• Introduction
• Explaining the legal bases we rely on
• When do we collect your personal data
• What sort of personal data do we collect
• How and why do we use your personal data
• Combing your data for personalised direct marketing
• How we protect your personal data
• How long will we keep your personal data
• Who do we share your personal data with
• Where your personal data may be processed
• What are your rights over your personal data
• How can you stop the use of your personal data for direct marketing
• Contacting the Regulator

1. Introduction

This Privacy Notice explains the types of personal data we may collect about you and how this is stored when you become a Halkin customer and use some of our services or app.

The government has updated the General Data Protection Regulations which state businesses must better inform customers about the data they collect and how this is used and stored. Under the Regulations, Halkin is acting as a Data Controller.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Halkin uses your data.  Depending on the type of service you have, we are required to collect some information from you to validate your identity under the HMRC 2017 Money Laundering Regulations.  

We are also obligated under the FSA to hold some financial data for 5 years after you last took services from us.We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

2. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example; to enable us to, contact you and explain what we do prior to entering into a contract with you, we need your address, phone number and email address.  If your registered office is your home address, we will need to hold this information.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example; we are required under the HMRC MLR 2017 regulations to collect and verify details of company directors in accordance with our Compliance Policy.  We have to hold copies of documents to show HMRC if the audit our procedures.

Legitimate business operation

We require your data to allow you to access the building and services you have purchased.  We also hold data other systems, such as the meeting room booking and visitor management system.  The regulation deems these systems, and the data held, as reasonably expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example; we will provide you with access to our app and members portal to book meeting rooms, view your bill and communicate with Halkin and other Halkin Members.  We need your email and phone number to send you booking confirmations.

We also use your email or phone number to notify you of any visitors or packages you may have.

We will also use your email address details to send you information telling you about member events and services that we think might interest you.

Consent
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In specific situations, we can collect and process your data with your consent.
For example; when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is in connection with a particular service. In most instances we will only require your name, email address and phone number.

3. When do we collect your personal data

• When you register your interest for one of our services directly via our website or through one of our third-party brokers or agents when they will notify you that your details will be passed of workspace providers.
• When you sign up to a Halkin Smart Product or Meeting room via our website.
• When you engage with us on social media.
• When you download or install our app.
• When you contact us by any means with queries, complaints etc.
• When you ask us to email you information about a product or service.
• When you’ve given a third-party permission to share with us the information they hold about you.
• We collect data from publicly-available sources (such as Companies House) when you have given your consent to share information or where the information is made public as a matter of law.

4. What sort of personal data do we collect

• On Initial enquiry we will collect: your name, company name, email and telephone number. We will keep email correspondence and a record of any conversations we have with you in person or on the phone during the sales process.
• When you sign up for a service we will require further information about your business and payment details.  Details of your interactions with us through the Halkin Members portal and emails directly with our team regarding the service we are providing to you will be stored for reference.
  For example; we collect notes from our conversations with you, details of any feedback or comments you make, details of meeting room bookings and other services you may purchase.
• Copies of documents you provide to prove your identity where the law requires this. (Including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
• Details of your visits to our website or app, and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
  We’ll only ask for and use your personal data collected to enable us to fulfil our service obligations to you. Of course, it’s always your choice whether you share such details with us, however we may not be able to provide some of the regulated services such as Halkin Smart Virtual without you confirming your identity.
  
• Payment Details – Business bank and credit card information.  This information may be collected when you sign up but is stored by our payment gateway providers; Worldpay and PTX. Halkin have access to this information to enable us to collect payments we do not store it.
• Your comments and reviews.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

5. How and why do we use your personal data

We want to provide you with the best possible service. One way to achieve that is to get the full picture of you and your business requirement for our service by combining the data we have about you.  We then use this to offer you products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

• To respond to any requests you make directly by using our website or app or via a third-party broker. If we don’t collect your personal data, we won’t be able to provide you with a service and comply with our legal obligations.
• We will keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout.
• We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  For example; your details may need to be passed to a third party to supply or deliver the product or service such as telephone or internet access, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations.
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• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests.
• With your consent, we will use your personal data, to keep you informed by email, web, text, telephone about relevant events and services.
• Of course, you are free to opt out of hearing from us by any of these channels at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to you. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
  For example; in the event of an audit of information we hold on you from HRMC
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• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
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  Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

6. Combing your data for direct marketing

We want to bring you offers and promotions that are most relevant to your business needs at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered as described above. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Brokers or Companies House mentioned above.

7. How we protect your personal data

We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.  Your data will be held in our management software Microsoft 365 and Dynamics CRM and other accounts and business management systems.

We have verified with all our data storage and system providers that they are using the correct encryption methods to comply with the GDPR regulations.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by highly regulated 3^rd party providers using SSL encryption.

Our partners regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

8. How long will we keep your personal data

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
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For example; 
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Contracted Customers – We are legally required to keep records for 5 years after you last do business with us, so we can comply with the FSA regulations.
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Enquiry details – If you have contacted for information regarding one of our services we will retain your information for 3 years or until you tell us you wish to be removed.

9. Who do we share your personal data with

We share your personal data with trusted third parties.
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For example; our security company and our Internet and telephony partners, to enable us to provide the services you have purchased.
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The policy we apply to those organisations to keep your data safe and protect your privacy is listed below;

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
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  Examples of the kind of third parties we work with; – IT companies who support our business systems and provide internet services.
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  Sharing your data with third parties for their own purposes
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  We will only do this in very specific circumstances, for example;
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  For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
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• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

10. Your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
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This is not something we currently do, if we do in the future, we will apply the same procedures to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
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Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

11. What are your rights over your personal data

An overview of your different rights
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You have the right to request;

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete
  For example; when you withdraw consent, or object and we have legitimate overriding interest, or once the purpose for which we hold the data has come to an end
• That we stop using your personal data for direct marketing
• That we stop any consent-based processing of your personal data after you withdrawn that consent.
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  Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
  If we choose not to action your request, we will explain to you the reasons for our refusal.
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  Your right to withdraw consent;
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• Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
  
  Direct marketing
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• You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
  
  Checking your identity
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• To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

12. How can you stop the use of your personal data for direct marketing

There are two ways you can stop direct marketing communications from us:

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• In our apps, you can manage your preferences and opt-out from sections of the Halkin members portal

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

13. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
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If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
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To contact them go to www.ico.org.uk/concerns (please note we can’t be responsible for the content of external websites)