Privacy and Cookies policy

Last updated on March 2023.

INSTANT GROUP - PRIVACY AND COOKIES POLICY (GLOBAL)

1. GENERAL

Purpose

Welcome to our privacy and cookies policy for services provided through our websites www.instantoffices.com, www.easyoffices.com, www.coworkintel.com, incendiumconsulting.com, coworker.com, capstanadvisors.com, coworkinginsights.com and our group website www.theinstantgroup.com . We are committed to protecting and respecting your privacy in the delivery of our flexible office brokerage services (“Services”). We have developed this policy because we want you to feel confident about the privacy and security of your personal information in connection with our Services and also to outline some of your rights.

This Policy (together with our Terms of Use and any other documents referred to on it) will:

• inform you as to how we look after your personal data collected from your use of our website whether by (i) submission of your enquiry for office space, (ii) signing up to our newsletter or market data, (iii) subscribing to our Service, (iv) taking part in a competition or (v) that you otherwise provide to us during our communications will be processed by us.
• tell you about your privacy rights and
• explain how the law protects you.

By providing your personal data to us (whether via one of our websites, by email, or otherwise), you will be acknowledging that you have read this notice.

It is important that you read this policy together with any other privacy notice or fair processing notice 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 policy supplements the other notices and is not intended to override them.

This website is not intended for children and we do not knowingly collect data relating to children. If you are concerned that your child may have provided information through our website please contact us at privacy@theinstantgroup.com

Data Controller

Depending upon which website you are using, the data controller which is registered with the Information Commissioner's Office (the "ICO") and responsible for your personal data, will vary as set out in the table below

Third-Party Links

Our websites 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the policy of every website you visit.

2. DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about a living individual from which that person can be identified, either on its own or when it's combined with other information held by us. It does not include data whereby the personal data has been stripped of sufficient elements that means the individual can no longer be identified (anonymous data).

In order to provide our Services to you we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 policy. Please see section 8 for further information.

We do not ask you to provide to us any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Neither do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

From you. You may give us your Identity, Contact, Financial, Transaction, Profile, and Communication Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• submit an enquiry for office space;
• create an account on our website;
• subscribe to our service or publications;
• subscribe to our market data reports;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• make a complaint;
• report a problem with the website;
• give us some feedback or otherwise contact us;
• submit a job application, such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment to us; and
• complete any anti-money laundering (KYC) checks.

Automated technologies or interactions. As you interact with our website, we may, where we are permitted to do so by applicable law, collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to section 8 below for further detail.

From third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing, (from us or from third parties) via email or text message, provided we have your consent to do so. You have the right to withdraw consent at any time by using the unsubscribe feature on email communications. or in some cases, via your online account by changing your contact preferences. Such communications may also be provided by third parties acting on our behalf - these communications will be clear that they are communications from us.

For further information please see sections 4 and 7 below.

4. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We will only process your personal data where we are permitted to do so by applicable law.

We have set out in the table below, a description of all the ways we plan to use your personal data, and which of the bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. If you need details about the specific ground we are relying on to process your personal data where more than one ground has been set out in the table below, please contact us at privacy@theinstantgroup.com.

We will only use your personal data where we are permitted to do so by applicable law 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@theinstantgroup.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the lawful basis set out in the table above, where this is required or permitted by law.

5. DISCLOSURE OF YOUR INFORMATION

We may have to share your personal data with the following external third parties set out below for the purposes set out in the table in section 4 above:

• Our affiliated companies, including for each affiliates' marketing purposes if you have consented to such use. Users who visit the affiliates' separate website should still refer to their separate privacy policies, which may differ in some respects from this privacy notice
• Serviced office operators
• Real estate agents
• Third party brokers
• Service providers - such as website hosting, professional services, including information technology services and related infrastructure, customer service, e-mail delivery, auditing and other similar services
• Professional advisers
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy
• To abide by applicable law or protect rights and interests of others or yourself. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others' rights, property, or interests, or prevent fraud or abuse

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.

6. INTERNATIONAL TRANSFERS

The Instant Group is headquartered in the United Kingdom (UK). We may share your personal data within The Instant Group. This may involve transferring your data outside the UK (or the country the information was collected in) to a country which have in place data protection laws which may be of a lower standard than in the country it was collected in.

It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your order and any international requests that you make for serviced office solutions, the processing of your payment details and the provision of support services. By submitting your personal data, you acknowledge this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Many of our external third parties are based outside the UK and the European Economic Area (EEA), so their processing of your personal data may involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we will ensure a similar degree of protection is afforded to it by the transferee, such as through appropriate safeguards. Please contact us at privacy@theinstantgroup.com if you would like to see a copy of the specific safeguards applied to the export of your information.

7. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We will get your express opt-in consent before we provide you with direct marketing. We will also ask for your express opt-in consent before we share your personal data with any other company, including those within the Instant group of companies for marketing purposes.

You can ask us to stop sending you marketing messages at any time by using the unsubscribe feature on our email communications to update your contact preferences. If you wish to opt-out from receiving marketing materials from any of our third party partners, please contact the relevant business directly.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions, where we have a separate legal basis to use that personal data.

8. COOKIES

A cookie is a small piece of data (text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preferences or login information as an example. Those cookies are set by us and called first party cookies. We also use third party cookies, these cookies are from a domain different than the domain of the website you are visiting, used to understand usage, improving site features or personalised advertising as an example. You can find out more information about cookies here: www.allaboutcookies.org

More specifically, we use cookies and other tracking technologies for the following purposes:

• Assisting you in navigation and ensuring your requirements go to the correct team globally
• Assisting you in finding and selecting products or services of interest
• Analysing your use of our products, services or applications
• Assisting with our promotional and marketing efforts

We use the following types of cookies on our websites:

• Strictly Necessary Cookies - These are essential in order to enable you to use the key features of the website. Without these cookies we will not be able to connect you to the offices, properties, products or services you are looking for. These cookies cannot be switched off.

The remainder of the cookies below are optional, and we require your consent before placing them. The following are not strictly necessary for the operation of this website, but are needed to provide you with the best user experience.

• Performance Cookies - These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our websites. They help us know which pages are the most and least popular and see how visitors use our product for future improvements.. If you do not allow these cookies, we will not know when you have visited our site, also reducing the information available to improve our website in the future.
• Functional Cookies - These allow us to remember choices you have made, such as previous searches to provide you a more enhanced, efficient and personal service. The information these cookies collect relates to our website only.
• Targeting Cookies - These third-party cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and device. If you do not allow these cookies, you will not experience targeted advertising across the websites.
• Third Party A/B testing Cookies - Some of our pages use a third-party software provider, Optimizely, to test variations in functionality and content. This helps us constantly improve our website and deliver the best service and product to our visitors. This technology help us to continually improve the service and experience we provide you.

We have set out below a detailed list of the cookies we use on our websites. Our websites are checked regularly to ensure this list is as accurate as possible. We classify cookies in the following categories:

You can opt-out of each cookie category (except strictly necessary cookies) by clicking/selecting “cookie preferences” on the site. If you have any queries or require more information on this please email privacy@theinstantgroup.com

STRICTLY NECESSARY COOKIES

FUNCTIONAL COOKIES

TARGETING COOKIES

9. DATA SECURITY

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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone in order to avoid illegitimate intrusion into your privacy or your business transactions.

All the information you provide will be held in the strictest confidence and only used for the purposes described in this Policy. Due to the nature of the internet, the transmission of information online is not completely secure.

Although we will do our best to protect your personal data in accordance with industry practice, we cannot guarantee the security of your data transmitted to our website. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access to, or loss, misuse, disclosure or modification of the personal information that you provide to us.

10. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, for the purposes of satisfying any legal, accounting, or reporting requirements where by law or good industry practice we have to keep certain information (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

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 requirements. If your personal data is used for two purposes we will retain it until the purpose with the latest period expires.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. YOUR LEGAL RIGHTS

In accordance with applicable law you may have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  (a) if you want us to establish the data's accuracy;
  (b) where our use of the data is unlawful but you do not want us to erase it;
  (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@theinstantgroup.com

No Fee Usually Required

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 manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

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.

Time Limit To Respond

Subject to the provision of the requisite information, we will try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we can have up to three calendar months to respond, and if this is the case we will explain this to you within the first month.

Please be aware that your exercise of some of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and some of these rights may be limited where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

12. CHANGES TO OUR POLICY

Any changes we may make to this Policy in the future, for example in relation to updates to our processes and purposes, will be posted on our website. Such changes will become effective upon your use of our website after such changes have been posted. If the changes are material, we may provide you additional notice, to your email address. We encourage you to periodically review this page for the latest information on our privacy practices.

13. CONTACTING US

If you have any questions regarding this Policy or to access or correct your information, please contact us by:

• emailing privacy@theinstantgroup.com
• clicking on the unsubscribe link in any of our email communications or via Your Account; or
• writing to the Data Privacy Manager at the Instant Group, The Blue Fin Building, 11th Floor, 110 Southwark Street, London SE1 0TA.

If you are unhappy with how we have handled your data, or you are not satisfied with our response to any requests you have made to us regarding the use of your personal data, you may have the right to lodge a complaint with the relevant data protection regulator.

To the extent the complaint relates to the conduct of a UK based organisation you can complain to the Information Commissioner’s Office (ICO).

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (please note we can't be responsible for the content of external websites)

Thank you for visiting our website.