SureSpace Privacy Notice

Introduction

Welcome to SureSpace’s Privacy Notice. This Privacy Notice tells you everything you need to know about how we collect, use, and disclose your “Personal Data” when you interact with us, whether through our website, application, or otherwise.

What key information do you need to know about us?

Our legal entity name is My NDPA Ltd, incorporated in England & Wales (registration number 15615720), with the registered address of 2-4 Petworth Road, Haslemere, England, GU27 2HR.
We are registered with the Information Commissioner’s Office (“ICO”), the data protection supervisory authority in England & Wales. Our ICO registration reference is C1477764.
As a Data Controller, we are responsible for protecting your privacy and rights and ensuring compliance with Data Protection Laws.

What key data protection terms do you need to know?

To help you understand this Privacy Notice, we’ve provided a glossary of key terms below:
Consent: Freely given, specific, informed, and unambiguous agreement to the processing of Personal Data.
Data Controller: An organization responsible for deciding how and why Personal Data is processed.
Data Processor: An organization that processes Personal Data on behalf of a Data Controller.
Personal Data: Information relating to an individual that can identify them, directly or indirectly.
Processing: Any operation involving Personal Data, such as collecting, using, or sharing.
Special Category Data: Data revealing racial or ethnic origin, religious beliefs, health data, or similar sensitive information.

What does our data protection compliance program look like?

We have established a robust data protection compliance program, including policies, procedures, and technical security controls, to ensure adherence to Data Protection Laws.
Our key principles:
We only process Personal Data lawfully, fairly, and transparently.
We collect Personal Data only as necessary and keep it accurate and up to date.
We protect Personal Data using appropriate technical and organizational measures.

Do we have a data protection officer?

At this stage, we are not required to appoint a data protection officer because we do not engage in large-scale processing of Personal Data or conduct regular, systemic monitoring of individuals. However, we regularly review this determination and remain committed to protecting your data.

What types of Personal Data do we collect?

Depending on your relationship with us, we collect various types of Personal Data, including:
Identity Data: First name, last name, date of birth, etc.
Contact Data: Phone number, email address, etc.
Profile Data: Information about your background and preferences.
Transaction & Financial Data: Payment details.
Technical & Usage Data: IP address, browser type, and interactions with our website or application.
We may also aggregate data (such as statistical data) for analysis and research purposes. Aggregated data is not considered Personal Data as it does not identify you directly.

Cookies and Tracking Technology

We use cookies and other tracking technologies to enhance your experience on SureSpace. Cookies help us understand how you interact with our website, improve functionality, and personalize content.
Types of Cookies: We use functional, analytical, and advertising cookies. Functional cookies ensure our platform operates smoothly, while analytical cookies help us monitor and improve performance. Advertising cookies may be used to deliver relevant ads.
Managing Cookies: You can manage your cookie preferences through your browser settings or the cookie banner on our website. For more information, see our [Cookies Policy].

Do we use artificial intelligence (AI)?

SureSpace uses Artificial Intelligence (AI) to enhance your creative experience, such as generating art or assisting in content creation. AI-driven features process input data, such as text or images, to deliver relevant outputs.
AI Data Processing: We only process data necessary for AI functionality. No significant automated decision-making or profiling is used that would affect your legal rights.
Opting Out: Users may opt-out of AI-driven features by adjusting their account settings if they choose not to use AI tools for content creation.

How do we retain and manage AI-generated content?

Any AI-generated content you create on SureSpace will be retained according to our general data retention policy. If you delete your account, AI-generated content may also be deleted unless anonymized for research purposes.

What are the lawful grounds for which we process Personal Data?

We rely on several lawful grounds for processing your Personal Data:
Consent: When you explicitly agree to the processing.
Contract: When processing is necessary to fulfill a contract with you.
Legal obligation: When required by law.
Legitimate interests: When processing is necessary for our business interests without overriding your rights.

What are the categories of Data Subjects that we engage with?

We engage with the following categories of Data Subjects:
Prospective and existing SureSpace users (18 years and older)
Prospective employees
Third-party suppliers and contractors

Who do we share your Personal Data with?

We share Personal Data only when necessary and with specific categories of third parties, including:
Technology companies: For software and platform support.
Professional advisers: Such as law firms, banks, and accountants.
Governmental agencies: To meet legal and regulatory obligations.

How do we protect your Personal Data?

We have implemented strong security measures, including encryption, to protect your Personal Data from unauthorized access, loss, or disclosure. Access to your data is restricted to authorized personnel, and we ensure that our third-party partners comply with similar security standards.
Additionally, in the event of a data breach, we will notify the ICO and affected individuals within 72 hours, as required by law. We will inform you about the nature of the breach, the potential impact, and steps taken to mitigate any risks.

Do we transfer your Personal Data outside of the UK and/or EEA?

We ensure that Personal Data transferred outside of the UK and/or EEA is protected by implementing the following safeguards:
We use Standard Contractual Clauses to ensure your Personal Data receives the same level of protection.
We transfer Personal Data only to countries with adequate data protection standards as recognized by the ICO or European Commission.

How long do we keep your Personal Data?

We retain your Personal Data only as long as necessary for the purposes for which it was collected, including compliance with legal obligations. In the case of litigation or ongoing legal obligations, we may retain your data for an extended period.

What rights do you have regarding your Personal Data?

You have several rights concerning your Personal Data, including:
Right to access: Request copies of your data.
Right to rectification: Request corrections to inaccurate data.
Right to erasure: Request deletion of your data in specific situations.
Right to restrict processing: Limit how we use your data.
Right to object: Object to data processing in specific circumstances.
Right to data portability: Request transfer of your data to another controller.
If you wish to exercise any of these rights, contact us at [email protected].

How do we use your Personal Data in marketing?

We may use your Identity, Contact, Profile, and Technical & Usage Data to offer tailored marketing communications, provided you have not opted out. You may withdraw your consent for marketing communications at any time by contacting us.

Third-Party Processors

SureSpace may use third-party service providers (processors) for activities such as payment processing, cloud storage, and support services. All third-party processors comply with data protection standards and are contractually obligated to ensure your data’s safety.

Intellectual Property and User-Generated Content

When you generate or upload content (including AI-generated content), you retain ownership of your intellectual property. However, by using SureSpace, you grant us a license to use, distribute, and display your content on the platform as necessary to provide our services. We ensure all user-generated content is treated in accordance with our privacy practices and protected from unauthorized access.

Do you have any questions or concerns?

By using SureSpace, you agree to the practices outlined in this Privacy Notice. If you have any questions or concerns, feel free to contact us at [email protected].