GDPR means General Data Protection Regulation (EU) No. 2016/679;
What data are collected?
- 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.
What we do with the User Data and Optional Data
- 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).
Who is controller and processor and third party sub-processor?
- 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.
What are the security measures in place?
- 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.
- 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.
- The Spaceflow guarantees that information in the App may not be accessed, disclosed, altered, or destroyed without authorized access.
- 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.
- 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.
- 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?
- 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.
- 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.
- 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
How you can reach us
- You can reach the Spaceflow under following contacts:
You can also reach the SF Manager in the App help desk for particular building profile.