FreeSpade Lifestyle Privacy Notice
Summary
Welcome to FreeSpade Lifestyle.
We are committed to respecting and protecting your privacy. This privacy notice sets out how we collect and use the personal data that you provide to us via our mobile app, FreeSpade Lifestyle (our "App", and any other services we provide to you, our "Services"). It also tells you about your privacy rights and how the law safeguards your personal data.
If you have any queries about this notice or how we use your personal information, please contact us at privacy@concierge.freespadelifestyle.com.
Contents
1. About us
Our Services are operated by Free Spade Group Collaboration Hub, INC ("FreeSpade Lifestyle", "us", "we", or "our").
Free Spade Group Collaboration Hub, INC, with its registered office at 1235 East Boulevard Suite E, #220, Charlotte, North Carolina 28203. FreeSpade Lifestyle is the data controller of any data you provide to us via our Services.
You can contact us about any queries you have regarding this privacy notice at either our postal address above, or at privacy@concierge.freespadelifestyle.com
We have appointed a data privacy manager 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 data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: Free Spade Group Collaboration Hub, INC
Email address: privacy@concierge.freespadelifestyle.com
Postal address: 1235 East Boulevard Suite E, #220, Charlotte, North Carolina 28203
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to respond to your concerns before you approach the ICO so please contact us in the first instance.
2. What personal data do we collect via the Services?
'Personal data' means any data which can be associated with you as an individual, either directly or indirectly. We collect different information depending on how you use the Services and how you interact with us.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity information, such as your name, organisation name and position, and your driving licence and passport information (please see section 4a below for information on how and why we collect this information).
We do not ask you for 'special categories' of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or health information. However, if you choose to provide us with this information, and provide us with your explicit consent, we may retain it for as long as is necessary. We do not collect data about actual or alleged criminal offences.
3. How we collect personal data
Different personal data is collected in different ways.
When you create an account to use our Services, you will provide us with your identity, contact, and log-in information, and your marketing and communications preferences.
When you enter your payment card details via our Services, they are provided direct to our payment processors, Stripe and/or Checkout. We do not collect or store payment card details. You will also provide us with personal data when you correspond with us.
As you use the Services, we will collect your technical, usage and transaction data as described above.
Some of this data is collected using cookies, beacons and similar technologies. Cookies are files with small amount of data which are sent to your browser (or device) from our Services and stored on your device.
We use the following cookies:
|
Cookie name |
What it is used for |
|---|---|
|
skipReferrerState, preapproved, allowedState, applied |
This is used on the Site to identify what part of the application a user is on and to persist across page refreshes and browser openings. This prevents multiple applications on the same device. |
|
Localization |
This is used on the Site to temporarily store the estimated latitude and longitude of the user’s IP address in order to indicate the user's default city. This cookie is stored in session storage, and deleted when the browser tab is closed. |
|
user token |
This authenticates requests with our server, which includes refresh and access tokens. |
|
session |
This is used on Android devices to display a member's name (including their first name, surname, phone, email, and profile picture URL). |
|
authToken |
This is used to authenticate the member with the server. |
|
memberData |
This is used on iOS devices to display and welcome the member by name (includes the member’s first name, surname, phone, email, and profile picture URL). |
|
_ga, __utma, __utmb, __utmc, __utmt, __utmz _gid |
This helps us count how many people visit our Site, and tracks repeat visitors via Google Analytics. This cookie expires after 2 years. |
|
mp_mixpanel |
This cookie stores an anonymous, randomly-generated ID to detect repeat visits to the Site on the same device, and associates actions to the device. This cookie expires after 3 months. |
You can remove cookies from your computer through the settings on your browser, but be aware that this may impact your ability to make use of some features on our and other web sites. Management of cookie settings varies from one browser to another. The "Help" menu of your web browser will provide full instructions.
We also use Google Analytics, a third party service provided by Google, to help us analyse user habits to help increase the functionality of our Services. The information will be used by Google only for the purpose of evaluating the use of our Services. Google Analytics has its own privacy notice, which can be viewed here.
4. How and why we use personal data
We will only use your personal information, in accordance with relevant legal obligations, where:
a) We need the information to fulfil our contract with you
If we have entered into a contract to provide you with our Services, we will need your personal data in order to do so. The personal data that we use will depend on the service(s) we have agreed. For example:
b) It is necessary for our legitimate interest (reasonable business purpose) in doing so
We will use your information for our legitimate business reasons where our doing so will not unduly affect your rights. >Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/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.
