Privacy Policy

SPASSIO – WEBSITE PRIVACY POLICY

 

WHO WE ARE

We are HAKAMA Ltd (company number 14015397), trading under the business name Spassio, and our address is 20-22 Wenlock Road, N1 7GU London, United Kingdom (referred to as “we” or “us” or “our”). We are the providers of the website www.spassio.com (referred to as the “Site”). We provide this Site for our members so that they can advertise prefabricated homes online. “Our members” are manufacturers of prefabricated homes. We are not a manufacturer of prefabricated homes. A reference to “you” or “your” is a reference to a user of the Site or any of our services.

INTRODUCTION

We are committed to protecting your privacy. This privacy policy explains how and for what purposes we use the information collected about you. Please read this privacy policy carefully. If you have a query about information relating to a prefabricated home on the Site, please contact the manufacturer directly, or alternatively contact us on info@spassio.com.

CONTACTING US

If you would like to stop receiving marketing and communications from us please contact the Customer Services Team at support@spassio.com. If you have any questions about this privacy policy or our use of your personal information or would like to submit a subject access request or exercise your other data subject rights, please contact us via email at support@spassio.com or please write to HAKAMA Ltd, 20-22 Wenlock Road, N1 7GU London, United Kingdom.

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
1. PREFABRICATED HOMES ADVERTISED ON THE SITE
1.1. What we collect and where it comes from

In the course of providing our services, we collect property data such as images, prices, locations and descriptions of prefabricated homes. This data is provided to us by our members or other third parties on behalf of those members.

1.2 Why we collect it
  • To provide the www.spassio.com Site;
  • To enable our members to advertise their prefabricated homes to the largest online audience available;
  • To enable potential purchasers to see detailed descriptions and images of prefabricated homes that they may be interested in;
  • For our own commercial purposes such as to identify trends in the prefabricated homes market, and to build prefabricated homes databases.
1.3 Our lawful basis for processing this personal data

We have a legitimate interest to process this information. These legitimate interests are:

  • Providing a service to our members by helping them market prefabricated homes;
  • Providing a service to our members by advertising prefabricated homes to potential purchasers;
  • Providing a service to potential purchasers so that they know what prefabricated homes are currently on the market and the price of those homes;
1.4 How long we will keep it for

We will stop advertising a prefabricated home when we are instructed to do so by our members.

2. ENQUIRIES TO OUR MEMBERS
2.1 What we collect and where it comes from

if you choose to access a particular search feature or to fill in a form on the Site you may be asked to provide information about yourself, such as:

  • Your name and contact details
  • Details of the sort of prefabricated home you are interested in
  • The cost and specifications of the prefabricated home, and
  • The country where you want the prefabricated home to be delivered.

If you choose to contact us or a member using the member telephone number on Site, calls may be recorded for training and monitoring purposes. We may also keep a record of call activity, including missed calls.

2.Why we collect it

To make sure that you receive the benefit of the Spassio service. This may include:

  • Transferring your enquiry to our member advertising that prefabricated home so that they can respond to your enquiry. Some of our members may use lead handling agencies who handle and process your enquiry on their behalf; or
  • Sending your request to book a show-house viewing to our member advertising that prefabricated home and for us to confirm your booking by email or text on our member’s behalf;
  • Transferring other relevant information to our member so that they can assess whether the prefabricated home is suitable for you; and
  • Allowing you to provide our member with feedback on the prefabricated home once you have viewed it;
  • For training and monitoring purposes where calls are recorded;
  • To profile your lead activity on our Site or telephone calls to our Members to enhance the service you receive from our Members. If you want to know more about this, see “Lead Profiling” below.
2.3 Our lawful basis for processing this personal data

To provide a service to our members and/or to provide a service to you.

2.4 How long we will keep this data for

All enquiry data will be kept for two years from the date on which you last used our Site or our services. After that it will be erased or anonymised so that the data no longer identifies you.

Telephone call recordings are stored for a shorter period of time, being three months from the date of the recording, at which point they are deleted.

Profiling data will be kept for a shorter time period, as described in “Lead Profiling” below.

3. REGISTERED USERS AND SAVED SEARCHES ALERTS
3.1 What we collect and where it comes from

Information that you provide to us when you register as a Spassio user and/or request email updates such as Email Alerts about when a prefabricated home is placed on the market and meets your search parameters.

