Introduction

Welcome to Spacehive. We are a platform that enables crowdfunding for civic spaces. This policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection and GDPR law, Spacehive Limited is the controller of that information and responsible for its use and protection. As we operate a platform that allows our users to run fundraising projects and reach out to others for funding, those users may also be separately legally responsible for the use of your information in connection with those projects.

Spacehive Limited (“we”, “our” or ”us”) is committed to protecting and respecting your privacy.

This Privacy Policy explains why and how we will use the personal information that we have obtained from you or others, with whom we share it and the rights you have in connection with the information we use.

This policy describes the way we handle and use the personal information that we obtain from all the different interactions you may have with us as a business, including when you visit our offices, social media pages or website currently located at www.spacehive.com (the “Site”) or when you contact us or take part in any of our competitions or promotions.

We, Spacehive Limited, are the Controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed. Please see the section at the end of this policy for our contact and legal information.

Our users run fundraising campaigns from our Site and in doing so may collect personal information from you if you pledge funds to their projects. Their use of that information during and after their campaign (e.g. to keep in contact with you about progress of their project and their achievements) are uses of your information for which those users determine, independently of us. As a result, those users will be separate controllers of your personal information.

We refer to ‘project owners’, ‘backers’, ‘movements’, ‘funds’ and ‘pledges’ throughout this document. For more information regarding these, please see our Terms on the website. When we refer to ‘you’ we mean a user of our service.

This policy was last updated on the date that appears at the top of this page.

How and when we collect personal information about you

We receive personal information about you that you give to us, that we collect from your use of our Site and social media pages and that we obtain from other sources. We only collect personal information which we need and that is relevant for the purposes for which we intend to use it.

1. Personal information that you give to us

   This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.

   When you sign up for a Spacehive Project creator account, you may provide us with:

   • Your personal details, including name, date of birth, postal and billing address, email address, phone number
   • Your account log in details, such as the user name and the password you have chosen
   • Biographical data, including your skills and experiences relating to your project

   We may also ask you for information and copies of identity documents when you wish to apply for partner funding, when you report a problem with our Site or when you exercise your legal rights. If we do not receive this information, you may be unable to register with the Site, list or raise funds, pledge funds to projects, communicate with other users or communicate with us effectively or allow us to comply with our own obligations.

   When you back a project by donating money to it: you may provide us with:

   • Your personal details, including name, date of birth, postal and billing address, email address, phone number
   • Your account log in details, such as the user name and the password you have chosen

   When you interact with our Facebook, Twitter & LinkedIn pages you may provide us with:

   • Your social media profile details, which you have made public
   • Your social media activity, including likes, shares and comments

   When you interact with our customer care team, via email, our website enquiry form, live chat or our social media pages, you may provide us with:

   • Your personal details including name, email, phone number and other details which you share with us
   • Details of your enquiry

   When you contact us or we contact you or you take part in promotions, competitions, surveys or reviews about our Services, we may collect:

   • Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media
   • Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
   • Your feedback and contributions to customer surveys or reviews

   When you attend a Spacehive-organised event, you may provide us with:

   • Your personal details including name, email, phone number and other details which you share with us

   This information is provided by you entirely voluntarily.

   When you visit our website, we may collect:

   • Details of your visits to our site, including, but not limited to traffic data, location data, weblogs and other communication data, and the resources you access;
   • 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 our Cookies for further information; and
   • Details regarding when and how you consented to receive marketing communications from us (including the time and date you provided your consent).

   We may also process any personal information which you allow to be shared, including the information you upload to the Site (such as your Spacehive profile), and information you share on third party social networks.

   When you visit our social media pages we collect:

   • the information you post on those pages;
   • information regarding your interactions with the content we post; and
   • statistical information regarding all our followers’ activities (but from which we cannot identify you as we only have access to this information in aggregated form).

   Remember that when you share information publicly, it can be indexable by search engines. While we provide you with different options on sharing and deleting your data, we cannot delete content from search engines so you need to be careful about information you make public.

2. Personal information we may receive from other sources:

   We may obtain certain personal information about you from other sources (including those outside of our business) which may include our suppliers and our clients. The third parties that may send us personal information about you are as follows:

   Source of personal information	The circumstances in which we may obtain personal information about you from this source
   Other users	users of the Site may share personal information about you with us, for example if you misuse the Site or breach our Terms of Use.
   Our funding partners	We may receive your personal information from our funding partners if you have indicated to them that you would like us to contact you about funding opportunities. We may also receive personal information if you provide it as part of the process of pitching to a Fund for a pledge.
   Social media networks (publicly available source)	We may process your social media profile registration data where you choose to register with our Site using your existing social media profile and log-in details
   Our Verification partner	Locality, our verification partner, may share personal information which you have provided to them, as part of the process of verifying projects. This personal information may include your email, phone number, or address or other items of personal information.

