SAFE SPACE TECHNOLOGY LTD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value your privacy and have made it our company’s mission to provide you, the user, a safe space to anonymously discuss workplace issues with your employer, without the fear of them ever being able to identify you. You can think of SafeSpace as a ‘middle man’ in the safeguarding relationship, ensuring that you’re only identifiable if you choose to be.
Our software will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of the application;|
|“Cookie”||means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
- Information About Us
Our Site is owned and operated by Safe Space Technology Limited, a limited company registered in England under company number 12678933.
Registered address: 8 Garden Close, Watford, WD17 3DP.
- What Does This Policy Cover?
- What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about Our collection and use of your personal data.
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact us.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.
- What Data Do You Collect and How?
|Data Collected||How We Collect the Data|
|Name, email address, country of registration||Explicitly input into mobile application or web application during registration or subsequent explicit input during normal application usage|
|Messages||Messages are sent between users.|
|Incident reports||Through explicit input of data by the user in our apps and websites.|
|IP address, device type, browser type and version, operating system||From HTTP and TCP request data.|
- How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we use your personal data, and our lawful bases for doing so:
|What we do||What Data we use||Our Lawful Basis|
|Registering you on SafeSpace.||Name, email address, country.||Legitimate interest – connect your account to your organisation’s SafeSpace account and on incident report, attribute the incident data to the correct department|
|Allow messaging between users||Messages sent by one message and surfaced to a desired recipient either anonymously or identifiably, at the users’ request||Explicit consent from user|
|Collect and process incident reports||The incident data provided||Explicit consent from user|
|Use analytics and statistics to understand application performance and usage||IP Address, device type, browser type and version, operating system, sessions||Legitimate interest – anonymised data used to improve our service to customers|
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
On our website, we use the following automated system for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.
- The following automated profiling may take place:
- Using website user behaviour to ascertain a level of interest in our product which then drives advertising decisions
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep The Data|
|Name, email address, country||While you are a user of the platform|
|Incident report||While you are a user of the platform and for up to 24 months after account termination.|
|Messages||While one or both of the members of a conversation are registered on the platform.|
|Anonymised technical device information||Perpetually|
- How and Where Do You Store or Transfer My Personal Data?
We store your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
- Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If you, the user, provide us with explicit permission to share your personal data, it will be shared.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
- How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our website or applications you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
- Can I Withhold Information?
You may access our website without providing any personal data at all. However, to use all features and functions available in our products, you may be required to submit or allow for the collection of certain data.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our site for digital marketing to analyse user traffic and behaviour. For more details, please refer to the table below. These Cookies are not integral to the functioning of our Site and your use and experience of our will not be impaired by refusing consent to them.
All Cookies used by our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a Cookie Banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our site may not function fully or as intended.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|User Session||Keep a user logged in||Yes|
and the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|Advertising||Various, including Linkedin, Google, Twitter, Facebook.||Track user behaviour to gauge product interest and target advertising|
|Analytics||Track user behaviour to allow us to analyse aggregated anonymous traffic data for the improvement of our services|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email [email protected]
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.