At Pure Offices Limited (referred to as “we”, “us”, “our”) we take privacy seriously and we are committed to protecting it. Collecting and holding your personal data is a serious responsibility, and we want you to know that we are handling it properly and lawfully.
This policy explains when and why we and companies in our group (which means our ultimate parent company and subsidiaries from time to time, as defined in section 1159 of the UK Companies Act 2006) collect personal data about individuals, how this data is used, the conditions under which it may be disclosed to others and how it is kept secure.
Pure Offices Limited (company number 06352067) is the data controller in relation to the processing activities described below. This means that we decide why and how your personal data is processed.
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes. Please see the section Changes to this policy for more information.
- PERSONAL DATA WE COLLECT AND HOW WE USE IT
The categories of personal data we collect about you and the way in which we collect it are as follows:
Personal data you give to us: This is information about you voluntarily give to us by entering information via:
- our website (www.pureoffices.co.uk);
- our social media platforms (such as Facebook, Twitter and LinkedIn);
- our Wifi platform at our centres;
- visiting our offices or making an enquiry at our centres; and/or
- corresponding with us by instant chat, phone, email, or otherwise.
This includes information provided at the time of registering to use our site, contacting us in relation to the services we provide or making an enquiry about our services, posting material or requesting further services, managing your customer account (including accessing documentation and engaging in correspondence with us by phone, email or otherwise).
We may also ask you for information when you report a problem with our website. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well.
The categories of personal data that may be collected voluntarily includes: name, email address, job title or current employment details, address, contact telephone number, enquiry details, identification information, cardholder and payment details, information used to send/receive funds to/from you or that appears on your bills, details of events you have signed up for and attended, legal information relating to claims made by you or against you or the claims process, information relating to the sale of our services, information contained in our correspondence or other communications with you about our services or business (including responses to any surveys), your marketing preferences. We may also collect sensitive personal data where it is proportionate and necessary to do so, including information relating to your health or disabilities and details of the adjustment requirements.
Personal data we collect about you: We may automatically collect the following information: details of transactions you carry out through our website, and your visits to our website, including, but not limited to, traffic data, location data, weblogs and other communication data, the resources you access, and the number and frequency of your visits. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see Cookies for further information. We may also collect any personal data which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Personal data we may receive from other sources: We obtain certain personal data about you from sources outside of our business which may include other third party companies. We offer some of our services on or through other websites and the personal data that you provide to those sites may be sent to us in order to deliver the service. The personal data we receive from third party sources includes information from property agents, brokers and other bodies such as companies house.
- HOW WE USE YOUR PERSONAL DATA
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
- Performance of a contract with you or to take steps to enter into it. We may use and process your personal data where we have supplied you (or continue to supply you) with any services, where we have arranged for the supply of another company’s products or services to you, or where you are in discussions with us about any service. We will use this information in connection with the contract for the supply of services when it is needed to carry out that contract or for you to enter into it.
- Legitimate interests or that of a third party for the following purposes:
- for marketing activities (other than where we rely on your consent to this);
- for analysis to inform our marketing strategy, to help us understand how our website is used and by whom, to research users’ demographics, interests, and behaviour, and to assist, enhance and personalise your customer experience (including with customised services and to make improvements to our services and website);
- other similar purposes. to correspond or communicate with you;
- for business administration, including statistical analysis;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for security, prevention of fraud and other criminal activities (such as through our use of CCTV);
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- to monitor the quality of our support to customers and your communications with us;
- to assess and improve our service to customers and to provide staff training within the business;
- for the management of enquiries, queries, complaints, or claims; and
- for the establishment and defence of our legal rights.
- Compliance with a legal obligation. We will use your personal information to comply with our legal obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
- Vital interests. We may use your personal information to contact you if there are any urgent health and safety notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
- Consent. We may use and process your personal data where you have consented for us to do so for the following purposes:
- to send you direct marketing communications. Please see Marketing below for more information, including how to withdraw your consent; and
- to make service adjustments for anyone with a disability or illness who uses our services and to eliminate any barriers to accessing our services in accordance with our legal obligations. Our processing of special category data, such as health information you give us, will require your consent. We will always request your explicit consent before using any sensitive personal data about you and you have the right to withdraw your consent at any time.
- DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION
Your personal data may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data to share with our investors or for promotional, analytical and research purposes. This information may be collected by cookies placed on our website– please see Cookies for more information.
- OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA
We may disclose your information to the following third parties:
- Group companies. We may share your personal data with other companies within the Pure Offices group (such as our parent company, Northwood Investors International). They may use your personal data in the ways set out in How we use your personal data, in connection with business and financial administration].
