PRIVACY NOTICE

Last updated 3 June 2020

The Collective (Living) Limited and its group companies (collectively “The Collective”, “we”, “us”, and “ours”) is committed to protecting the privacy of our users and customers. This privacy notice (“Privacy Notice”) is intended to inform you how we gather, define, and utilise the personal information  that you give to us when you interact with us in person, via the phone, email or through www.thecollective.com (the “Website”), our mobile application (the “App”) or any other of our services, collectively our “Services”. It is also intended to assist you in making informed decisions when using our Services. All your personal information shall be held and used in accordance with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (the “Act”). If you want to know what information we collect and hold about you, please email us at hello@thecollective.com or write to us at: The Collective Dome Properties Limited whose registered office is at 14 Bedford Square, London, WC1B 3JAhello@thecollective.com.

What information do we collect?

The personal information that we may collect about you broadly falls into the following categories:

• Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. We may ask you to complete voluntary surveys so that we can improve the service we provide.  We may also ask you to write a personal description or provide a photo as part of your member profile. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Our Services may contain interactive functions that allow you to engage with other users of the Services, to upload photographs and other content (the “User Materials”), participate in surveys, and otherwise to interact with the Services and other users. If you use an interactive function as part of our Services that requests or allows you to provide us with information (including, for example, using our chat function to message other members (“Member Chat”) or our member support staff (“Member Support”)), we will collect and process this personal data in accordance with this Privacy Policy.

• Information that we collect automatically

When you use our Services, we may collect certain information automatically from your device.  In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Services, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who use our Services, where they come from, and what content on our Services is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our Services to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies” below.

• Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including our customer referral scheme), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties include for example your name and email address and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.

We maintain the highest standards of security, however the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal information, we cannot ensure the security of your data transmitted to our Website. Any information you submit is sent at your own risk. Once we have received your personal information we will use strict procedures and security features to prevent unauthorised access. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using appropriate technical security measures. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

What are cookies?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website or use an app, that site’s computer asks your computer and/or phone for permission to store this file in a part of your hard drive specifically designated for cookies. Each website and app can send its own cookie to your browser or device if your browser’s preferences allow it, but (to protect your privacy) your browser or device only permits a website or app to access the cookies it has already sent to you, not the cookies sent to you by other sites.

How do we use information we collect from cookies?

We use Cookies and web server logs to collect information about how our Services are used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent using our Services and other similar services used before and after using our Services. As you use our Services, the Services uses cookies to differentiate you from other users to prevent you from seeing unnecessary advertisements or requiring you to log in more than is necessary for security or give us your details more than once. Cookies, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people using our Services and which parts of the Services are most popular. This helps us gather feedback so that we can improve our Services and better serve our customers. For more information please refer to our Cookie Policy.

How do we use the information that you provide to us?

We use and analyse your personal information to keep in touch with you and to supply and improve our products and services. We will also use your personal information to tell you about products and services that we think may interest you.  Sometimes we’ll combine and anonymise this information so you won’t be identified.

In particular, we use your personal information for the following purposes:

• To ensure that content from our Services is presented in the most effective manner for you and your computer.
• Manage your account and help you to manage your account.
• To pass your Information to other companies to supply goods, services or information requested by you and we may pass your Information to them for this purpose.
• To notify you about changes to our service (including any problems with the Services).
• Keep things secure and prevent crime and fraud.
• Manage our Services and your use of our Services.
• Look into any complaints or questions you may raise.
• Recover any money you might owe us.
• To contact you with information about products, services and special offers or ask you to participate in one of our customer satisfaction surveys.
• Check what you’re interested in or eligible for, so we can offer (and develop) relevant products and services, and surveys.
• Where you have provided your consent, tell you about products and services from other companies we think you’d be interested in, or let selected third parties tell you directly about their products and services.
• If we are under a duty to disclose or share your personal data to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or protect the rights, property, or safety of our customers, or others.
• to pursue our legitimate business interests (such as direct marketing, conducting market research and preventing fraud and money laundering to minimise our credit and fraud risks and protect our business).
• We may sometimes use automated systems to analyse your personal information. For example, to make decisions in respect of how we market our product to you. We ensure that any service provider that we use which may make automated decisions about you based on your personal information has implemented measures to safeguard your rights and interests.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided within this notice.

Who does The Collective share my personal information with?

We may disclose your personal information to the following categories of recipients:

• to our partner companies or agencies and their sub-contractors or prospective partners who help us run our services, for example our billing or customer service centres and our initiatives.
• to our third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any other person with your consent to the disclosure.
• If you choose to ‘share’ our content with friends through Facebook, Twitter or other social networks, some of your personal data might be sent to these websites. We don’t control how these social networks use your personal data, so please check those websites’ privacy policies and terms for more information about how they may use your personal data. Social media networks receive data which may include information like the website you’re visiting, the date and time you visit the website, your IP address, browser type, cookie information and other browser-related information. We work together with Facebook, Twitter [insert names of other relevant plugin providers here too] to ensure we correctly control and process your data.

Our service providers

We use a number of service providers to provide our cloud infrastructure environment and storage of our user’s personal information.

We also work with various service providers that monitor, maintain and otherwise support our Services. In order to provide this functionality these service providers may, if the law provides, have access to your personal information.

Your data protection rights

You have a number of legal rights in relation to the information that we hold about you, including:

• The right to access, correct, update or request deletion of your personal information.
• The right to object to processing of your personal information and the right to ask us to restrict processing of your personal information or request portability of your personal information.
• Right to withdraw your consent to the use of your personal information where we are relying on that consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• In some circumstances, you have the right to receive some of your personal information in a usable format and/or request we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
• Theright to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. You can also exercise this right through the App by going to settings and withdrawing your consent to push notifications and direct messages. To opt-out of other forms of marketing, then please contact us using the contact details provided in this notice.

You can exercise these rights at any time by using the following contact details: The Collective (Living) Limited whose registered office is at 14 Bedford Square, London, WC1B 3JA or via email to: hello@thecollective.com.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are unhappy with our collection and use of your personal information, you also have the right to complain to a data protection authority – in the UK this is the Information Commissioner who can be contacted through www.ico.org.uk. .

International data transfers

Data and personal information that we collect from you may be transferred to, processed and stored at a destination outside the European Economic Area (“EEA”) as certain of our third-party service providers and partners operate around the world.  This means that when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

A copy of our data retention policy can be provided on request to: hello@thecollective.com

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.