Online Privacy Policy

1. General

What does this notice cover?

This policy describes how the relevant companies within our corporate group (also referred to as "we" or "us" or "our") will make use of your data when we otherwise interact with you via these websites, mini-programs or otherwise provide services to you ("Services").

It also describes your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the "Your Choices and Rights?" section.

The addendums for specific jurisdictions form part of this policy. In the event of any conflict or inconsistency between the terms of this policy and the addendums, the addendums for the specific jurisdiction shall prevail.

This website is not intended for children and we do not knowingly collect data relating to children. If you are concerned that your child may have provided information through our website, please contact us at us using the details provided at Section 11 below.

Data Controllers

The controller responsible for the processing of personal data collected via this website and related online services is Pathway IP II GmbH, whose place of business is at Dammstrasse 19, CH‑6300 Zug, Switzerland. Pathway IP II GmbH acts as the group‑level data controller for personal data processed through our websites and associated online services, including where such websites are branded or operated under different group brands.

Personal data may be collected via, and processed in connection with, different group websites, platforms or brands. Other companies within the group may support the operation of these websites or process personal data on behalf of the controller, acting in accordance with applicable data protection laws and appropriate intra‑group arrangements.

Additional information required under local laws (including the identification of local contacts, representatives or entities responsible for specific processing activities) is set out in the relevant country or region‑specific addendums to this Privacy Notice.

Third-Party Links

Our websites may include links to or integrations with 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 policy of every website you visit.

2. Data We May Collect About You

Personal data, or personal information, means any information about a living individual from which that person can be identified, either on its own or when it's combined with other information held by us. It does not include data whereby the personal data has been stripped of sufficient elements that means the individual can no longer be identified (anonymous data).

In order to provide our Services to you we may collect, use, store, transfer, infer and generate different kinds of personal data about you which we have grouped together as follows:

Identity Data

Includes first name, last name, email, phone number, username or similar identifier, password, information required to verify identity or ownership, including ID documentation such as passport copy and/or proof of address, and, where required for KYC or anti-money laundering checks, biometric data used to verify your identity, such as facial images, facial geometry or biometric templates generated from identity documents or live image/video checks.

Contact Data

Office address, email address, telephone numbers and job position/role.

Financial Data

Credit rating using third party, bank account details and payment card details, invoice details (e.g. where we invoice our customers as collections agent for our real estate partners using our designated payment services provider (currently Stripe) including platform fees, on-demand fees, deposits and sales tax, and any other financial details obtained as a result of providing enforcement support to our real estate partners.

Transaction Data

Information that you provide or we record when you submit an enquiry. This includes information provided or recorded at the time of registering to use our website such as subscribing to our introductions and matching services, posting material, requesting further services from your contact, or otherwise collected or recorded during viewings, appointments or telephone calls. Details of transactions you carry out through our website and the fulfilment of your orders, including the arrangements and deals entered with third party office service operators and providers with whom we match your requests. Information that you provide to us or that is recorded as part of customer service/customer technical support including details of contact and reported issues/incidents, feedback, reviews and surveys.

Technical, Profile and Usage Data

Please see section 8 below regarding cookies. It also includes other details of your access to and usage of our Services including the Worka platform including identifiers such as IP address captured to enable us to confirm timestamp of account creation, mobile IDs, Internet service provider, platform type, date/time stamp, information about the device you use to access our Services (e.g. operating system, device ID, browser type) as well as activity/usage data generally i.e. data "events"/transactions (e.g. creation of a user ID or a booking or payment being made), information about your browsing or searches or clicks on our website(s), referring/exit website addresses and geolocation data.

Communication Data

Includes your preferences in receiving communication from us and our third parties and your communication and marketing preferences/consents.

Inference Data

Any inference drawn from any of the information described in this Policy to create a profile about you.

Audio and Video Recording Data

Includes personal data you provide during phone calls, which may be recorded for training and quality purposes.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 Policy.

We generally do not ask you to provide to us any Special Categories of Personal Data about you, however, where required for identity verification, KYC, fraud prevention or anti-money laundering purposes, we may process biometric data for the purpose of uniquely identifying you. We will only do this where permitted by applicable law and where an appropriate legal basis and additional condition for processing applies.

