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Privacy Policy

GDPR means General Data Protection Regulation (EU) No. 2016/679;

Please, all definitions used in the Terms of Use are also used in these Privacy terms unless is stated something explicitly different.

What data are collected?

  1. In order to provide You and the SF Manager with an essential App functionality under the Terms of Use we, the Spaceflow, collect through the App below stated data:
    • Personal information: You as any user of the App (the SF Manager and the Merchant as well) provide us with your Name/Surname, Your e-mail address for Your Account, the Merchant provides us with telephone number and graphics (if this can identify reasonably a natural person) in order to create and access the Account (“Personal Data”);
    • Device information: You also provide the Spaceflow with other device data such as: the phone brand (e.g. Samsung, iPhone etc.), phone operating system (eg. Android, iOS or different), language of your operating system and the App privacy setting to properly operate the App in your phone and to provide a proper application setup;
    • Location information: So that the Spaceflow is able to join You to a specific Profile though the App, the App requests your device to send geolocation data, this happens solely for the purposes to offer nearby Profiles. Such geolocation is not stored anywhere and is removed from the App once you are offered with the nearby Profiles;
    • Third party data: In order to sign into the App, the Spaceflow enables You to link your Account to the Facebook account (and therefore the App possess Facebook credentials) but the App does not send any data to the Facebook, therefore You cannot publish your activity done through the App to such service;
    • Notification data: In the App we save the Notification Token which will notify You about news in the Profile that you have access to, as well as you may have stored your access code to such Profile and your password to your Account;

    (Personal Data and other data specified above jointly the “User Data”), in order to create and access your Account and to connect the Profile.

  2. If you decide to provide optional information in your Account (i.e. personal photo, telephone, bio, employer, if You are the User, or additional description if You are the Merchant; “Optional Data”), it is up to You and you personalize your Account.
  3. If You post any content, including photos and other materials and to share them publicly and related to the building profile You use (in a whole or in a part), then our legitimate interest as the SF Manager is to collect such data in order to reach our stated purpose (“Content”). Content posted within the building profile stays in the building profile communication history till it is outdated.
  4. The App does not allow to do any personalized analysis of your behavior or profiling based on the User Data, the Optional data or the Content.

What we do with the User Data and Optional Data

  1. We, the Spaceflow, use the User Data in the App in order to make the App work under the Terms of Use, i.e. to provide all users of the App their connection with their Account and to join Profiles, and to connect the Users, the Merchants and the SF Managers in social environment of the Profiles and in effect to provide the SF Managers technical means to fulfill their purposes under 1.6 below.
  2. In addition to the purpose described above, we the Spaceflow, may use the User data which cannot be linked reasonably to any individual (are not personal data under the GDPR) and the Content on the basis of our legitimate interest in further development of the App, more specifically:
    • to improve, test, and monitor the effectiveness of the App with respect to the current functionalities in the Profiles (e.g. workload of hardware if certain amount traffic is reached, modify user experience in order to provide more comfort and intuitive use of the App, change of the Apps configuration if any);
    • to develop and test new features (including their improvement, e.g. future internal market, different method of sharing economy implemented within the building profile, incentivize a cooperation of building users,) of the App;
    • to monitor metrics such as total number of visitors, traffic (e.g. how much users sign into the App during day, what are the main activities they do in the app, the workload of the App during the day);
    • to diagnose or fix problems with the use of the App (e.g. if the App does not work properly with a specific device operating system, if it crashes due to incompliance with other technical parameters of the device);
    • to automatically update the App on your device (if the Spaceflow comes with any new functionality of feature we do so through the App update).
  3. Personal Data of the Users in the particular Profile are viewed by the SF Manager through the web admin environment of the App. We, the SF Manager are entitled to observe and manage the Profile environment to the extend You see and through web admin page we, the SF Manager, are entitled to see your Personal Data we use the web admin webpage to: to regulate access control and management of users of the Profile for a particular building and to react to various request/demands and feelings from You, to communicate with You directly through various communication activities (questionnaires, posts and notifications regarding functionalities, facilities and etc.) in the building to provide You an extraordinary experience in the buildings operated by us, the SF Manager, and to provide social place for You to meet and to make the building life more vibrant.
  4. If your Account is in private regime, the Optional Data and your Account is not seen within a particular Profile by anyone except the SF Manager and the Spaceflow through the web admin page to the extent of your Personal Data and if You post anything, your post is visible to anyone in the particular Profile. The Merchant cannot see in web admin page anything about You except its published information (e.g. advertisements). If your Account is in public regime, your Account can be viewed also by other users connected to the same Profile and in such Profile to the extent of your Personal Data and Optional Data and the Content you published.
  5. If we, the SF Manager or the Spaceflow, use the App, it works the same as for You, except from we can additionally make an announcement in the particular Profile.

