Plus X Holdings Limited – Privacy Policy
Introduction
Plus X Holdings Limited respects your privacy and is committed to protecting your personal data.
We administer Innovation Hubs at various locations in the UK for use by a wide community of members including freelancers, startups, scaleups, corporates and education partners (our “Innovation Hubs”), and we provide various services and facilities to our members and their users and other visitors of our Innovation Hubs (our “services and facilities”), including a website for members, members’ users and other visitors at https://www.plusxinnovation.com/ (our “website”), and integrating innovation and business support programmes, startup accelerators and access to our business growth services.
This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), and use and receive our services and facilities at our Innovation Hubs, and tell you about your privacy rights and how the law protects you.
Important Information and Who We Are
Purpose of this Privacy Policy
This privacy policy aims to give you information on how Plus X Holdings Limited collects and processes your personal data through your use of this website, or our services and facilities, including any data you may provide through this website when you sign up to our, or otherwise purchase a service from us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Plus X Holdings Limited is made up of different legal entities, details of which can be found here: Plus X Slough Ltd, Plus X Brighton Ltd, Central Research Laboratory (Hayes) Ltd. Address for correspondence: 85 Great Portland Street, First Floor, London. W1W 7LT (collectively “Plus X Holdings Limited’s Group”).
This privacy policy is issued on behalf of the Plus X Holdings Limited’s Group so when we mention “Plus X Holdings Limited”, “we“, “us” or “our” in this privacy policy, we are referring to the relevant company in the Plus X Holdings Limited’s Group responsible for processing your data. Plus X Holdings Limited is the controller and responsible for this website.
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 data privacy manager in the following ways:
Data Privacy Manager
Plus X Holdings Limited
Postal address: 85 Great Portland Street, First Floor, London. W1W 7LT.
Email address: dataprivacy@plusx.space
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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity and Contact Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, your address, email address and telephone numbers. It may also include the contents of messages you may send to, or receive from. It may also include the company you represent, your job title and work experience (including name of organisation, position held at the company, length of employment). It may also include visitor data including the name, email address and company name of the visitor that has been invited to attend one of the Innovation Hubs.
- Financial and Transaction Data includes bank account and payment card details, including details about payments to and from you and other details of services and facilities that you/the relevant member have used.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Promotional Data includes visual images/footage of you at one of our Innovation Hubs, or participating in any of our activities and events at one of our Innovation Hubs.
- Usage Data includes information about how you use our website, services and facilities, including attending any of our innovation/accelerator or business support programmes.
- Marketing and Communications Data includes your preferences in receiving marketing and newsletters from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or the relevant member, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or the relevant member (for example, to provide the relevant services and facilities to you or the organisation you represent).
In this case, we may have to cancel a service you or the company you represent have with us, but we will notify you if this is the case at the time.
How is Your Personal Data Collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to use our services and facilities;
- create an account on our website;
- subscribe to our service or publications;
- enter a competition, promotion or survey;
- subscribe to the newsletters, news, publications and events circulated by us; or
- give us feedback or contact us.
- We only track users' activity on our website based on explicit consent given via the cookie banner. Your preferences can be customised via the cookie banner at any time. If consent is given; as you interact with our website, we will collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies, if consent has been given. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties including:
- Technical Data from analytics providers (such as Google and Hotjar based outside the UK), advertising networks (such as Google based outside the UK) and search information providers (such as Google, Companies House based inside and outside the UK); and
- Contact, Financial and Transaction Data from providers of technical (such as our external IT support provider based in the UK), payment (such as Stripe based inside and outside of the UK) and delivery services.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or the organisation you represent.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending any third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out in the table below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Marketing and communications from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you(we call this marketing).
You will receive marketing communications and newsletters from us if you have either requested information from us, or you or the company you represent have used our services and facilities and you have not opted out of receiving that marketing or other communications.
Third-party marketing
We will get your express opt-in consent if we look to share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase from us, service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
Disclosures of Your Personal Data
We may share your personal data with the parties set out below for thepurposes set out in the table above, including:
External Third Parties such as;
- Service providers who provide IT and system administration services, payment processors and technology providers.
- Programmes sponsors in order to assist and shape the relevant innovation programme.
- Landlords of the Innovation Hubs.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- Courts based in and outside the UK in relation to any claims any member of Plus X Holdings Limited’s Group is involved in.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Internal Third Parties who are members of Plus X Holdings Limited’s Group; and
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 policy.
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.
International Transfers
Many of our external third parties are based outside the UK 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:
1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
2. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data Security
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.
Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for.
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.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows:
- 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 your personal data 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.
- Object to processing of your personal data. This may apply 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.
- Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
- Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
- Right to withdraw consent. Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
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.
