Fresh Locations Limited Privacy Notice

This privacy notice aims to inform you about how we look after your personal data when you use the functions on our website (regardless of where you visit it from), when you register your property with us or you approach us in relation to making a booking for one of our locations, and your rights in relation to that data. 

The term ‘personal data’, also commonly referred to as personal information, means any information about an individual from which, on its own or when combined with other information, that person can be identified. It does not include data where the identity has been removed.

Information about us

For the purposes of data protection regulations, Fresh Locations Limited (“Fresh”) is the data controller, which means the entity responsible for your personal data. Fresh is referred to in this privacy notice as “we”, “us” and “our”. 

Our full contact details are:

Fresh Locations Limited, 37 Ormonde Road, London SW14 7BE

Email: bookings@freshlocations.com

Telephone: 07970 755076

If you have any questions about anything in this privacy notice, or you wish to request access to the data we hold about you, you can contact us using the details above. 

It is important that the personal data we hold about you is accurate and up to date. Please do let us know if any of that data changes during the time we hold it. 

Third party links and websites

Our website may contain links to third-party websites, plug-ins and applications. By clicking on any of those links or enabling those connections you may allow third parties to collect or share data about you. We do not control those third-party connections and we are not responsible for what the relevant third-party may do with data they collect about you. We recommend that you read the privacy notices of each third-party site in order to understand how they may collect and process your data. 

What data do we collect from you?

The data we collect from you will depend on the nature of our interaction, for example whether you are just browsing our website, you are a location owner or you are looking to book a location. We may from time to time collect, use, store and transfer the following personal data about you:

Where you are browsing our website:

  • Your IP address and other technical data based on that IP address e.g. time zone; location and other technology on the device you use to contact us
  • Your username and password, if you have registered to use the Favourites function on our website
  • Usage data from our website, including information about how you have arrived at our website
  • Your communications preferences with regards to receiving marketing and newsletters. 

In addition, if you are registering a location with us or booking a location: 

  • Your full name (first name and surname)
  • Your address
  • Your contact details, including email addresses and telephone numbers
  • Financial information, including bank account holder details

We may also collect aggregated or anonymised data (or both) such as statistical /demographic data, for any purposes. This data may be derived from your personal data but as it does not directly or indirectly identify you, it is not considered ‘personal data’ in legal terms. For example, we may aggregate information about how you use our website and services to calculate the percentage of users accessing a specific website feature, such as our ‘Favourites’ function. 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 notice. 

If we need to collect any personal data for any legal reason or under the terms of a contract we have with you, and you do not provide that data when requested, then we may not be able to carry out our obligations under that contract, for example to provide you with certain services. In those circumstances we may have to cancel our contract with you, but we will notify you if this is the case. 

How do we collect your data?

We collect data from and about you in various forms and circumstances, as set out below: 

  • When we interact with you directly – you may provide us with data such as names, addresses and email addresses and, if you are location owner, financial data, when you correspond with us by post, phone, email or otherwise. This could include data you provide when you:
    • apply to register your property with us
    • subscribe to our newsletter
    • enquire about locations on our books
    • register for the Favourites function on our website
    • contact us or chat with us via the live chat function on our website
  • Via automated technology – as you use our website, we may automatically collect technical data about the device you are using to access our website and your browsing activities and patterns. We collect this data by using cookies and other similar technologies. You can read more about what cookies are and how we use them by clicking here.
  • Via third parties or publicly available services – we collect data about you from third party providers as set out below:
    • Technical data from analytics providers such as Google
    • Identity and contact details from JivoChat
    • Technical data from Google AdWords
    • Identity data from publicly available sources such as Companies House, if you are enquiring about booking a location

How do we use your data?

We will only use your personal data when the law allows us to. Most commonly we will use your data in the following circumstances: 

  • Where it is necessary for performance of a contract to which you are a party or to take steps at your request before entering into such a contract with you. 
  • Where it is necessary for our legitimate interests (or those of a third party). This means the interest of our business in managing and conducting our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your interests and fundamental rights when relying on legitimate interests in processing your data. 
  • Where it is necessary for compliance with a legal obligation that we are subject to. 

We have set out below a description of the ways we use your personal data and which of the legal grounds that we rely on in order to do so. Please contact us if you would like any more information about the legal ground that applies to any particular use of data. 

Where you are browsing our website: 

Purpose/ActivityData UsedLawful Basis of Processing
To enable you to register for the Favourites function on our websiteUsername and password Performance of a contract with you
To respond to enquiries about us and locations on our books Contact details as provided to usPerformance of a contract with you
To send newsletters and updatesEmail addressYou have given consent for us to do so
To manage our relationship with you, including:(a) notifying you of changes to our policies; and
(b) to collect and recover any monies owed to us.
(a) Name and contact details
(b) Name, address, contact details and financial information
(a) necessary to comply with legal obligations;(b) performance of a contract with you; and (c) our legitimate interests (in recovering monies due to us)
To correspond via the live chat function on our websiteContact details provided by youPerformance of a contract with you 
To comply with legal and accounting obligationsName, address and financial informationNecessary to comply with legal and regulatory obligations 
To administer and deliver relevant website content IP addresses and other technical data/ analytics data (anonymised)Our legitimate interests (improving and delivering our service as best as possible).
To improve our website, services and client experiencesIP addresses and other technical data and analytics data (anonymised)Our legitimate interests (to keep our website updated and relevant; to develop our business strategies).