Who is controller and processor and third party sub-processor?

  1. We, the Spaceflow, are a controller of the User Data with respect to provide functionalities of the App under 1.5. and 1.6. above and we use the User Data to fulfill our obligations under the Terms of Use, we use the Content and the User Data in legitimate interest for purpose stated in 1.6.
  2. If You provide (as the Merchant or any Building user) the Personal Data/Optional Data of another natural person (e.g. sub-contractor or employee), You are considered to be a controller with full liability and the Spaceflow is a processor.
  3. We, the SF Manager, are a controller of Personal Data, Optional Data and Content accessed to us within particular Profile and which we need in order to fulfill our stated purposes in 1.7 with the App as a chosen tool. We use such data on basis of our legitimate interest to provide better services in the building to which the building profile in the App is connected, to create closer connection between us, the operator of the real-estate project, and You (the User/Merchant) to provide unique and vivid experience when your work or use the particular building any other way and make the particular building attractive for our current and prospective tenants. In this regard the Spaceflow is a processor of such data in compliance with this Privacy Terms and Terms of Use.

What are the security measures in place?

  1. The App and the web admin environment uses in communication with all users of the App a Transport Layer Security (TLS) encryption technology to encrypt personal information (including geolocation) and maintains by-design security.
  2. If You make a reservation within particular Profile in the App for a certain service, You will decide whether the App will have access to your calendar application in order to record such reservation.
  3. The Spaceflow guarantees that information in the App may not be accessed, disclosed, altered, or destroyed without authorized access.
  4. Data logs from the App are saved for the purposes of security events and are after 7 days erased from the App. The Personal Data and the Optional Data are stored in the Account till the moment the Account is deactivated or information in Profile is outdated. If there is a serious suspicion that the particular user breached the Terms of use or committed a fraud and other illegal activity, such log can be accessed, processed and retained for an extended time period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of the Terms of Use, or otherwise to prevent harm.
  5. The Spaceflow, the SF Manager and the Merchant can access the App through Web admin environment. We do not use any plugins of the third parties in our web admin environment and the App webpage.
  6. The Spaceflow uses its own analytics tools to monitor metrics and usage trends in the App and such tools collect information sent by your device but are anonymized. The Spaceflow works within the App only with anonymized logs of such statistics and then provide results to the SF Manager in the web admin environment.
  7. If Information is de-identified (e.g. used anonymized statistics) so it is no longer reasonably associated with an identified or identifiable natural person, the Spaceflow and the SF Manager may use it for any business purpose.

What are your rights and your obligations?

  1. In principle, You (the User) have the right to information about what data the Spaceflow and the SF Manager collect and use, right to correction of stored data, to deletion of data, restriction of them, data portability, revocation and opposition. If You believe that the processing of your data violates data protection law (in EU it is the GDPR) or if your data protection claims have otherwise been violated in a way, you can complain to the supervisory authority. In Czech Republic it is Office for the Data Protection.
  2. You shall be responsible for maintaining the secrecy of your unique password to your Account, and for controlling access to emails between You and the App/the SF Manager, at all times.
  3. We, the SF Manager and the Spaceflow may access, preserve and share User Data in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires it to do so. This may include responding to legal requests from jurisdictions outside of the European Union/United States where the SF Manager / Spaceflow has a good faith belief that the response is required by law in such jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

Changes of Privacy Terms

  1. The Spaceflow (not the SF Manager) may modify or update these privacy policy provisions regarding of the Terms of Use regarding its activities from time to time. The Spaceflow may provide You through the App with additional forms of notice of modifications or updates as appropriate under the circumstances. You will have an option to further use of the App after any modification to these Privacy terms under condition you will agree with such change.

How you can reach us

  1. You can reach the Spaceflow under following contacts:
  2. You can also reach the SF Manager in the App help desk for particular building profile.