- Our suppliers and service providers. We may disclose your information to our third party service providers, professional advisors, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), IT providers, professional advisors (including accountants and lawyers), building or operational service providers, postal service providers, advertising and marketing agencies, communication fulfilment service providers, property agents, brokers and administrative service providers. When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
- Credit/debit card payment processors. When you make payments to us for our services, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
- Customer satisfaction surveys. As customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services.
- Business sale or restructure. We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. It also includes in the event of any liquidation, dissolution, or administration.
- Legal obligation. We may also transfer your personal data if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.
When disclosing your personal information to third parties, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
- WHERE WE STORE YOUR PERSONAL DATA
Personal data you provide to us is stored on our secure servers which are located within the United Kingdom and/or the European Economic Area (EEA)..Companies in our group may store your data in servers based in the US.
Where we transfer your personal data to, or store it in, countries located outside of the United Kingdom or the EEA (for example, hosting services providers ) we ensure that appropriate safeguards (such as Standard Contractual Clauses and EU-US Privacy Shield) are in place for that transfer and storage as required by applicable law. This is because some countries do not have adequate data protection laws equivalent to those in the United Kingdom and EEA.
- HOW LONG WE KEEP YOUR PERSONAL DATA FOR
If we collect your personal data, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal data in an identifiable format for longer than is necessary for the purposes for which we collect it unless we believe that the law requires us to preserve it.
If you have made an enquiry or contacted us via our website in relation to our services, we will store your information for as long as is reasonably required to deal with your enquiry.
If you have contacted us with a complaint or query, we will store your personal data for as long as is reasonably required to resolve your complaint or query.
If you have signed up to receive email marketing from us, we will store your personal data for as long as you are subscribed to our email marketing list (even if you are no longer an active customer). If you unsubscribe, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.
We may need your personal data to establish, bring and defend legal claims. For this purpose we will retain your personal data for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal data above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law, or you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see Erasing your personal data or restricting its processing below); or
- in limited cases, the law permits us to keep your personal data indefinitely provided we put certain protections in place.
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
- SECURITY AND LINKS TO OTHER SITES
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal data, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we have given (or where you have chosen) a password or security code which enables you to access an account or facilities as part of our services, you are responsible for keeping this password and security code confidential.
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We may collect your preferences to receive marketing information (including promotional offers, networking opportunities, and social events) directly from us by email in the following ways:
- if you make an enquiry or register for an online account with us and indicate that you would like to receive marketing information from us;
- if you become a customer, we may contact you with marketing information in the ways mentioned, except where you are an individual (rather than an employee of a company or corporate body) or where you indicate you would prefer otherwise. If you are an individual, we may contact you with marketing information if you provide your consent;
- if you sign up to our newsletter emails via our website or other medium where available; or
- when you refresh your marketing preferences when responding to a request from us to do so.
We may contact you with targeted advertising delivered online through social media and platforms operated by other companies by using your personal data or use your personal data to tailor marketing to improve its relevance to you, unless you object.
You have the right to opt-out of our use of your personal data to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your consent and Objecting to our use of your personal data and automated decisions made about you for further details on how you can do this.
You have a number of rights in relation to your personal data under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. Except in rare cases, we will respond to you within one month from either: (i) the date that we have confirmed your identity; or (ii) where we do not need to do this because we already have this information, from the date we received your request.
- Accessing your personal data. You have the right to ask for a copy of the personal data that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal data. The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by emailing or writing to us at the address at the end of this policy.
- Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using the unsubscribe tool in the email, or by contacting us at the details at the end of this policy. If you withdraw your consent, our use of your personal data before you withdraw is still lawful.
- Objecting to our use of your personal data and automated decisions made about you. Where we rely on your legitimate business interests as the legal basis for processing your personal data for any purpose(s), you may object to us using your personal data for these purposes. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal data for direct marketing purposes by using our unsubscribe tool.
- Automated decisions. In certain circumstances, you may contest a decision made about you based on automated processing.
- Erasing your personal data or restricting its processing. In certain circumstances, you may ask for your personal data to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal data for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes or in connection with legal proceedings.
- Transferring your personal data in a structured data file. Where we rely on your consent as the legal basis for processing your personal data or need to process it in connection with your contract, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.
- Complaining to the data protection regulator. You have the right to complain to the Information Commissioners Office (ICO) (or other relevant data protection authority) if you are concerned about the way we have processed your personal data. Please visit the ICO’s website at https://ico.org.uk/ for further details.
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy, you must immediately notify us and cease using our services.
This policy was last updated on May 2020
Email: Our email address for data protection queries is firstname.lastname@example.org.
Post: If you wish to write to us, please write us at Privacy Matters, Pure Offices Ltd, 2nd Floor, The Blade, Abbey Square, Reading, Berkshire, RG1 3BA.
Phone: If you would prefer to speak to us by phone, please call 0118 321 5077.