3. How Is Your Personal Data Collected?

From You

You may give us your Identity, Contact, Financial, Transaction, Profile, and Communication Data by filling in forms including online or by communicating with us by post, phone, email or otherwise. This includes personal data which you provide or which we infer, generate, or record when you:

apply for our products or Services;
submit an enquiry for office space;
create an account on our websites including registering to use our platforms;
subscribe to our service or publications;
subscribe to our market data reports;
request marketing to be sent to you;
enter a competition, promotion or survey;
make a complaint;
report a problem with the website;
give us some feedback or otherwise contact us; and
complete any anti-money laundering (KYC) checks, including by uploading identity documents or completing image, video, liveness or biometric verification checks.

For certain processing such as completing KYC checks, processing the details of the authorised users to provide our Services and processing contact/payment details for invoicing purposes, the provision of information is mandatory: if relevant data is not provided, then we will not be able to provide the requested Services. The provision of other information, such as responding to customer services surveys, is optional.

Automated Technologies or Interactions

As you interact with our website, we may, where we are permitted to do so by applicable law, collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to our Cookie Notice for further detail.

From Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties and public sources as set out below:

Technical Data

Please see our Cookie Notice.

Transaction Data

Serviced office brokers and partners and providers of payment processing services.

Financial Data

Credit rating agencies.

Identity Data and Contact Data

AML KYC service providers including providers that use biometric verification, liveness detection, document authentication or AI-supported identity verification tools.
Data brokers or aggregators such as D&B Hoovers and Clearbit
Publicly available sources such as organisations' websites, company registries and the Electoral Register
Real estate brokers and partners
Serviced office operators

4. Purposes for Which We Will Use Your Personal Data

We will only process your personal data where we are permitted to do so by applicable law.

We have set out 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. If you are in the European Economic Area ("EEA"), the United Kingdom ("UK") or Switzerland, we have also identified what our legitimate interests are where appropriate and how they relate to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then — as required by data protection law — we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals' interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by contacting us using the details given below.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing (from us or from third parties) via email, push notifications or text message, provided we have your consent to do so, as outlined below. You have the right to withdraw consent at any time by using the unsubscribe feature on email or text communications or in some cases, via your online account by changing your contact preferences. Such communications may also be provided or recorded by third parties acting on our behalf — these communications will be clear that they are communications from us. For further information on marketing and your contact preferences, please see section 7 below.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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 below, please contact us at us using the details provided at Section 11 below.

To register you as a new customer and complete anti-money laundering (KYC) checks that are legally required, including where required through AI-supported document verification, biometric matching and liveness detection.

Data categories used: Identity, Contact,Financial and Biometric Verification Data

Lawful basis: (a) Necessary for our Legitimate Interests (to deal with your request for workspace and where we have a contract with your organisation, to perform or administer our contract)

Categories of third parties: Service providers; our affiliated companies; professional advisors

To process your enquiry concerning flexible workspace solutions to you

Data categories used: Identity, Contact, Transaction and Communication

Lawful basis: (a) Necessary for our Legitimate Interests (to deal with your request for workspace and where we have a contract with your organisation, to perform or administer our contract)

Categories of third parties: Third party real estate brokers; service providers; our affiliated companies

To organise office viewings with you by phone and/or email and submit reminders of those viewings to you by SMS

Data categories used: Identity and Contact

Lawful basis: (a) Necessary for our Legitimate Interests (to deal with your request for workspace and where we have a contract with your organisation, to perform or administer our contract)

Categories of third parties: Third party real estate brokers; service providers; our affiliated companies

To provide ongoing customer support whilst you are a customer including, by phone or email

Data categories used: Identity and Contact

Lawful basis: (a) Necessary for our Legitimate Interests (to deal with your request for workspace and where we have a contract with your organisation, to perform or administer our contract)

Categories of third parties: Service providers; our affiliated companies

Where you use our online platforms, to provide you with workspace listings which you may select, book and pay for online on-demand, and otherwise manage the platforms

Data categories used: Identity, Contact, Technical and Usage

Lawful basis: (a) Necessary for our Legitimate Interests (to provide the platform services and any related services to you)

Categories of third parties: Third party real estate brokers; service providers; our affiliated companies

To invoice you and collect payment from you for office space or other services we provide to you

Data categories used: Identity and Contact

Lawful basis: (a) Necessary for our Legitimate Interests (to invoice you for the services we provide to you)

Categories of third parties: Service providers; our affiliated companies

To manage our relationship with you, which will include, by email

(a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to leave a review or take a survey;
(c) Communicating with you such as by responding to your queries or requests and sending you information.