3.2 Why we collect it
  • To provide you with the benefit of services for registered users only;
  • To provide Email Alerts to you of new prefabricated homes marketed on our Site that meet your search criteria;
3.3 Our lawful basis for processing this personal data

To provide you with our services.

3.4 How long we will keep it for

Information that you provide to us when you register as a Spassio user will be kept for as long as you have an account setup on our Site. The personal data relating to your account will be deleted when you delete your account.

4. GENERAL SITE USE
4.1 What we collect and where it comes from

Information that you provide when participating in discussion boards or other social media functions on our Site and enter into competitions, promotions or surveys available on the site.

4.2 Why we collect it
  • To provide the Site to you;
  • To enhance the services that you select on our Site;
  • To process any queries that you have about Spassio or its members;
  • To customise and enrich your experience on our Site;
  • To contact you for your views on our services and to notify you occasionally about important changes to our Terms of Use or this privacy policy or developments to this Site or our services;
  • To deliver relevant advertising to you whilst you are on the Site;
4.3 Our lawful basis for processing this personal data

To gain information about the use of our Site and any improvements that can be made as well as providing advertising space to our members and third parties.

4.4 How long we will keep it for

Information that you provide when participating in discussion boards, enter into competitions, promotions or surveys will be retained for two years.

Information that is provided when you interact with us through social media functions will only be retained on the social media platforms which you use to contact us – we will not copy or store it separately. This data will be retained for as long as you keep it on your social media accounts.

5. COMMUNICATIONS
5.1 What we collect and where it comes from

Information that you provide to us by corresponding with us by phone, e-mail or otherwise.

5.2 Why we collect it

To process and resolve any queries that you may have.

5.3 Our lawful basis for processing this personal data

To ensure that your queries are addressed.

5.4 How long we will keep it for

Information that you provide to us by corresponding with us by phone, e-mail or otherwise will be retained for the later of 18 months from the date of communication or until your query is resolved.

6. INFORMATION WE RECEIVE FROM THIRD PARTIES (OTHER THAN OUR MEMBERS)
6.1 What we collect and where it comes from

We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you, when we collected the data, that it may be shared internally and combined with data collected on this Site.

6.2 Why we collect it
  • To allow you to participate in the interactive services available on our Site or to participate in competitions or promotions via our Site;
  • To pass your searches and messages on to our members to help them communicate with you directly and to provide a more personalised service to you. This may include contacting you about other relevant prefabricated house models, adding you to their enquiry database for future contact and offering you their additional services;
  • To provide services and information to our members, which they can use to benchmark their performance;
  • To customise and enrich your experience on our Site; and
  • To contact you for your views on our services and to notify you occasionally about important changes to our Terms of Use or this privacy policy or developments to this Site or our services.
6.3 Our lawful basis for processing this personal data

We have a legitimate business interest to process this information. These legitimate interests are:

  • Enhancing the service that you receive on the Site;
  • To provide a service to our members so they can respond to enquiries; and
  • Providing information necessary to enable us to provide a competitive, cost effective services.
6.4 How long we will keep it for

We will store this personal data for two years from the date on which you last used our Site or Services at which point it will be erased or anonymised so that the data no longer identifies you.

7. INFORMATION WE COLLECT ABOUT YOU
7.1 What we collect and where it comes from

This is different to the information you give us, because it relates to technical data that we collect. We may:

  • Collect technical information that has the potential to identify you, such as the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Collect information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page; and
  • We may combine technical information with other information that we have about you to help us with our processing of your information as set out in this privacy policy.
7.2 Why we collect it
  • To provide the Site to you;
  • To conduct reviews that assist us in the improvement and optimisation of our Site;
  • To ensure that content from our Site is presented in the most effective manner for you and for your device;
  • To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • As part of our efforts to keep our Site safe and secure; and
  • To customise and enrich your experience on our Site.
7.3 Our lawful basis for processing this personal data

We have a legitimate interest to process this information. These legitimate interests are:

  • To help ensure the on-going security of the Site;
  • Enhancing the service that you receive on the Site; and
  • Providing information necessary to enable us to provide a competitive, cost effective services.
7.4 How long we will keep it for

We will store this personal data for two years in order to allow us to review and monitor normal traffic patterns and trends on Site. After two years this data will be kept in an anonymous form.

