Welcome to our privacy and cookies policy for services provided through our websites www.worka.com, www.instantoffices.com, www.easyoffices.com, coworkintel.com,incendiumconsulting.com, coworker.com, capstanadvisors.com, and our group website theinstantgroup.com or when we otherwise interact with you via these websites or otherwise provide services to you (“Services”).
This Policy (together with our Terms of Use and any other documents referred to in it):
It is important that you read this Policy together with any other privacy notice or fair processing notice 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 policy supplements the other notices and is not intended to override them.
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 privacy@theinstantgroup.com
If you are visiting or using our Services from California, you can find specific disclosures, including “Notice at Collection” details, in the “California Privacy Rights” section of this Policy below.
Depending upon which website you are using, the controller responsible for your personal data will vary as set out in the table below:
| Website | Controller | |||
|---|---|---|---|---|
| worka.com | Depending on which of our Worka Services you are using, the controller responsible for your personal data will vary: Worka Partner Portal: For our real estate partners’ “quotable” transactions (Sweden and Denmark only): Objektia AB of Box 324, 11674 Stockholm, Sweden (Company number: 556982-2173) | |||
| coworkintel.com | Worka IQ GmbH of Baarerstrasse 52, 6300 Zug, Switzerland (Company number: 447.730.148). | |||
| instantoffices.com | easyoffices.com | Coworker.com | theinstantgroup.com | Instant Offices Limited of 11th Floor, Blue Fin Building, 110 Southwark Street, London SE1 0TA registered in England and Wales (Company number: 3769141) |
| incendiumconsulting.com | Capstanadvisors.com.comIncendium Consulting Limited of 11th Floor, Blue Fin Building, 110 Southwark Street, London SE1 0TA registered in England and Wales (Company number 08216440 |
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.
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 follows:
| Identity data | includes first name, last name, email, phone number, username or similar identifier, information required to verify identity or ownership (e.g. ID documentation such as passport copy and/or proof of address) |
| Contact 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 Instant 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, 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 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. |
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. Please see section 8 for further information.
We do not ask you to provide to us 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). Neither do we collect any information about criminal convictions and offences.
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:
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.
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 section 8 below |
| Transaction Data | Serviced office operators and partners and providers of payment processing services |
| Financial Data | Credit rating agencies |
| Identity Data and Contact Data | - AML KYC service providers - Data brokers or aggregators such as D&B Hoovers and Clearbit. - Publicly availably sources such as Organisations’ websites, Companies House and the Electoral Register - Real estate partners and customers - Serviced office operators |
We will only process your personal data where we are permitted to do so by applicable law. Under UK/EU data protection law, the use of personal data must be justified under one of a number of legal bases.
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. 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 or text message, provided we have your consent to do so, as outlined in the table 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 in the table below, please contact us at
privacy@theinstantgroup.com| Purpose/Activity | Type of data | Lawful basis for processing (including basis of legitimate interest - EEA, UK, or Switzerland) | Categories of third parties to whom personal data may be disclosed |
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| To invoice you for office space or other services provided by real estate partners | (a) Identity (b) Contact | (a) Necessary for our legitimate interests, ensuring it doesn’t override your rights and freedoms, to invoice on behalf of real estate partners. We only handle invoicing; other payment processing is managed by the partner’s privacy policy. | (a) Real estate partners (b) Customers (c) Service providers |
| To manage our relationship with you, including notifying you of updates or requesting feedback | (a) Identity (b) Contact (c) Profile (d) Communications | (a) Necessary to comply with legal obligations on data protection (b) Necessary for legitimate interests, including keeping records and improving our services. | (a) Service providers |
| To register you as a new customer and complete legally required KYC checks | (a) Identity (b) Contact (c) Financial (d) Inference | Necessary for legitimate interests in processing your request for workspace access, ensuring it doesn’t override your rights and freedoms. | (a) Service providers (b) Affiliated companies (c) Professional advisors |
| To process your inquiry and provide workspace solutions | (a) Identity (b) Contact (c) Transaction (d) Communications | Necessary for legitimate interests in workspace support and communications, as long as it doesn’t override your rights and freedoms. | (a) Real estate agents (b) Real estate partners (c) Advertising and analytics companies |
| To organize office viewings and send reminders of those viewings | (a) Identity (b) Contact | Necessary for legitimate interests in managing viewings and related communications. | (a) Real estate agents (b) Real estate partners (c) Service providers (d) Customers |
| To provide ongoing support during your workspace occupation | (a) Identity (b) Contact | Necessary for legitimate interests in supporting and managing workspace occupation. | (a) Real estate agents (b) Real estate partners (c) Service providers |
| Where you use our platform to view workspace listings | (a) Identity (b) Contact (c) Technical (d) Usage | Necessary for legitimate interests in providing workspace listings and updates. | (a) Real estate agents (b) Real estate partners (c) Customers (d) Service providers |
| To register you as a new customer (including for our Worka platform) and complete anti-money laundering (KYC) checks that are legally required |
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(a) Necessary for our Legitimate Interests, so long as they do not outweigh your rights and freedoms (to deal with your request for workspace) |
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| To process your enquiry and refer flexible workspace solutions to you and introduce you to our real estate partners. We will continue to help you with your workspace search unless and until you tell us otherwise, and facilitate and conclude workspace bookings generally. |
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(a) Necessary for our Legitimate Interests, so long as they do not outweigh your rights and freedoms (to deal with your request for workspace) |
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| To organise office viewings with you by phone and/or email and submit reminders of those viewings to you by SMS |
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To providing ongoing support during your occupation of the flexible workspace including, by phone or email (which may include recording or storing telephone, video, text, or email communications):
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| Where you use our Worka platform, to provide you with workspace listings from our real estate partners which you may select, book and pay for online on-demand, and otherwise manage the Worka platform (including granting access to and managing |
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(a) Necessary for our Legitimate Interests, so long as they do not outweigh your rights and freedoms (to provide the Worka platform and any related services to you) |