Data categories used: Identity, Contact, Profile and Communication

Lawful basis: (a) Necessary to comply with a legal obligation to which we are subject under laws relating to data protection; (b) Necessary for our Legitimate Interests (to keep our records updated and to improve products/services we offer)

Categories of third parties: Our affiliated companies

To enable us to conclude, perform or administer a contract we have with your organisation, to comply with any applicable legal or regulatory obligations or to protect legal rights

Data categories used: Identity, Contact, Transaction, Financial and Communication

Lawful basis: (a) Necessary for our Legitimate Interests (where we have a contract with your organisation, to perform or administer our contract); (b) Necessary to comply with a legal obligation to which we are subject under laws relating to anti-money laundering

Categories of third parties: Real estate agents; our affiliated companies; service providers; professional advisors

To enable you to partake in a prize draw, competition or complete a survey

Data categories used: Identity, Contact, Profile, Usage, Communication

Lawful basis: (a) Consent (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility)

Categories of third parties: Service providers; our affiliated companies

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Data categories used: Identity, Contact, Technical

Lawful basis: (a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud); (b) Necessary to comply with a legal obligation to which we may be subject under laws relating to IT security and payments

Categories of third parties: Service providers; professional advisors; regulatory bodies; our affiliated companies

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Data categories used: Identity, Contact, Profile, Usage, Communication, Technical

Lawful basis: (a) Consent (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility); (b) Necessary for our Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Categories of third parties: Service providers; advertising and analytics companies; our affiliated companies

To use data analytics to improve our website, for our products/services (including undertaking and providing market data, insights, analytics and reporting), marketing, customer relationships (including reporting) and experiences

Data categories used: Transaction, Technical, Usage

Categories of third parties: Service providers; advertising and analytics companies; our affiliated companies

To make suggestions and recommendations to you by email or text/direct message about services that may be of interest to you (such as information regarding offers or other opportunities)

Data categories used: Identity, Contact, Technical, Usage, Profile

Categories of third parties: Service providers; advertising and analytics companies; our affiliated companies

Where we process personal data on the basis of a legitimate interest, then — as required by data protection law — we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals' interests outweigh our interests in the processing taking place. If legitimate interest is not an available legal basis in a particular jurisdiction, we will engage in the processing activities described above on a legal basis that is available in that particular jurisdiction.

5. Where We Transfer Your Personal Data

We share your personal data within the group. This may involve transferring your data outside the UK/EU, to countries with data protection laws which may be of a lower standard than in the UK/EU.

It may also be processed by staff operating outside the UK/EU who work for us or for one of our suppliers, for example in the US, India, China, Singapore and South Africa. Such staff may be engaged in, among other things, the fulfilment of your order and any international requests that you make for serviced office solutions, the processing of your payment details and the provision of support services. It may also be processed in other locations where our partners and customers are located. By submitting your personal data, you acknowledge this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Many of our external third parties are based outside the UK/EU so their and their sub-processors' processing of your personal data may involve a transfer of data outside the UK/EU and in particular to the US.

Whenever we transfer your personal data out of the UK/EU, we will ensure a similar degree of protection is afforded to it by the transferee, such as through appropriate safeguards. Please contact us at us using the details provided at Section 11 below if you would like to see a copy of the specific safeguards applied to the export of your information.

6. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. Where we are required by applicable law, we will get your express opt-in consent before we provide you with direct marketing. We will also ask for your express opt-in consent before we disclose your personal data to any other company (including those within the group of companies for marketing purposes), where required by applicable law.

You can ask us to stop sending you marketing messages at any time by using the unsubscribe feature on our email and any text communications to update your contact preferences. If you wish to opt-out from receiving marketing communications from any of our third-party partners, please contact the relevant business directly.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions, where we have a separate legal basis to use that personal data.

7. Data Security

We have put in place reasonable and appropriate security measures to help 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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone in order to avoid illegitimate intrusion into your privacy or your business transactions.

All the information you provide will be held in the strictest confidence and only used for the purposes described in this Notice.