These legitimate interests include the requirement to run our business, to keep our records updated, to analyse how customers use our services, to grow our business and develop our marketing strategy.
We will use your identity, log-in, contact and usage information to keep our records up to date.
We will use your technical, location and usage information to:
We may also use any or all of the information above to administer and manage our business in general, to detect and prevent misuse of our Services (including fraud and unauthorised payments), and to enforce our Terms and Conditions or any other contract to which we may be a party. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.
c) You have given us your consent
If you sign up to our mailing lists, we will send you updates and marketing information that you have consented to receive. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by emailing us at privacy@concierge.freespadelifestyle.com
We will only ever store any 'special categories' of data when you have provided us with your explicit consent to allow this.
We will only ever use your exact location data if you have given us your express consent to this. Likewise, we may need your contact, identity, technical and/or usage information to respond to a question you have asked us.
d) We need to comply with a legal or regulatory obligation
In certain circumstances, we may need to retain or use your personal data to comply with regulations and/or the law.
5. Children
Our Services are not intended to be used by any child or young person under the age of 18. Please do not provide us with any personal data relating to children or young persons under the age of 18 unless you are their legal guardian.
6. How we share personal data
We will share your data:
a) With our trusted third party service providers
These include:
We will only disclose your data to third party service providers under terms of confidentiality, and they will only use your personal data for the purposes stated in this notice.
As noted above, we do not share your payment information with our payment processors - instead, you provide it to them direct. We use Stripe and Checkout. For information about how they use your personal data, please see their privacy notices at https://stripe.com/gb/privacy and https://www.checkout.com/legal/privacy-policy. The only exception to this is if we suspect that your account is being misused, in which case we may discuss certain aspects of your transaction history and/or identity details with our payment processors.
We will also share your information with other third parties and suppliers, but only if you ask us to do so (for example, if you ask us to make a booking on your behalf).
b) With other members of our Services
Where we provide the functionality, you may choose to share some of your profile information with other members of the Services. We will never make your profile visible to other members without your express consent.
c) With our US entity
We share personal data between our UK and US entities.
d) If you choose to share it via social media
Where we provide the functionality, you may choose to share some of your information from our Services with your friends, followers or contacts on social media.
Your personal data may be disclosed or transferred to potential or actual buyers of, investors into or lenders to our business or any of our assets, or any of the advisors or representatives of the above. If so, we will ensure that appropriate confidentiality terms are in place.
On rare occasions, we may share personal data when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government inquiry); to enforce or apply our terms of use or other agreements; in the context of a business reorganisation or restructuring exercise; or to protect the rights, property, or safety of our business, our employees, our users, or others.
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 above rules, where this is required or permitted by law.
7. International transfers
Our Services are hosted on servers located worldwide. We also use cloud-hosted software solutions which are located in the US and EU.
Where we transfer personal data outside of the EU to a recipient in a third country in the absence of an adequacy decision by the European Commission, we take care to ensure that our data exports are compliant with data privacy law. We do this by relying on the Model Clauses and/or ensuring that the recipients of the data are certified under the EU-US Privacy Shield scheme. For further information, and/or to obtain copies of the relevant documents, please contact us at privacy@concierge.freespadelifestyle.com
8. Data security
The safety of your personal data is of paramount importance to us, and we use various technical and organisational measures to ensure that your data is secure. We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
9. How long we keep personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
To obtain further information about how long we retain your personal data, please contact us at privacy@concierge.freespadelifestyle.com
10. Third party links
Our Service may contain links to third party sites whose information practices may be different than ours. When you leave our website, we encourage you to read the privacy policy of every website you visit. Please consult all third party sites' privacy notices, as we have no control over information that is submitted to, or collected by, third parties.
11. Your rights
You have the right to:
withdraw your consent to our using your data at any time. 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.
If you wish to exercise any of these rights, please contact us at privacy@concierge.freespadelifestyle.com.
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 reserve the right to refuse to comply with your request in these circumstances.
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.
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.
Changes to this notice or your data
We may amend or modify this privacy notice from time to time. We will post any revised notice on this site and on our app, and if the changes are significant, we will notify you by email.
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.
This privacy notice was last updated on 24 March 2022.