Data Protection and Data Sharing (Privacy Policy)

1. Each party shall comply with its respective obligations under the provisions of the data protection legislation (being the Data Protection Act 1998 (or any subsequent legislation including the General Data Protection Regulation (Regulation (EU) 2016/679)) or any regulations statutory instruments made under such legislation). References in this clause to "data processor", "data controller" and "personal data" shall have the meanings defined in the data protection legislation.
2. When accepting a Booking we may share details of the Explorer with you (Shared Data) via our website. The Shared Data may include an Explorers name. These details are provided to you for the purpose of accepting and fulfilling Bookings. In relation to the Shared Data provided by us, you agree to:
1. comply with your obligations under the data protection legislation;
2. provide us with all reasonable assistance as we may require from time to time;
3. only use the Shared Data for the purpose of accepting, managing and fulfilling Bookings and for security purposes (Agreed Purposes); and
4. only use the Shared Data for the duration of the Booking.
3. The permitted use of the Shared Data expressly excludes (without limitation)
1. disclosure in breach of the confidentiality obligations;
2. use of the Shared Data for any purposes inconsistent with the Agreed Purposes unless required or permitted by law;
3. transferring the Shared Data outside of the European Economic Area;
4. including any element of the Shared Data within any larger data set already held by you; and
5. washing or integrating any element of the Shared Data against any previous data derived by you from other data washing activity.
4. Pompli reserves the right upon giving reasonable notice and within normal business hours to inspect (either by itself or through an appointed third party) your systems in order to ascertain compliance with the data protection legislation and the terms of this Agreement. Each party shall bear its own costs of any such inspection which shall be carried out with the minimum of disruption.
5. Even where the Shared Data does not constitute personal data for the purposes of the data protection legislation, you shall (for the purposes of this Agreement treat the Shared Data as though it were personal data).
6. You shall where you are acting as data controller in relation to Shared Data:
1. issue notices to data subjects in relation to the Shared Data about your processing of such Shared Data when requested to do so by Pompli;
2. allow Pompli to approve and, if Pompli deems necessary, to amend any notices given to data subjects in relation to the Shared Data that are required by data protection legislation;
3. promptly inform Pompli about the receipt of any data subject access request;
4. not disclose the Shared Data with any party other than the parties to this Agreement, the employees and subcontractors of each party who need access to the Shared Data and any other third parties engaged to perform obligations in connection with this Agreement;
5. ensure that you have in place appropriate technical and organisational measures, reviewed and approved by Pompli, to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data;
6. provide Pompli with reasonable assistance in complying with any data subject access request;
7. not disclose or release any Shared Data in response to a data subject access request without first consulting with and obtaining the consent of Pompli;
8. assist Pompli, at the cost of Pompli, in responding to any request from a data subject and in ensuring compliance with its obligations under the data protection legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
9. notify Pompli without undue delay on becoming aware of any breach of the data protection legislation;
10. not transfer any personal data outside of the European Economic Area unless the prior written consent of the data subject has been obtained and the following conditions are fulfilled:
11. the data subject has enforceable rights and effective legal remedies with regard to the transferred personal data;
12. the transferring party complies with its obligations under the data protection legislation by providing an adequate level of protection to any personal data that is transferred.
13. use compatible technology to that used by Pompli for the processing of Shared Data to ensure that there is no lack of accuracy resulting from personal data transfers; and
14. maintain complete and accurate records and information to demonstrate your compliance with this Clause 12 and allow for audits by Pompli or its designated auditor.
7. You shall procure that where you disclose the Shared Data to a subcontractor in accordance with clause 12.6(d) (whether directly or by requesting Pompli to grant access to the Shared Data) that such subcontractor shall comply with the terms and conditions set out in this Agreement.

Insurance

You will be entirely responsible for any and all insurance that you may require for the purposes of granting any license to use your Coworking Space.

Confidentiality

Except as otherwise agreed in these terms and conditions, each party agrees with the other to keep secret and not share (except for with its employees, advisers and contractors) any confidential information it receives from the other party through the Services.

