    1. Identity
    2. Contact
    Performance of a contract with you
    To process and deliver your order including:
    1. Manage payments, fees and charges
    2. Collect and recover money owed to us
    1. Identity
    2. Contact
    3. Financial
    4. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you which will include:
    1. Notifying you about changes to our terms or privacy policy
    2. Asking you to leave a review or take a survey
    1. Identity
    2. Contact
    3. Profile
    4. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary to comply with a legal obligation
    3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
    To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HeadBox or our business partners.
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    To help create and maintain a trusted and safer environment on the Site, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;
    1. Identity
    2. Contact
    3. Tecnical
    1. 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)
    2. Necessary to comply with a legal obligation
    To operate, protect, improve and optimize the Site, HeadBox’s business, and our users’ experience, such as to perform analytics, conduct research, and for advertising and marketing;
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    6. Tecnical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
    1. Tecnical
    2. Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you
    1. Identity
    2. Contact
    3. Tecnical
    4. Usage
    5. Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business)

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or have an account with us and, in each case, you have not opted out of receiving that marketing.

    Opting out

    You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

    Change of purpose

    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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  6. Disclosures of your personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above and as set out below:

    • Parts of your public profile page that contain some personal information may be displayed in other parts of the Site to other users for marketing purposes.

    • Your public Listing page will always include some minimum information such as the city and neighbourhood where the Space is located, your public profile photo and your responsiveness in replying to Guests’ queries. Parts of your public Listing page may be displayed in other parts of the Site to other users for marketing purposes. The Site may also display the Space’s approximate geographic location on a map, such that a user can see the general area of the Space.

    • The Site allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Site. If you change your settings or the information on your public profile or public Listing pages, third-party search engines may not update their databases quickly or at all. We do not control the practices of third-party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.

    • When you submit a request to book a space or venue, your full name will become visible to the Host. We will not share your phone number unless there is a confirmed booking.

    • When your request to book a space or venue is accepted by the Host or when you accept a Guest’s request to book your space or venue, we will disclose some of your Personal Information to the Host or Guest. However, your billing information will never be shared with another user.

    • When a Guest uses your space or venue or when you use a Host’s space or venue, we will ask you to review the Guest or the space/venue. If you choose to provide a review, your review may be public on the Site.

    • You may link your account on a third party social networking site to your HeadBox account. We refer to a person’s contacts on these third party sites as “Friends”. When you create this linkage:

      • some of the information you provide to us from the linking of your accounts may be published on your HeadBox account profile;

      • your activities on the Site may be displayed to your Friends on the Site and/or that third party site;

      • other HeadBox users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

      • other HeadBox users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s); and

      • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes.

    • The publication and display of information that you provide to HeadBox through this linkage is subject to your settings and authorizations on the Site and the third party site.

    • We may distribute parts of the Site (including your Listing) for display on sites operated by HeadBox’s business partners, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

    • We may allow our related entities such as our subsidiaries, and their employees, to use and process your personal information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your personal Information under this Privacy Policy.

    • We may also engage third party companies and individuals, who may be located outside of the EEA, to provide services to us, including services to help verify your identification or to conduct checks against databases such as public government databases (where legally allowed). We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

    • External Third Parties as set out in the Glossary.

    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  7. International transfers

    Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

    • Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Europe.

    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

    For more information on how we administer Third Party Processors and Headbox's expectations of them in relation to any personal data that they handle on Headbox's behalf, please see our Third Party Processor Policy

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

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  9. Data retention

    How long will you use my personal data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

    In some circumstances you can ask us to delete your data: see Request erasure below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  10. Your legal rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about your legal rights.

    If you wish to exercise any of the rights set out above, please contact us.

    No fee usually required

    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.

    What we may need from you

    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.

    Time limit to respond

    We try 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.

  11. Glossary

    LAWFUL BASIS

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    THIRD PARTIES

    External Third Partiest

    • Service providers acting as processors who provide IT and system administration services.

    • Professional advisers acting as processors including lawyers, bankers, accountants and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

    YOUR LEGAL RIGHTS

    You have the right to:

    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.