Last updated 4 December 2018.

This website is owned and operated by Open Space Istanbul Ltd (“Open Space”, “our”, “we”, “us”). We are committed to protecting and respecting your privacy. This privacy policy (“Policy”) sets out the types of personal data we collect and use, and how we may disclose that information.

1. Introduction

This Policy covers our collection, processing and use of personal data when you use our website: http://www.openspacecontemporary.com (the “Website”).

When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it.

It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.

This Policy supplements other notices including our Website Terms and Conditions and our Cookies Policy and is not intended to override or replace them.

By visiting our Website, you agree to its terms (including as amended from time to time) and this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using this Website.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let our registered users and users of the Website know. However, it is your responsibility to check this Policy before each use of the Website – for ease of reference the top of this Policy indicates the date on which it was last updated.

Please note that our Website is not directed at or intended for children under the age of 13 and we do not knowingly collect personal information about children.

2. Who we are

The Website is owned and operated by Open Space Istanbul Ltd. We are a registered company in England and Wales under company number 09173207 and have our registered office at Flat 68, Chelsea Gate Apartments, 93 Ebury Bridge Road, London, Greater London, SW1W 8RB.

The controller responsible for your personal data is Open Space.

3. What information we collect

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully.

Data we collect from you when you use our Website

When you use this Website (by filling in forms, registering to use our Website, subscribing to our service, participating in discussion boards or other social media functions on our Website) contact us by post, telephone, email or SMS, participate in a competition or promotion or report a problem with this Website, we may collect, store and use certain personal information that you disclose to us. The information we collect from you may include (but is not limited to) your title, name, gender, address, e-mail address, telephone number, personal description, business / company name, job history, job title, qualifications and photograph.

We shall also collect information about you when you visit our Website through the use of technologies such as cookies. The following are examples of information we may collect:

  • information about your device, browser or operating system;
  • time zone setting;
  • your IP address;
  • information about links that you click and pages you view on our Website
  • length of visits to certain pages;
  • subjects you viewed or searched for;
  • page response times;
  • records of download errors and/or broken links;
  • page interaction information (such as details of your scrolling, clicks, and mouse-overs);
  • methods used to browse away from the page; and
  • the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).

We use the data described above for several different reasons. Firstly we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.

We also use a third party service (Google Analytics) to help us to collect various data about you and the way that you use the Website in order to enable us to better understand your interests – both so that we can service content to you that we think will be of interest to you, and so that we can ensure that you are shown adverts delivered by third parties which are more likely to be of interest to you. Google is not permitted to use of or attempt to find out the identities of those using our services.

Please note that, while you have the option to consent to specific individual cookies, unless specifically set out in our Cookies Policy, we rely on our legitimate interests as our condition for processing your personal data on the basis set out in this section (specifically that we have a legitimate interest in optimising the Website content and ensuring that you are served with relevant commercial communications as you use them).

Updating your information

If you want to update the information you have previously given to us, you can contact us by email using: info@openspacecontemporary.com.

4. How and why do we use/share your information

How we use your information

Here are some examples about how we may use the information we collect about you:

  • to provide you with a personalised browsing experience when using this Website;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • to provide you with the information, products and services that you request from us;
  • to fulfil any contractual agreements between you and us;
  • to respond to communications from you;
  • to comply with legal and regulatory requirements;
  • to manage any account that you hold with us;
  • to administer our Website and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to ensure that content from this Website is presented in the most effective manner for you and for your computer;
  • to notify you about changes to this Website or our services; and as part of our efforts to keep our Website safe and secure.

Why is Open Space allowed to use your information in this way?

We will only use your personal data in the following circumstances:

  • Where you have asked us to do so, or consented to us doing so;
  • Where we need to do so in order to perform a contract we have entered into with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and / or
  • Where we need to comply with a legal or regulatory obligation.

Sharing your information

Depending on how and why you provide us with your personal data we may share it in the following ways:

  • we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  • with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (see ‘Service Providers’ below); and / or
  • with analytics and search engine providers that assist us in the improvement and optimisation of this Website.

We will not share your information with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition) and you have provided your consent for such use. Such activity will have its own terms and conditions relating to the way in which your information may be used which you will be notified of at the relevant time.

We may also disclose your personal information to third parties in the following events:

  • if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets as part of that sale;
  • if Open Space or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and / or
  • in order to enforce or apply our Website Terms and Conditions or any other terms or agreements entered into with you; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights. A list of our major service providers are available on request,

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information, products and services, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing.

Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about the mechanism via which your personal data is transferred, please contact info@openspacecontemporary.com

Links to third party websites

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We may also provide links to third party websites that are not affiliated with us. Please note that all third party websites are out of our control and are not covered by this Policy. If you access third party websites using the links provided, the operators of these websites may collect information from you that could be used by them in accordance with their own privacy policies. Please check these policies before you submit any personal data to these websites.

5. How long we keep your information

Except if required otherwise by law, we retain your personal data for as long as necessary to fulfil the purposes for which we collect it and also where we have a legitimate interest in doing so, such as:

  • To enable us to respond effectively to grievances that may arise after you cease to engage with us; or
  • Where you sign up to receive email marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request.

You can ask us to access, rectify or, in some circumstances, delete your personal data: see ‘Your Rights’ below for further information.

In some circumstances we may also anonymise your 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.

6. Security

Open Space takes the protection of your information very seriously. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to us via the internet.

7. Cookies

A cookie is a small text file placed on your device when you visit a website. You can accept or decline cookies through your browser settings or other software. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to make improvements.

8. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see Section 4 of this Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

Open Space may process your personal data on the basis of a legitimate interest in the following ways:

  • To enable us to respond effectively to grievances that may arise after you cease to engage with us;
  • To optimise content of our Website;
  • To provide you with relevant commercial communications;
  • Where you sign up to receive email marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

For details on your right to ask us to stop sending you various kinds of communications, please contact us.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

9. Contact Details

If you have any queries regarding this Policy, if you wish to exercise any of your rights

Open Space Istanbul Ltd
[Flat 68
Chelsea Gate Apartments
93 Ebury Bridge Road
London
Greater London
SW1W 8RB]

Alternatively, you can contact us at info@openspacecontemporary.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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