General

1. No term of this Agreement will be enforceable by any person that is not a party to it including (if you are domiciled in the UK) any enforcement through the Contract (Rights of Third Parties) Act 1999.
2. You acknowledge that we may transfer our rights under the terms (and any related claims) to any third party without having to obtain your prior permission provided that this will not affect the standard of services you receive under this Agreement and that we notify you of the date on which we will transfer our rights and obligations under this Agreement to another legal entity, Your only rights under or in connection with this Agreement will be against the new legal entity and not against us.
3. You agree that these terms are fair and reasonable in all the circumstances. However if any part of these terms is disallowed or found to be ineffective by a court or regulator, the other provisions shall continue to apply.
4. If you breach these terms and we take no action against you, we will still be entitled to use our rights and remedies in any other situation where you breach these terms.

Governing Law and Jurisdiction

This Agreement shall in all respects be governed by the laws of England. We both agree to submit to the non-exclusive jurisdiction of the English courts, which means: (i) that if you live in the EU, you may enforce your rights in connection with these terms in the EU member state in which you live; or (ii) if you live in any other jurisdiction which gives you mandatory consumer protection rights, you may enforce your rights in connection with the terms, in accordance with such rights.

Privacy Policy

1. Pompli Limited, ("we" or "us") take the privacy of your information very seriously. This policy explains how and for what purposes we use the information collected about you via our website (referred to below as "the Service"). Please read this privacy policy carefully. By using the Service you are agreeing to be bound by this policy in respect of the information collected about you via this Site.
2. If you have any queries about the policy, please get in touch and we will do our best to answer your questions.

Personal information collected and use of this information

1. Core Account Data - although it is not compulsory to give us this information, if you do not then you cannot register as a member of the Service, or make a booking for a Coworking space with our Coworking space operators we will collect the following data.

1. Name - we need to store this to identify you in the provision of our service. It will be shared with Coworking space operators you make a booking with and users on our platform which you send messages to.
2. Email - we’ll send emails to you about your bookings and the Pompli service. We may share your email with third parties (including Coworking space operators).
3. IP Address - this is used by us and some of our third-party providers to identify your device in the provision of our service. It is also used for fraud checks and to ensure a secure product.
4. Payment method - payment method details you provide (including name, email address) are sent directly to PCI-compliant third party payment providers.
5. Booking history - we store a history of where and when you’ve booked spaces for administration purposes.
6. Phone number - we store this so Explorers can contact Coworking space operators and vice versa. Phone numbers are only shared when you’ve made a booking. We may contact you via phone should there be any issues with your bookings or account.
7. Messages - messages you send to other Pompli users about a booking are visible only to that user and to Pompli staff
8. Administering your booking - Pompli customer support workers may view the above data (aside from sensitive payment method details) when administering your booking.

2. Coworking Space Listing Data - to list your Coworking space with us we will collect the following data:

1. Coworking space address - we use this to show Explorers where your space is.
2. Space description - this is a public-facing description you provide when adding your space which helps Explorers decide if a space is suitable.
3. Photos of your space - these public-facing photos help Explorers decide if a space is suitable and help them access it on arrival.
4. Facilities - these are public-facing space attributes, which you can optionally provide to help Explorers decide if a space is suitable for them.
5. Access instructions - if you provide these when adding your space, they are used to help Explorers access your space.
6. Administering your space - Pompli customer support workers may view the above data when administering your space.

3. Other use of this information

We may notify you of certain offers and new products, subject to you giving your consent to do so. You can opt-out of this use at any time. We may use this information in order to:

1. make general improvements to our Service;
2. analyse how customers are making use of the Service;
3. Develop, maintain and/or improve our products and services, e.g. optimise business processes, quality assurance purposes, support efficient, management of our staff, analyse where customers have come from, analyse performance of web pages, provide relevant content to you, development of new products and services;

4. We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.

5. Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).

Data retention

1. After consenting to us using your data as described in this policy, we will retain it on our system for as long as we deem to be a period within which you may return to use your account. This varies from individual to individual depending on account activity. After that period we will close your account and delete your data in line with this policy.
2. You can remove your personal data from Pompli at any time by deleting your account. However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.

Other Sites

1. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
2. In addition, if you linked to this Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Further questions

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by emailing us at support@pompli.com.