spacebands is a multi-sensor wearable that monitors external, environmental hazards, anticipates potential accidents, and gives real-time data on stress in hazardous environments.
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Please take the time to read this Privacy Policy carefully to understand our practices regarding your personal information. By using our Services, you acknowledge that you have read and understood this Privacy Policy.
We may collect various types of information when you interact with our Services, including:
1.1: Welcome to the Privacy Policy of Spacebands – a collection of hardware devices that monitor and transmit workplace safety and well-being data to the accompanying mobile application software (‘App’) and web-based software (collectively the ‘Products’). This Privacy Policy should be read in conjunction with our Software as a Service (SaaS) Subscription Agreement and our Hire Agreement and Terms of Use for Hardware (collectively the ‘User Terms’).
1.2: spacebands respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use our Products and tells you about your privacy rights and how the law protects you when you use the Products.
1.3: spacebands Ltd is a company registered in England and Wales under company number 12681754. Our registered office address is Sbarc/Spark, Maindy Road, Cardiff, Wales, CF24 4HQ. We are the controller and responsible for your personal data (collectively referred to as "spacebands", "we", "us" or "our" in this Privacy Policy).
1.4: Words and phrases defined in our User Terms will take on the same meaning when used in this Privacy Policy.
1.5: We have appointed a data protection officer (‘DPO’) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
Full name of DPO: Ronan Finnegan
Email address: ronan@spacebands.com
Postal address: Fieldsafar, East End, Marshfield, Wiltshire, SN14 8NU
Telephone number: 07794637453
1.6: 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.
1.7: Please use the Glossary in section 12 to understand the meaning of some of the terms used in this Privacy Policy.
2.1: This Privacy Policy aims to give you information on how spacebands collects and processes your personal data based on different types of interaction.
2.2: Our Products are not intended for children, and we do not knowingly collect data relating to children.
2.3: It is important that you read this Privacy Policy together with any User Terms or fair processing policy 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 Policy supplements other notices and privacy policies and is not intended to override them.
2.4: We keep our Privacy Policy under regular review. This version was last updated in September 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS or by email or when you next start the App or log onto your account. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Software. Historic versions can be obtained by contacting the DPO using the details above.
2.5: 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.
2.6: This Software may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party apps or websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy policy of every app or website you visit.
3.1: 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) or data about corporate entities, like a company.
3.2: We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.3: Aggregated Data. We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Software 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 Policy.
3.4: Location Data. We also use proximity data to determine your location when using the Products. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by contacting the DPO using the details above or disabling Location Data in your settings.
3.5: Data not provided. 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 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.
4.1: Our Software uses cookies to distinguish you from other users of our Software. This helps us to provide you with a good experience when you browse our Software and also allows us to improve the Software.
4.2: A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer (if you agree). Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:
4.3: You can find more information about the individual cookies we use and the purposes for which we use them below:
4.4: You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Software.
5.1: We use different methods to collect data from and about you, including through:
6.1: We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
6.2: We may also use your personal information in the following situations, which are likely to be rare:
6.3: We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
6.4: We have also set out below, in a table format, a description of all the other 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. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
6.5: If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with the services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of workers).
6.6: We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
6.7: Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7.1: We strive to provide you with choices regarding certain personal data uses, particularly around direct marketing and advertising. We have established the following personal data control mechanisms:
8.1: We may share your personal data with the parties set out below for the purposes set out in section 6 above:
8.2: 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.
9.1: Your personal data may be stored or transferred to countries outside the European Economic Area (EEA) for the purposes described in this Privacy Policy and pursuant to providing the services to you. When we store or transfer your personal data outside the EEA, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing the appropriate safeguards listed below. Transfers of personal data will only be made:
By using our services, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.
10.1: 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.
10.2: We store your data on our secure cloud server, which is hosted by Microsoft and backed up by specialist backup software.
10.3: 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.
11.1: We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
11.2: 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, regulatory, tax, accounting or other requirements.
11.3: We must keep basic information (including Contact, Identity, Financial and Transaction Data) for six years for tax purposes after you cease being a registered Worker.
11.4: On an annual basis, the DPO is responsible for ensuring that we comply with the above provisions in destroying personal data, which is carried out as follows:
12.1: Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows (please check the Glossary for further information on each right):
If you wish to exercise any of the rights set out above, please contact us.
12.2: Fees. 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 could refuse to comply with your request in these circumstances.
12.3: Specific Information. 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.
12.4: Response time. We try to respond to all legitimate requests within one month. Occasionally, it could 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.
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 or 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
In addition to any third parties specifically mentioned throughout this document, External Third Parties can be summarised as follows:
YOUR LEGAL RIGHTS
You have the right to:
