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INTRODUCTION

Third Space is committed to ensuring that there is no modern slavery or human trafficking in our supply chain or any part of our business. We take a zero-tolerance approach to modern slavery and are dedicated to acting ethically and with integrity in all our business dealings and relationships. This statement sets out the actions we have taken to understand all potential modern slavery risks related to our business and to implement measures to ensure there is no slavery or human trafficking in our own business and our supply chain.

OUR BUSINESS

As part of our initiative to identify and mitigate risk, all employees have a role to ensure that we are vigilant with respect to our suppliers and other employees in our business to ensure that no such activities take place. We strongly encourage employees or members to raise any concerns with an appropriate staff member or via our Speak Up / Whistleblowing process.

OUR SUPPLY CHAIN

It is the responsibility of our business leaders that engage with suppliers, to ensure that they are doing all that they can to mitigate the risk of modern slavery and human trafficking across our supply chain.

POLICIES AND PROCEDURES

We have implemented several policies and procedures to mitigate the risk of modern slavery in our business and supply chain. These include:

• Modern Slavery Policy: Our policy outlines our commitment to preventing modern slavery and sets out the expectations for all employees, suppliers, and contractors.
• Employee Code of Conduct: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour
• Whistleblowing / Speak Up Policy: We encourage all employees, suppliers, and contractors to report any concerns related to modern slavery and human trafficking. All reports are treated seriously and investigated promptly.
• Recruitment/Agency workers policy: The majority of our Recruitment is handled by our internal recruitment team, who follow robust processes throughout selection and onboarding. When required, we use only specified, reputable employment agencies to source labour and always verify the practices of any new agency it is using before accepting workers from that agency.
• Employee Training: We have introduced a new, mandatory Modern Slavery Training Module for new starters, within our wider human rights/ethics/ethical trade training programme.

FUTURE ENDEAVOURS

We are continuing to look for ways to improve our existing practices, to ensure that Third Space is doing everything within its power to eradicate Modern Slavery and Human Trafficking practices within its ecosystem, both now and in the future.

Signed,
Colin Waggett
CEO
Third Space Limited
01 / 08 / 2024

Who is responsible for your data?

Our Privacy Notice applies to the personal data that Third Space collects and uses.

References in this Privacy Notice to “Third Space”, “we”, “us” or “our” means Third Space Holdings Limited (a company registered in England and Wales with registration no 05538574 and registered office at 16-19 Canada Square, London E14 5ER) and all its subsidiaries, which includes The Pearson Room (please contact us for a full list). We control the ways your personal data are collected and the purposes for which your personal data are used and are therefore the “data controller” for the purposes of the GDPR 2018, UK Data Protection Act 2018 and any other applicable European data protection legislation.

Please note:  Third Space Medical are NOT part of “Third Space” and have a separate Privacy Notice.  For more information, please contact their DPO: holly.cook@limedicine.co.uk

Categories of data we collect

We may collect and process the following categories of information about you:

Other:

We have partnered with various technologies:  MyZone, Inbody and MyWellness to offer members the opportunity to enhance their training experience.  Use of these services is optional and you are in control of your data via use of the APP (see the service provider’s privacy notice for more information).  Third Space can only view the data you give us permission to and communicate with you via the APP (if permission is given) eg to invite you to join club challenges.

Special categories of personal data 

In the course of providing services to you, we may collect information that is considered “special categories of personal data” eg completion of a health questionnaire prior to a spa treatment. We only collect this information where you have given your explicit consent, it is necessary to protect your vital interests, or you have deliberately made it public. If you do not allow us to process any special category personal data, this may mean we are unable to provide all or parts of the services you have requested from us.

How and why we use your personal data

To fulfil contractual obligations and provide our services to you

Club membership is a contract between Third Space and each individual member, so we require your personal data, photo ID and to take a picture for our database in order to issue you a membership card unique to you, to allow you club access and enable us to verify your identity when necessary.

In the case of spa bookings, we will store information regarding the treatments you have and any special requests in order to tailor your treatments and ensure we are adhering to health and safety and insurance requirements.

To communicate with you and manage our relationship with you

We may need to contact you by email, phone, letter and/or SMS for administrative, customer service or operational reasons, please be aware that these communications are not made for marketing purposes and as such, you will continue to receive them even if you choose not to receive marketing communications.  Examples of these include; changes to pricing structure or unplanned club closures.

We will also use your personal data to contact you after you have visited the club as a guest, made a booking for; a class, our restaurant, or spa, sent us a request, filled in a web-form through our website or contacted us on social media.

Your opinion is very important to us, so we may send you an email or SMS to seek your feedback.

We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our customer and to improve our services and experiences for other members and guests.

Having a named company contact for our suppliers and/or corporate accounts means we can communicate more efficiently with you for payment purposes or with any account queries.  As a named company contact at a company in the vicinity of one of our sites means we can liaise with you directly to negotiate benefits and offers exclusive to your employees and keep track of any negotiations.

If you attempt to join online or make a booking, then you leave our website before this has been finalised, we may contact you in order to help you easily complete your transaction.

To personalise and improve your customer experience

We may also collect information on how you use our website, which pages of our website you visit most, which classes you attend/book and what services you use/purchase, in order to understand what you like. We may use this information to tailor the content and offers that you see on our website and to send you relevant messages that we think you might like.

To raise awareness and enable you to share your achievements with others, we post photos and/or videos on social media, of any special events or challenges that we organise.  Please be aware that if you take part, you may be included in these.

To inform you about our news and offers that you may like

As part of our service, we will email you with club news and offers that we have negotiated for our members and guests.  If you do not wish to receive this additional information, you can; opt out at point of sale, visit the member area and amend your mailing preferences at www.thirdspace.london, choose the ‘opt out/unsubscribe’ option present on our email, reply STOP or UNSUBSCRIBE to any email/text contact.

As a previous member, we may contact you up to 24 months after your membership end date, if we have a re- joining offer exclusive to previous members.

If you have not made a purchase from us, we will only contact you via SMS/email/phone with updates, such as; offers and events IF you have consented to this (with the exception of direct response to a query). You can ‘unconsent’ to contact at any time choosing the ‘opt out/unsubscribe’ option present on our email, reply STOP or UNSUBSCRIBE to any email/text contact.

To improve our services, for administration purposes and to protect our business interests 

The business purposes for which we will use your information include accounting, budgeting, billing and audit, credit or other payment card verification, safety, security, statistical and marketing/profiling analysis, systems testing, maintenance, ordering of supplies, planning and development.

To comply with any other legal obligations.

*Other – CCTV & Thermal Imaging cameras

Third Space have CCTV installed in public areas (not changing areas).  Recordings are stored on a secure server for a maximum of 2 months for the purpose of security.  Third Space also operates underwater CCTV in our pools.  An alarm will sound at concierge if lack of movement is monitored whereby a live feed on screen (close sight only) can be viewed at concierge – our lawful basis for this processing is; to protect the vital interests of users, along with personal protection purposes.  Underwater CCTV footage will be stored for 2 weeks on a password protected local hard drive, kept on site in a locked cabinet.  Pool side signage will be introduced when CCTV commences operation. Third Space also operates thermal imaging cameras at the entrance of the club. These will check a visitors body temperature and sound an alarm if a high temperature is detected – our lawful basis for this processing is to; protect the vital interests of our users, along with personal health protection purposes. Thermal imaging data will be stored for 30 days on a password protected central server.

Sharing your personal data

Your personal data may be shared with other companies within our Group. It may also be disclosed to a third party who acquires us, acquires a member of our Group or substantially all of our assets.

We may also share some of your personal data with, or obtain your personal data from, the following categories of third parties:

• Your employer or health club benefits provider, if your membership is via a corporate scheme and Third Space invoice them for your membership subscriptions.
• An individual who pays for your membership on your behalf – to administer your membership on an ongoing basis
• Postal or digital mailing company/app – to send out communication to you on our behalf.
• Specialist survey company/app – to send out surveys to you on our behalf (you are not obliged to respond to them).
• Internal independent service providers eg Golf Lab, Spa Therapist or Third Space Medical – so, on your request, they can provide their services to you.
• Bank/credit or debit card companies – in order to process your payments for services.
• Credit control company – with prior notification, should contracted membership subscriptions or payment for goods or services become overdue (as per our T&C’s).
• Web servers/website providers – hosting/storing some personal data.
• IT support company – able to access some information to assist with IT issues.
• Table/spa booking websites – our restaurant (The Pearson Room) and/or spa are passed your details if you book a table or treatment via their website
• Social media site – hashed email matched to account to create custom audience file
• Till and booking apps
• Profiling company – some of your data may be temporarily shared to ensure relevance of marketing communication and profiling to enhance our targeting

In addition to the categories of recipient listed above, we may disclose your personal data when this is required by the law of any jurisdiction to which Third Space may be subject.

Child Membership (available Islington only) – we collect a child’s personal data from an adult member with parental responsibility for them.  We will assume all members linked to the child’s head member (parent paying for the memberships) are permitted access to the information on the child’s membership account; details of the child’s membership subscription, any ancillary services eg swim school, visits, DOB and contact details (as per head member account), plus any non-sensitive notes.  A child registration form must be completed for each child, which contains health questions and any special requirements.  The child registration forms are stored on a secure server on site, with limited access rights – a symbol on the membership account will denote if the Little Space team need to access information on this server prior to the child taking part in any activities.  Any other sensitive documents such as care plans or accident reports, will be stored in the same access controlled area. Our Little Space crèche is operated by Tinies.  As an OFSTED registered childcare provider, they may be required to process crèche user’s data that Third Space do not need sight of, for instance; safeguarding paperwork.  Please see Tinies Privacy Notice for information on how this data is processed and why. We will not take your child’s email address or attempt to contact child members directly.

Data transferred outside the EU

Some of the companies we use for our apps are situated in third countries; therefore some data may be transferred to countries outside the European Economic Area (EEA).  Transfers of data to these companies are either on the basis of adequacy, or subject to appropriate safeguards.

Security of your personal data

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data.

As described in this Privacy Notice, we may in some instances disclose your personal data to third parties. Where Third Space discloses your personal data to a third party, we require them to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, over which we have limited control.

Cookies

We use cookies when you visit our site. By using our site, you agree to us placing these sorts of cookies on your device and accessing them when you visit the site in the future.  If you do not agree to our use of cookies in this way, you should set your browser settings accordingly or not use the Third Space site. If you disable the cookies that we use, this may impact your user experience while on the Third Space site.

There are three main types of cookies – here’s how and why we use them.

• Site functionality cookies – these cookies allow you to navigate the site and use our features, such as the member’s area.
• Site analytics/performance cookies* – these cookies allow us to measure and analyse how our visitors use the site, to improve both its functionality and your experience. These cookies don’t identify you as an individual.

*One of the type (2) cookies we use is ‘Hotjar’.  We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

• Marketing cookies* – used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.

*The marketing cookies we use on the Third Space website are; Facebook and Google. Facebook marketing cookies on our site let Facebook know that you have visited the Third Space website; this allows Facebook to match your user info to your Facebook account (where applicable) and allow targeted advertising from Third Space.   We also use our Facebook cookies to review how our generic adverts on Facebook are performing – to log a user reaching our website via clicking on a Third Space advert on Facebook.  As well as Facebook, we use Google AdWords to re-engage visitors that are likely to convert to members based on online behaviour across websites.

If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies.

Further information about cookies can be found at https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/.

Please note that by deleting or disabling future cookies, your user experience may be affected and you might not be able to take advantage of certain functions of our site, and the complete Third Space web experience

We may occasionally include links to third party websites on our emails and/or website.  We do not take any responsibility for these sites, the cookies they use or how they manage any data you may provide to them.

Retention Period

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for example to comply with retention obligations e.g. under tax or contract law. You can request deletion of your personal data at any time (see the section below on your right to erasure).

Your rights

Your rights are as follows (noting that these rights don’t apply in all circumstances):

• The right to request access to your personal data and information about how we process it
• The right to rectification – we will correct your personal data if it’s inaccurate and complete any incomplete personal data. It is your responsibility to ensure that you submit true, accurate and complete information to us.  You have the ability to change certain information via your online account (such as email and address).
• The right to erasure – you have the right to request that we delete personal data that we hold about you.
• The right to restrict processing
• The right to object to processing – if you would like us to stop processing your personal data, you can do this in a number of ways; you can visit the member area and amend your mailing preferences thirdspace.london, you can choose the ‘opt out/unsubscribe’ option if present on our email, you can reply STOP or UNSUBSCRIBE to any email/text contact, you can advise a team member if they call, or you can email data@thirdspace.london
• The right to Data Portability – move, copy or transfer your personal data

.Updates to our Privacy Notice

We may update this Privacy Notice to reflect changes to our information practices or in line with new legislation. We encourage you to periodically review the Privacy Notice on our website for the latest information on our privacy practices.

Contacting Third Space

If you have any questions or concerns about this Privacy Notice, or the way Third Space are processing your data, or would like to exercise your rights in relation to your personal data, please contact our Data Privacy Manager at data@thirdspace.london or write to us at: Third Space, 16-19 Canada Square, London E14 5ER.

If you have a complaint or concern about how we are processing your personal information then we will endeavor to address such concern(s). However, if you would like to direct your complaint/concerns to a Data Protection Authority, the contact details for your local Data Protection Authority are as follows: https://ico.org.uk/global/contact-us/.