   Please note we do not knowingly collect personal data that is ‘sensitive data’ from a legal perspective or that relates to criminal convictions or offences. Please do not provide this information to us whether directly or by posting it to the Site. If we receive this type of information, we will promptly delete it.

Use of your personal information

We use your personal information for a variety of reasons. We rely on different legal grounds to process your personal information, depending on the purposes of our use and the risks to your privacy. You will only receive unsolicited marketing communications from us if you have consented and can opt-out of receiving them at any time. We do not share your personal information with companies that would send their marketing to you.

We use your personal information in the following ways:

1. Where you have provided CONSENT

   We may use and process your personal information for the following purposes where you have consented for us to do so:

   • to contact you via email with marketing information about our projects, funding opportunities and business

   You may withdraw your consent for us to use your information in any of these ways at any time. Please see your rights in relation to your personal information for more.

2. Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of our CONTRACT

   We will use your personal information where this is necessary for us to perform our contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract, for the following purposes:

   • to register and set you up as a member on our Site;
   • to publish details of your pledges (unless you choose to pledge anonymously), your projects;
   • to process your pledges and share your details with our payment processors so that payments can be made from you (note we use third party payment providers to process payments);
   • to share your personal information with our funding partners to obtain funding for your projects;

3. Where necessary for us to pursue a LEGITIMATE INTEREST

   We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

   Processing necessary for us to promote our business, brand and activities and measure the reach and effectiveness of our work

   • for analysis and insight to enhance your visitor experience;
   • to tailor and personalise our marketing communications;
   • to supply your details to social media and other online platforms operated by other companies for them to contact you with our targeted advertising online, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
   • to identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information).

   Processing necessary for us to support our users with their enquiries

   • to respond to correspondence you send to us and fulfil the requests you make to us.

   Processing necessary for us to respond to changing market conditions and the needs of our guests and visitors

   • to analyse, evaluate and improve our Site and other services so that your visit and use of our Site, fundraising support and other services and social media pages, are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
   • to undertake market analysis and research (including contacting you with surveys) so that we can better understand you as a guest;
   • for the purposes of developing new initiatives and features on our Site (for example new types of fundraising options or support.
   • for the purposes of understanding the impact that Projects, Movements, Funds and Partners create.

   Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

   • to administer our Site and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
   • for the prevention of fraud and other criminal activities;
   • to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or visitor;
   • for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access, including to archive, destroy, pseudonymise or anonymise your personal information;
   • 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);
   • for the purposes of corporate restructure or reorganisation or sale of our business or assets;
   • for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
   • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
   • to inform you of updates to our terms and conditions and policies; and
   • for other general administration including managing your queries, complaints, or claims, and to send service messages to you.

   Marketing communications: If you give your consent, we may use your personal information to contact you by email to send you newsletters or to notify you with details of projects, services and competitions. We try to adapt any marketing material that we send to you, for example by notifying you of projects or Funds that apply to your interests and in your location. If you do not wish to receive email communications from us, please inform us by using the unsubscribe link inside the email messages we send, or, if you have a registered account on our Site, by changing your Notifications settings from within your account.

   We provide tools that allow project owners to send backers news and updates on their projects. However, we do not permit project owners to send any other type of marketing communications using these tools. Project owners can access contact details for the backers relating to their projects. Any communications they send using these details will be sent solely based on their decisions and for which they will be acting as the controller of your personal information.

   If you opt-out of receiving marketing communications from us, we hold email address for a defined period to ensure that we comply with your wish.

Disclosure and sharing of your personal information by us

We only disclose and share your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any contractors or recipients that work for us will be obliged to follow our instructions. We do not sell your personal information to third parties.

We may disclose your information to the following:

• our funding partners with whom we work to make further sources of funding and support available to project owners. Our partners include corporates, foundations and also organisations in the public sector such as local councils. We promote initiatives and funding opportunities with some of our partners from time to time. When we do so we and the relevant partner may make joint decisions regarding how we use your personal information in connection with those opportunities;
• project owners for them to contact you in connection with their project and backers to allow them to identify the project owners responsible for the projects to which they pledge, in each case in accordance with our Terms;
• our third party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf, including the operation and maintenance of our Site and social media pages. Our Suppliers can be categorised as follows:

The Suppliers above are located in the European Economic Area or the USA.

When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure.

We may disclose the personal information to other third parties as follows:

• any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
• if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals or regulators.

