Spica Luna Privacy Policy

This privacy notice informs you about how we process your personal data when you use the Spica Luna mobile application or desktop web application (“App”).

This privacy notice supplements any privacy notices already published by the company you work for and in the event that there are conflicting policies between the two, your employer’s privacy notice will replace the ones contained within this notice.

With this privacy notice, we would like to inform you about the following topics:

• Who is responsible for processing your personal data
• How is your personal data collected
• What types of personal data we process
• Why and on what legal basis do we process personal data
• Profiling and automated decision-making
• With whom we share your personal data
• How we protect your personal data
• How long we store your personal data for
• What data protection rights you have
• Changes to this privacy notice

Reference to “Service” or “Services” means the services as defined in the Terms of Use and provided in the context of the App. When you use the App, we process your personal data so that you may view information about your office, use the indoor navigation feature to wayfind to points of interest within the building (where available), interact with the services available within your workplace, book a resource, use any of the team collaboration features available within the app, subscribe to variety of location based notifications, plan future visits to the office, raise requests with the local facilities team and many more features available now or coming soon.

It is up to you to decide whether you would like to make use of the Services or App. To use the App, we require certain personal data. If you choose not to provide the personal data that is required to use the App, we will not be able to provide the Services and you will not be able to use the App. The provision of certain personal data may be optional. You will be able to use our App and Services even if you do not provide such optional data to us.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

Spica Technologies Ltd (“Spica”, “we”, “our” or “us”), are a company registered in England and Wales whose registered office is at 2.07 iCentrum Innovation Birmingham Campus, Holt Street, Birmingham, England B7 4BP with company number 09276549.

Where Spica’s own employees use our products, Spica is the Data Controller for personal data processed in the app. However, for all customer uses, the user’s employer is the data controller and Spica acts in the capacity of Data Processor.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager at privacy@63.35.179.135.

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.

HOW IS YOUR PERSONAL DATA DEFINED AND COLLECTED?

Personal data means any information relating to an identified or identifiable natural person.

We may collect your personal data either directly from you, from third-party sources including the organisation you work for and from publicly available information sources as follows:

• Information you give us: You may provide information about yourself in connection with your use of the Services and the App, for example by signing in, entering information directly into the app, using different features of the App or by corresponding with us by email or otherwise contacting us.
• Information we collect through this App: Some data is automatically collected through the app when the App is active. This information may also include your precise location when the App is either open, minimised in the background or when fully closed but only if you have provided separate consent for the App to collect this information.
• Information either Spica or your employer already has about you: Spica or your employer may already have information about you that is necessary for you to use the App, such as your login credentials, work contact details, preferences etc.

As the accuracy of your personal data depends largely on the information you provide to us, kindly inform us or your employer as soon as practicable if there are any errors in your personal data or if there have been changes to your personal data.

PROFILING AND AUTOMATED INDIVIDUAL DECISION-MAKING

We do not use automated decision-making, nor do we engage in profiling activities when you use the App.

WITH WHOM DO WE SHARE PERSONAL DATA?

Spica Technologies Ltd makes an unwavering commitment to keep your data safe, never sell your personal data, not share your personal data without being transparent about it and to put your data to work so we can better protect you, and so you can get the most out of our products and services.

Against this background, we may share your data with the following third parties to the extent required to provide the Services and the App and to fulfil the other purposes described in this privacy notice:

• Third-party service providers. We share your personal data with authorised third parties: (i) to process or manage your personal data so that we may provide the Services (including but not limited to third parties providing the information technology necessary, such as third party hosting providers, CRM providers and other professional cloud services which allow us to provide our Services and (ii) to carry out market and customer research (including but not limited to third parties providing advertising networks, analytics tools or search information tools and software).
• 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 privacy notice.
• Lawful requests. We may disclose your personal data if we are under a duty to disclose or share such data in order to comply with any legal or regulatory obligation or request.
• Protection of our interests and protection against fraud. We may disclose your data (i) if this is reasonably required to enforce terms of use or any other agreement we have entered into with you or to investigate potential breaches; or (ii) if this is required to protect the rights, property or safety of Spica, our customers, or others (including by exchanging information with other companies and organisations for the purposes of fraud protection) and (iii) in accordance with applicable laws, to defend our interests or to prevent and combat fraud.
• GPS/IPS location data that the App collects whilst you are using it or in the background is never shared with a third-party. This information is only ever held for short periods of time to provide users with location-based features.

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.

Some of our Third Parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK ICO. All member countries of the European Economic Area (EEA) have been deemed by the UK ICO to meet this requirement.
• Where we use certain service providers outside of the UK and the EEA, we may use specific contracts approved by the UK ICO which give personal data the same protection it has in the UK and Europe. 

Please contact us at privacy@63.35.179.135 if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

HOW DO WE PROTECT YOUR PERSONAL DATA?

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.

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.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

By law we have to keep basic information about our customers for six years after they cease being customers. In some circumstances you can ask us to delete your data.

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.

WHAT DATA PROTECTION RIGHTS DO YOU HAVE?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You 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@63.35.179.135.

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 may 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 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 will notify you and keep you updated.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update and change this privacy notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our privacy notice in the future will be brought to your attention by appropriate means, e.g. in the App or on our website.

GLOSSARY

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 privacy@63.35.179.135.

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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.