Although we will do our best to protect your personal data in accordance with industry practice, we cannot guarantee the security of your data transmitted to our website. Due to the nature of the internet, the transmission of information online is not completely secure. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access to, or loss, misuse, disclosure or modification of the personal data that you provide to us.

8. Your Legal Rights

You have the following rights (subject to certain conditions in data protection laws and other relevant laws which may apply):

Depending on the data protection laws applicable in a particular jurisdiction, your rights may vary depending on the country or jurisdiction in which you are located. Please refer to the relevant country or regional addendum (set out in the annexures to this Privacy Notice) for further information on the rights that apply to you.

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.
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 using the details provided at Section 11 below.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, for the purposes of satisfying any legal, accounting, or reporting requirements (where, by law or good industry practice, we have to keep certain information (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

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. If your personal data is used for two purposes, we will retain it until the purpose with the latest period expires.

Where we process registration data, we do this for as long as you are an active user of our sites and for seven years after this unless a longer retention period is required to establish, exercise or respond to legal disputes.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process personal data for site security purposes, we retain it for as long as is necessary to investigate incidents, maintain system security, and comply with legal obligations.

Where we process personal data in connection with performing a contract or for a competition, we keep the data for 6 years from your last interaction with us unless a longer retention period is required to establish, exercise or respond to legal disputes.

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.

10. Changes to Our Policy

Any changes we may make to this Notice in the future, for example in relation to updates to our processes and purposes, will be posted on our website. Such changes will become effective upon your use of our website after such changes have been posted. If the changes are material, we may provide you additional notice, to your email address. We encourage you to periodically review this page for the latest information on our privacy practices.

11. Contacting Us

If you have any questions regarding this Notice or want to make a request to exercise any of your legal rights (as set out in section 8 above), please contact us by:

Emailing Privacy privacy@spaces.com; or
Clicking on the unsubscribe link in any of our email communications or via Your Account.

If you are unhappy with how we have handled your data, or you are not satisfied with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the data protection authority in the country in which you reside, where your place of work is located or where the alleged infringement took place. In the UK, this is the ICO.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (please note we can't be responsible for the content of external websites).

We would, however, appreciate the opportunity to deal with your concerns before you approach any data protection authority so please contact us in the first instance at the email address stated above.

Thank you for visiting our website.

California Privacy Rights Addendum

If you are in California and the processing of personal data about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that data.

Notice at Collection

At or before the time of collection, you have a right to receive notice of our practices, including the categories (see section 2 "Data We Collect About You") of personal data and sensitive personal data to be collected, the purposes (see section 4 "Purposes for which We Will Use Your Personal Data") for which such data is collected or used, whether such personal data is sold or shared (see section 5 "Where We Transfer Your Personal Data"), and how long personal data is retained (see section 10 "Data Retention"). You can find those details in this Policy by referring to the sections named above.

Right to Know

You have a right to request that we disclose to you the personal data we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of your personal data. Note that we have provided much of this information in this Policy. You may submit a "request to know" by contacting us using the details provided at Section 11 of the main Privacy Notice.

Rights to Request Correction or Deletion

You also have rights to request that we correct inaccurate personal data and that we delete personal data under certain circumstances, subject to several exceptions. You may submit a request to correct or delete, by contacting us using the details provided at Section 11 of the main Privacy Notice.

Right to Opt-Out

You have a right to opt-out from future "sales" or "sharing" of personal information as those terms are defined by the CCPA.

Note that the CCPA defines "sell" and "share" very broadly, and some of our data disclosures described in this Privacy Policy may be considered a "sale" or "sharing" under those definitions. In particular, we may let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our websites and apps when you use our Services, but do not "sell" or "share" any other types of personal data. If you do not wish for us or our partners to "sell" or "share" personal data relating to your visits to our sites for advertising purposes, you can make your request by clicking/selecting "cookie preferences" on the site or using the browser or platform controls described in section 3 above. If you opt-out using these choices, we will not disclose or make available such personal data in ways that are considered a "sale" or "sharing" under the CCPA. However, we will continue to make available to our providers (acting as our service providers) some personal data to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously "sold" or "shared" personal data or stop all interest-based advertising.

We do not knowingly sell or share the personal data of minors under 16 years of age.