LEAD PROFILING

We may from time to time profile your activity when using our services or our Site. This profiling is limited in its scope to telephone and email enquiries you send to our members. It only takes place to help us and our members understand what sort of prefabricated homes you may be interested in, and to categorise your activity to help us and our members determine how likely you are to require services from our members. Members may then contact you to offer their services, although they can only do so if they have a lawful reason to do so (known as a lawful basis of processing your personal data). You can always object to our profiling by emailing us here support@spassio.com. Any profiling data that we hold about you will only be kept for a period of 12 months from the date of the last telephone or email you have sent to a member of our Site.

USE OF YOUR DATA FOR MARKETING AND COMMUNICATIONS

Sometimes we may use your personal information to provide marketing messages to you. You can opt out of marketing and other communications at any time by contacting support@spassio.com. You can always make use of the Site without having to agree to marketing. The types of things that we may do include:

  • Providing direct marketing advertisements and communications to you via email, text, post or telephone;
  • Making suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them;
  • Communicating with you on third party social media platforms; and
  • Monitoring the effectiveness of our direct marketing communications and your responses to it.
REMOVING DATA FROM THE SITE

If you have any concerns about the data of a prefabricated home displayed on the Site, please contact us at support@spassio.com and we will endeavour to resolve the issue promptly.

WHO HAS ACCESS TO YOUR PERSONAL DATA?

We retain access to all personal information that we have collected from you or about you. Once your information has been passed to one of our members in the course of providing our services then that member will have a copy of the information that you have provided within your enquiry and your contact details which they will use to get in touch with you. Our members (or any third party that acts on their behalf) will be responsible for information in their possession and that information will be subject to any privacy terms or policies that the member has in place; we are not responsible for use (or misuse) of your information by any of our members.

When our service is available via the websites of our partners, those partners may have access to your information. We may also have links to other websites from our Site. We are not responsible for the content, security, privacy policies and practices of any other websites, even if you access them using links from this Site or if you can access this Site or use our services from them. We recommend that you check the privacy policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.

If our business is sold or merged, or if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. We will make sure that any such transfer is done in a secure way.

If we offer or supply a service to you that is provided on our behalf by a third party we may have to pass your information to them in order to deliver the service. The categories of third parties (who are acting as a data processors) include: telephone call recording and our support ticketing systems. We may also use third parties to provide services on our behalf which may include processing (but not using themselves) your information e.g. to complete partial addresses or to augment the information we hold about you. In either case, we will not pass your information to anyone who is not also subject to adequate privacy commitments in our contract with them.

We will not otherwise disclose, sell or distribute your information to any third party without your permission unless we are required to do so by law or to obtain professional advice.

WHERE DO WE STORE YOUR PERSONAL DATA?

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We follow strict security procedures to ensure that your personal information is not damaged, destroyed or disclosed to a third party without your permission and to prevent unauthorised access to it. Only employees who need access to your information to perform a specific job are granted access to personally identifiable information. We may require you to co-operate with our security checks before we disclose information to you. If you are a registered user, you can update the personal information that you give us at any time by viewing your account page.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

YOUR RIGHTS

You have the right to ask us not to process your personal data at any time.

You have the right to use our Site without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We always use the most recently submitted form to be your current consent status. If you are a registered user, but not signed in when you submit a form, we will not be able to use your saved settings so will deem your consent choice to be as per the form you submit at the time. You can exercise your right to prevent such processing by selecting the specific options in the fields or forms when you become a registered user.

You have a right to request access to or rectification of your personal data which we hold about you. You also have a right to erase your personal data, to restrict the processing of your personal data and the right to receive your personal data that you have provided to us, the right to object to our processing of your personal data and a right to request that we transmit your personal data to another data controller.

Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact the Data Protection Officer whose contact details are provided earlier in this privacy policy.

You have the right to complain to the Information Commissioner’s Office if you feel unhappy with the way we process your data. Please visit www.ico.org.uk for more information.

COOKIES AND TRACKING

Like many websites, we use “cookies” to enable us to personalise your visits to our Site, simplify the signing-in procedure, keep track of your preferences and to track the usage of our Site.

CHANGES TO THIS PRIVACY POLICY

Any changes we may make to this privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this privacy policy.

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