In addition, where you registering your location with us: 

Purpose/ActivityData UsedLawful Basis of Processing
To set you up as a location owner on our books/to provide our services as agent once you are set upName, address and contact detailsPerformance of, a contract with you
To manage our relationship with you, including:(a) notifying you of changes to our policies; and
(b) to collect and recover any monies owed to us.
(a) Name and contact details
(b) Name, address, contact details and financial information
(a) necessary to comply with legal obligations;(b) performance of a contract with you; and (c) our legitimate interests (in recovering monies due to us)
To comply with legal and accounting obligationsName, address and financial informationNecessary to comply with legal and regulatory obligations 
To administer and deliver relevant website content IP addresses and other technical data/ analytics data (anonymised)Our legitimate interests (improving and delivering our service as best as possible).
To improve our website, services and client experiencesIP addresses and other technical data and analytics data (anonymised)Our legitimate interests (to keep our website updated and relevant; to develop our business strategies).

We will only use your personal data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another purpose and that purpose is compatible with the original purpose for which the data was provided to us. You can contact us at any time to obtain more information about this processing. If we need to use your personal data for any other purpose, we will notify you and will explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent if the law requires or permits us to do so. 

Marketing

We only send out marketing information and newsletters if you have opted in to receive that information. We do not share or pass on data to any third parties for marketing purposes. 

You can ask us to stop sending you marketing/newsletters at any time by contacting us at bookings@freshlocations.com or by choosing ‘unsubscribe’ at the bottom of any such communication (but, if you do so we will retain personal data provided to us and which we need to process in order to continue providing our other services to you). We may also retain personal data of individuals that have opted out in order to comply with record-keeping obligations. 

Disclosure of your personal data and international transfers

We may share your personal data with third parties as set out below:

Third PartyLocation of recipient (if outside UK)
Professional advisors such as lawyers, accountants and auditors, who provide professional services to us and are under a duty of confidentialityUK
HMRC and other authorities and regulators, whose laws and regulations require us to disclose dataUK
Other service providers:
Service providers providing website/IT systems admin and support, development and maintenanceUK
CloudflareMalta
DropboxUSA
iCloudUSA/Asia
JivoChatUSA
Google AnalyticsUSA
QuickBooksUSA
Amazon Web ServicesIreland

We strive to ensure all third parties respect the security of your personal data, to treat it in accordance with the law and to process and use that data only for the purposes specified by us and in accordance with our instructions. 

Some of our external service providers are based outside the UK, as set out above, so their processing of your data involves a transfer of data outside the UK. Wherever we transfer your data outside the UK, we use our best efforts to ensure that a similar degree of protection is afforded to it by ensuring that least one of the following safeguards is in place: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
  • For certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection as it has in the UK. 

Please contact us If you want further information about transferring personal data outside the UK. 

We may also share personal data with 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 notice.

Data security

We have put in place appropriate security measures for the nature and scale of our business, in order 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 of our employees, contractors and other third parties who have a business need to know. They will only process data we give them on our instructions and they will be subject to a duty of confidentiality.  

We have procedures in place to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so. 

How long will we use your data for?

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying legal, regulatory, tax, accounting and reporting requirements. 

To determine how long we need to retain data, alongside any applicable legal, regulatory, tax, accounting and reporting requirements we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process that data and whether we can achieve those purposes without keeping the data.

If you contact us via the JivoChat web chat service on our website, the data you provide will be retained for two (2) months following that communication, unless you have asked us to provide anything to you such as location examples/suggestions, in which case we may retain that data for a longer period. 

The law also requires us to keep certain basic information about our clients for six years after ceasing to work with you, for tax purposes. 

Please contact us for any further information about retention of data. 

Your legal rights

You have the right to request the information we hold on you, to ask us to correct that data and, in certain circumstances, to erase that data. 

You also have certain rights to object to our processing your data, to restrict that processing or to request transfer of your personal data. 

If you would like any more information about, or would like to exercise, any of these rights please contact us. You will not be charged any fee to do so, unless your request is clearly unfounded, excessive or repetitive, in which case we can refuse to comply or we may charge a reasonable fee. 

We will make every effort to respond to legitimate requests within one month. Occasionally it may take us longer to do so, if your request is complicated or you have made more than one request, and in such circumstances we will do our best to keep you updated. 

We may need to request specific information from you to help us with your query or to 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 does not have a right to receive it. 

If you feel that our processing of your personal data is not compliant with our legal and regulatory obligations you are entitled to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. We would, however, appreciate the opportunity to try and address your concerns before you contact the ICO, so we would be grateful if you would contact us in the first instance. 

This privacy notice was last updated in June 2023 

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