Right to Limit Use and Disclosure of Sensitive Personal Data

We collect government-issued identifiers and information such as a username or account number in combination with a password, security or access code, or other credential that allows you to log into an account. This information is considered "sensitive personal data" under CCPA. You have a right to limit our use and disclosure of sensitive personal data for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal data for any such additional purposes.

Right to Non-Discrimination

You have a right to not be discriminated against for exercising these rights set out in the CCPA.

Authorized Agent

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with 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 manifestly unfounded, repetitive or excessive. Alternatively, we may 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. For some types of personal data we may have, such as where you visit our website and are not authenticated, there is no reasonable method by which we can verify your identity as the person to whom that data relates.

Time Limit to Respond

Subject to the provision of the requisite information, we will try to respond to all legitimate requests within the time required by law (e.g. for EEA, UK, and Switzerland, one calendar month; for California, 45 days). Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. If this is the case, we will explain this to you within the first month.

Please be aware that your exercise of some of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and some of these rights may be limited where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

Governing Law and Jurisdiction

Laws of England in respect of Services globally (save for Services in North America where the governing law shall be the law of the State of New York).

The parties agree that the courts of England shall have exclusive jurisdiction except where New York law is the governing law in which case the courts of New York shall have exclusive jurisdiction.

Mainland China Addendum

This Mainland China Addendum (this "Addendum") shall be regarded as a supplement to the Website Privacy Notice (the "Policy"). This Addendum applies to all personal information about you that we process and that is subject to the Personal Information Protection Law of the People's Republic of China (the "PIPL"), regardless of how or where such personal information is collected.

Where we process personal information within the territory of the People's Republic of China ("PRC") as an overseas personal information handler under the Personal Information Protection Law of the PRC, we have appointed the following entity as our representative within China to handle matters relating to personal information protection:

PRC Representative: Dajie Gongfang Business Services (Shanghai) Co., Ltd. Contact details: privacy@spaces.com

Individuals in China may contact the PRC representative in relation to the protection of their personal information and the exercise of their rights under PRC law. The PRC representative acts solely as a liaison and does not affect our responsibilities as the personal information handler.

Data We May Collect About You (Mini-Program)

When you use the Mini-Program, we will collect and use your personal information for the following purposes and in the following methods:

(1) Information you provide to us or authorise us to obtain from third parties

Lead Enquiry / Contact Request (Mini-Program) — Enquiry Submission

Purpose: To allow users to submit enquiries and be contacted by our sales or support teams.

Method: Information is provided directly by the user within the Mini-Program.

Types of personal information collected and used: Mobile phone number, enquiry content.

WeChat Identity Binding (Implicit)

Purpose: To support Mini-Program runtime and basic user identification within the WeChat ecosystem.

Method: Automatically obtained via the Mini-Program SDK when launching the Mini-Program.

Types of personal information collected and used: OpenID (Union ID if applicable).

Order Payment via WeChat Pay or Alipay

Purpose: To complete the payment.

Method: User input.

Types of personal information collected and used: WeChat Pay transaction number, amount, status.

Lead Enquiry / Contact Request (Mini-Program) — Customer Identification

Purpose: To identify and communicate with customers.

Method: User input.

Types of personal information collected and used: Name.

Lead Enquiry / Contact Request (Mini-Program) — Communication and Booking Confirmation

Purpose: Communication and booking confirmation.

Method: User input.

Types of personal information collected and used: Mobile phone number, email.

Lead Enquiry / Contact Request (Mini-Program) — Service Discovery

Purpose: Service discovery.

Method: User input/device.

Types of personal information collected and used: Selected city/current location.

Order Processing

Purpose: Order creation and service fulfilment.

Method: WCMP interaction.

Types of personal information collected and used: Product type, centre location, booking date, order ID.

Agreement Signing

Purpose: Contract acceptance and record.

Method: User input.

Types of personal information collected and used: Customer name, company name (if applicable), agreement acceptance timestamp.

Order Payment Processing

Purpose: Payment confirmation.

Method: Obtained from third-party payment service providers.

Types of personal information collected and used: Payment status, transaction ID, payment reference.

Invoice Issuance

Purpose: Electronic invoice issuance.

Method: User input.

Types of personal information collected and used: Invoice title, company name, tax number.

City-Based Listing

Purpose: To determine the user's city.

Method: User-authorized via the standard WeChat Mini Program permissions interface.