Transfers of your personal information outside of Europe

Except in a limited number of cases, we do not transfer your personal information outside of Europe. Where we do, we take measures to protect your personal information.

All the personal information collected about you by us or on our behalf may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if our servers or the servers of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK and so they may not protect the use of your personal information to the same extent.

The non-EEA countries to which we transfer your personal information are listed in the table in Disclosure.

If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipients of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. For example, those of our third party service providers who receive your personal information in the USA may subscribe to the “EU-US Privacy Shield” framework. Where they do not, we ensure that we impose contractual obligations on them that are broadly equivalent as required by UK data protection law. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Security and links to other websites

We take the security of your personal information seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to our Site may not be completely secure, so please exercise caution. When accessing links to other websites, their privacy policies, not ours, will apply to your personal information.

We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain parts of the Site, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.

Our Site and social media pages may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites‚ so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

In addition, if you linked to our Site 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.

The periods of time for which we retain your personal information

We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information for a very short period whilst for others we retain it for a period of 7 years after the information is no longer required for business reasons so that we can deal with any legal proceedings that could arise.

We retain your personal information for the following periods:

The only exceptions to the periods mentioned above are where:

• 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 (see further Your rights in relation to your personal information);
• you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your rights in relation to your personal information);
• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
• we archive the information, in which case we will delete it in accordance with our deletion cycle; or
• in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

Your rights in relation to your personal information

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to verify your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received full details of your request.You have the following rights, some of which may only apply in certain circumstances:

1. To be informed about the processing of your personal information (this is what this policy sets out to do);

2. To have your personal information corrected if it is inaccurate and to have incomplete personal information completed;

   The accuracy of your information is important to us and we make it easy for you to review and correct the personal information that we hold about you in your Profile. 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, you can let us know by contacting us in any of the details described at the end of this policy but we ask you to first check that you cannot correct your details using the tools in your Profile.

   When downloading a list of backers on their project, project owners will see the address details of those users who pledged on their project. Please note that if you change your address after the project owner has downloaded this data (this usually happens once their project is successful) the details the project owner may become out of date, until the project owner downloads a new list of data - so we would recommend also contacting the project owner to inform them of a change to your contact details.

3. To object to processing of your personal information;

   Where we rely on our legitimate interests as the legal basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information 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 dataro.

   You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

4. To withdraw your consent to processing your personal information;

   Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool.

   You can also opt out of receiving our newsletter at any time by editing your Profile settings (login, click your name at the top right of the website then choose Profile settings).

   You can choose to receive or opt-out of future updates from Projects you have pledged on.

   The project owner will be responsible for handling your information after they receive it from us. The project owner, when downloading a list of backers on their project will see who has elected to receive further updates.

   Please note that our standard receipt emails and notifications in relation to project funding campaigns you may back contain important financial information regarding your pledge and so cannot be turned off.

   If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

5. To restrict processing of your personal information;

   You may ask us to restrict the processing your personal information in the following situations: 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 information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

6. To have your personal information erased;

   In certain circumstances, you may ask for your personal information 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 information for longer, we will make reasonable efforts to comply with your request.

7. To request access to your personal information and information about how we process it;

   You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. This is called a subject access request. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

   Remember, you can access a lot of your personal information through your account: You can see a record of the pledges you have made in the Backed Projects section (login, click your name at the top right of the website then My Account, and then Backed Projects).

   • You can also see a record of the projects you have created and run - see the Your Projects section.
   • You can also review and edit the personal information you have provided to Spacehive via your Profile settings.

   If you wish to make a subject access request please first check you cannot get the data from the areas listed above. If you wish to access data not listed there please be specific in your request and send us a message to info@Spacehive.com. We will then, in adherence with the ICO guidelines, respond to your request.

8. To electronically move, copy or transfer your personal information in a standard, machine-readable form;

   Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with a contract in place directly with you, 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.

   We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

9. Rights relating to automated decision making, including profiling

   We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.

   After creating a project on Spacehive we will match you to partner funds that you may be eligible for. You can view the full list of funds at any time. Part of your eligibility for a fund may include automated processes, but the decision to approve funding will not be purely automated.

Children

As per our terms and conditions, people under 16 are not permitted to use Spacehive on their own. Spacehive does not knowingly collect any personal information from children under the age of 16 and children under 16 are not permitted to register for an account or use our Services. If you believe that a child has provided us with personal information, please contact us at info@spacehive.com. If we become aware that a child under the age of 16 has provided us with personally identifiable information, or someone else has provided us with personal information about a child under 16, we’ll delete it.

Complaints

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website, where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.