1.1 We are committed to safeguarding the privacy of our website visitors and individual members.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to Soulspace Corporation Limited. For more information about us, see Section 20.
The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name and email address, as provided by you through our website.
2.3 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.4 We may process data about your use of our website and services] (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.5 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Relationships and communications – We may process contact data, and/or communication data for the purposes of managing our relationships and communicating with you (excluding communicating for the purposes of direct marketing) by email. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and individual customers, the maintenance of our relationships and the proper administration of our website and business.
3.3 Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website and business generally.
3.4 Record keeping – We may process your contact data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.5 Security – We may process your contact data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website and business, and the protection of others.
Retaining and deleting personal data
4.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 12 months following the date of the most recent contact between you and us, and for a maximum period of 24 months following that date;
(b) communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a maximum period of 24 months following that date;
(h) usage data will be retained for 24 months following the date of collection.
4.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1 In this Section 9, we have listed the rights that you have under data protection law.
5.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your contact data;
(b) the right to rectification – you can ask us to rectify inaccurate contact data;
(c) the right to erasure – you can ask us to erase your contact data;
(d) the right to restrict processing – you can ask us to restrict the processing of your contact data;
(e) the right to object to processing – you can object to the processing of your contact data;
(f) the right to complain to a supervisory authority – you can complain about our processing of your contact data; and
(g) the right to withdraw consent – to the extent that the legal basis of our processing of your contact data is consent, you can withdraw that consent.
5.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
5.4 You may exercise any of your rights in relation to your contact data by written notice to us, using the contact details set out below.
Third party websites
6.1 Our website includes hyperlinks to, and details of, third party websites.
6.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
7.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
7.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.1 We may update this policy from time to time by publishing a new version on our website.
11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
12.1 This website is owned and operated by Soulspace Corporation Limited.
12.2 We are registered in England and Wales under registration number 00683375, and our registered office is at 4th Floor 100 Fenchurch Street, London, England, EC3M 5JD.
12.3 Our principal place of business is The Boathouse, Millbrook, Guildford, GU1 3XJ.
12.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form.