Types of personal information collected and used: Latitude and longitude and converted location information.

Tencent Ads Postback

Purpose: Ad conversion attribution and performance optimization.

Method: Via Tencent Ads Mini Program SDK (automatic event tracking and manual event report).

Types of personal information collected and used: User ID and usage data.

(2) Device permission access

To enable specific functions of the Mini-Program, we will request the following operating system permissions related to your personal information. If you refuse or revoke these system permissions, you will not be able to use the corresponding functions, but this will not affect your use of other functions provided by the WeChat Mini-Program. You can manage your authorization of the relevant permissions by clicking the "···" icon in the top right corner of the Mini-Program page and selecting "Settings," or by choosing to disable some or all system permissions in your device settings.

Location Permission

Purpose of accessing the permission: To display nearby office locations where applicable.

Whether the user can disable the permission: Yes.

Camera

Purpose of accessing the permission: For scanning QR codes.

Whether the user can disable the permission: Yes.

(3) Collection and use of personal information by third-party SDKs

To ensure the stable operation and functionality of the Mini-Program, we embed third-party software development kits (SDKs) within this Mini-Program. Regarding how these third-party SDKs collect and use your personal information, you are advised to refer to the relevant service agreements and privacy policies of the third parties. The specific third-party plugins/SDKs integrated into this Mini-Program are as follows:

WeChat Pay

Operator name: Tenpay Payment Technology Co., Ltd.

Purposes and methods of processing personal information: This will be considered in a later phase.

Types of personal information processed: WeChat account identifier, order amount.

Third-party privacy policy or official website link: https://posts.tenpay.com/posts/be09d2a0635a25b7004277b0495f4fdf.html

Tencent LBS Open API

Operator name: Tencent Technology (Shenzhen) Co., Ltd.

Purposes and methods of processing personal information: To determine the location of the user.

Types of personal information processed: Latitude and longitude and converted location information.

Third-party privacy policy or official website link: https://rule.tencent.com/rule/0c5ee022-04cf-4614-a116-32d9f362552a

Baidu Map Web API

Operator name: Beijing Baidu Netcom Science and Technology Co., Ltd.

Purposes and methods of processing personal information: To determine the location of the user.

Types of personal information processed: Latitude and longitude and converted location information.

Third-party privacy policy or official website link: https://lbsyun.baidu.com/docs/pcsa?title=compliance/openprivacy

WeChat Mini-Program Base SDK

Operator name: Tencent Holdings Limited.

Purposes and methods of processing personal information: Required for Mini-Program runtime.

Types of personal information processed: OpenID, basic device/runtime info.

Third-party privacy policy or official website link: https://www.tencent.com/zh-cn/privacy-policy.html

Processing of Sensitive Personal Information

Regardless of how the Policy defines "special categories of personal data," certain categories of personal information constitute "sensitive personal information" under applicable laws in China. Such sensitive personal information is necessary for us to achieve the purposes set out in the Policy or this Addendum and to comply with applicable laws and regulatory requirements. You should be aware that if your sensitive personal information is leaked or illegally used, it may impact your personal rights and interests, including, without limitation, risks to your personal and property security. To the extent permitted under applicable laws in China, we will adopt enhanced protective measures when processing your sensitive personal information.

International Transfers

Your personal information may be transferred to or processed outside of China. If personal information is transferred abroad, we will comply with applicable laws and regulations and take necessary measures to ensure that the overseas recipients process personal data in accordance with the standards for personal data protection set out in the Policy, this Addendum and relevant laws and regulations.

For details regarding the cross-border transfer of your personal information, please see below:

Franchise International GmbH

Contact information: privacy@spaces.com

Categories of personal information being provided:

For Websites subject to the PIPL:

Contact information: name, address, unique login name and password, email address, telephone number
Technical information: browser type, Internet service provider, platform type, internet protocol (IP) addresses, referring/exit pages, operating system, date/time stamp, etc.
Demographic information: type of business, size of business, locations, etc.

For the Mini-Program:

Name, mobile phone number, Open ID/Union ID

Purpose and methods of the recipient's processing:

For Websites subject to the PIPL and the Mini-Program: personal information will be transferred to systems operated by the recipient for the following purposes: data consolidation, storage, simplified customer information management, reporting, delivery of complete products, services, and customer solutions, as well as other internal uses.