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| authorised users of both our customers and partners, and ensuring its operation and availability for business continuity purposes) | |||
| Together with our real estate partners, to invoice you for office space or other services they provide to you. |
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(a) Necessary for our Legitimate Interests, so long as they do not outweigh your rights and freedoms (depending on our arrangement with you, to invoice you on behalf of our real estate partners – in this case, we are only responsible for invoicing and all other payment-related processing of personal data is carried out by the relevant real estate partner and you should consult their privacy policy to learn how they may process your personal data) |
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| 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 about renewals or reminders. |
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(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, so long as they do not outweigh your rights and freedoms (to keep our records updated and to improve products/services we offer) |
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| 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 |
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(a) Necessary for our Legitimate Interests, so long as they do not outweigh your rights and freedoms (where we have a contract with your organisation, to perform or administer our contract) Necessary to comply with a legal obligation to which we are subject under laws relating to anti-money laundering. |
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| To enable you to partake in a prize draw, competition or complete a survey |
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(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) |
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| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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(a) Necessary for our Legitimate Interests, so long as they do not outweigh your rights and freedoms (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation to which we may be subject under laws relating to IT security and payments. |
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| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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(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, so long as they do not outweigh your rights and freedoms (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) |
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| 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 |
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(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, so long as they do not outweigh your rights and freedoms (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) |
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| 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). |
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(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, so long as they do not outweigh your rights and freedoms (to develop our products/services and grow our business) |
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We combine data we collect from different sources for these purposes, and to give you a more seamless, consistent, and personalized experience. And we may use aggregated or de-identified information in accordance with applicable law.
We will only use your personal data where we are permitted to do so by applicable law 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 at privacy@theinstantgroup.com
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 lawful basis set out in the table above, where this is required or permitted by law.
We may disclose your personal data described in section 1 above with the following recipients set out below for the business and commercial purposes set out in the table in section 4 above:-
We require recipients to respect the security of your personal data and to treat it in accordance with the law. After you submit a workspace enquiry to us, we may share your enquiry details (including contact details) with workspace providers and our commercial broker partners in order to provide office search support services to you. Those workspace providers and commercial broker partners may contact you to follow up on your enquiry.
We share your personal data within the Instant 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 privacy@theinstantgroup.com if you would like to see a copy of the specific safeguards applied to the export of your information.
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 Instant 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.
A cookie is a small piece of data (text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preferences or login information as an example. Those cookies are set by us and called first party cookies. We also use third party cookies, which cookies are from a domain different than the domain of the website you are visiting, used to understand usage, improving site features or personalised advertising as an example. You can find out more information about cookies here: http://www.allaboutcookies.org/
More specifically, we use cookies and other tracking technologies for the following purposes:
We use the following types of cookies on our websites:
The remainder of the cookies below are optional, and we require your consent before placing them. The following are not strictly necessary for the operation of this website but are needed to provide you with the best user experience.
When you visit our websites, you can access a detailed list of the cookies we use (with your consent, where required by applicable law) by clicking/selecting “cookie preferences” on the relevant site. Our websites are checked regularly to ensure this list is as accurate as possible.
You can opt-out of each cookie category (except strictly necessary cookies) by clicking/selecting “cookie preferences” on the site or using the following browser or platform controls. If you have any queries or require more information on this, please email privacy@theinstantgroup.com
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 Policy.
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.
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.
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.
You have the following rights (subject to certain conditions in data protection laws and other relevant laws which may apply):
If you are visiting our site or using our products and services from California, please see the California Privacy Rights section below.
f you wish to exercise any of the rights set out above, please contact us at privacy@theinstantgroup.com
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 “Disclosure of Your Information” here), and how long personal data is retained (see section 10 “Data Retention” here). You can find those details in this Policy by selecting the above links.
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 at privacy@theinstantgroup.com
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 at privacy@theinstantgroup.com
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 8 (see link to the Cookies section 8) 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 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.
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.
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.
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.
Any changes we may make to this Policy 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.
Terms and any dispute or claim arising out of or in connection with this Policy (including non-contractual disputes or claims) shall be governed by and construed in accordance with the 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.
If you have any questions regarding this Policy or want to make a request to exercise any of your legal rights (as set out in section 11 above), please contact us by:
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 Information Commissioner’s Office (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 privacy@theinstantgroup.com.
Thank you for visiting our website.
Last edited: November 2023