Level39 Privacy Notice

1. Introduction

Our Privacy Notice describes how we collect and process your Personal Data through our License Agreement, at events, on site and via our digital assets.

In order to comply with the requirements of the European General Data Protection Regulation (GDPR), this Privacy Notice outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

We are Level39, wholly owned by Canary Wharf Group Plc. We support fast-growth tech companies in three clear ways – giving access to world-class customers, talent and infrastructure.

2. Information About Your Personal Data

This Privacy Notice relates to data about you, and your interaction with our services.

Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, certain cookie and network identifiers, passport details and utility bills.

Level39 collects, uses, discloses and processes Personal Data as outlined in this Privacy Notice, including to operate and improve the services and our business; for advertising and marketing; and to provide you with information on events and our ecosystem activity, as further described in this Privacy Notice.

3. How We Collect and Use Personal Data

We collect your Personal Data in a number of ways and for various purposes, including:

  1. When you enrol as a member or to access some of our services or events, you will be requested to provide us with details which can include your name, telephone number, email address, postal address and where applicable, passport details / ID card, your photograph, utility bills, company or organisation name.
  2. We collect billing and payment information you provide when you access some of our services. We also collect information that you provide us when you participate in our events.
  3. We collect Personal Data when you communicate with us or if you sign up to receive promotional materials or information via email, – including email address, mobile number etc. If you sign up to such messages, we may use your Personal Data and other information to communicate with you about the Level39 services you have used; provide you with promotional messages and personalised advertising; to notify you of other services, events and other promotions (“Promotions“); to notify you of services we think may be of interest to you; and, for other marketing purposes. You can manage your marketing preferences by opting out at any time by writing to us at privacy@level39.co
  4. If you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by Level39 at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.
  5. We may also receive information about you from publicly and commercially available sources and other third parties as permitted by law.
  6. If you are a visitor on our premises your name and email address may be added to our visitor management systems.
  7. We use the personal information that we collect as necessary and appropriate for the following purposes:
  • To provide our products and services. We use your personal information to provide you with the products, services, and features that you or your company have requested; to respond to inquiries we receive from you or your company; to verify your identity and in connection with a transaction that you or your company has initiated.
  • To improve our products and services and to analyse how members navigate and use our products and services and individual features.
  • To manage the performance of our products and services.
  • For audit and reporting purposes, to perform accounting and administrative tasks, and to enforce or manage legal claims.
  • To deliver advertising and promotional communications, which may be subject to your consent, which we will seek at the appropriate time.
  • For security and to protect, enforce, or defend legal rights, privacy, safety or property, whether our own or that of our employees or agents or others, and to enforce compliance with Level39 policies and to comply with applicable law and government requests.

4. How We Disclose Personal Data

We may disclose your Personal Data to the following parties and in the following ways:

  1. To Affiliates and Partners; with companies or ventures that are owned or controlled by Canary Wharf Group Plc, and internally within Level39, in order to provide and improve services, for marketing purposes, and for advertising.
  2. To service providers. We rely on third-party service providers to perform a variety of services on our behalf. For example, we may rely on service providers to host data, process payment transactions and analyse data to improve our services. To do so, we may need to share your personal information with them.
  3. Our Community. Our Services include member communities, ecosystem activity, forums and networks that allow you to share and connect with others. We make this possible for Level39 members by creating a profile for new members that contains your name and the name of your company or other organisation. This profile is created automatically and is accessible to other members of the forum or network, some of which include all Level39 members. You can supplement your profile by adding additional information about yourself and your company or organisation and by posting content and comments and you may be able to share your profile with a broader audience.
  4. Other parties when required by law and as necessary to provide and protect our services. We will disclose your personal information to an acquirer in the event we sell or transfer all or a portion of a business or assets to that third party, such as in connection with a merger or in the event of a bankruptcy reorganisation or liquidation.
  5. We may request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.

5. Legal Basis for Processing

We collect and process your Personal Data for a variety of purposes outlined in this Privacy Notice. In certain cases, separate consent is not required, including:

  1. For the performance of a contract: To perform our contractual obligations to you, including member registration, where we need to provide your Personal Data to companies that are owned or controlled by Canary Wharf Group Plc and to our service providers, where we need to collect Personal Data from third party sources and when you access third party products and services, where we collect data from third parties or publicly-available sources.
  2. To meet legal obligations.
  3. For Legitimate Interests: to send you marketing and promotional messages in relation to services similar to those we have previously provided to you.  You can ask us at any time to take you off our mailing lists and we will not send you any more marketing communications

6. Consent as a Basis for Processing

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our services or a form (including enrolling in Promotions); or (ii) registering or creating a member account with us.

We may occasionally ask for your consent to contact you about other offers, products, Promotions, events, or services that we think may be of interest to you and for other marketing purposes.

We may also ask for your consent to share your Personal Data with certain Third Party business partners in order to offer certain goods, services, or programs. To withdraw consent, please contact us at privacy@level39.co

7. Information Security and Transfer of Data

Level39 is committed to being transparent and taking all reasonable and appropriate steps to keeping your personal information secure and to protect it from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures.

It may be necessary to transfer your data to suppliers/service providers where we rely on storage, system and administrative support from outside the European Economic Area therefore the processing of your data may involve a transfer of data to countries outside of the United Kingdom.

We take all reasonable steps to ensure that your personal data is processed securely. We will only transfer personal information outside the EEA where it is compliant with applicable data protection legislation and the means of transfer provides adequate safeguards in relation to your personal information.

8. Data Retention

We will retain your Personal Data for as long as you are a member with us or as otherwise necessary to provide you the services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Some data may also be stored longer than the stated retention period for the purposes of business continuity.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Notice, we will delete your Personal Data from our systems.

9. Your rights

To exercise your privacy rights please send your request in writing. We may be required to verify your identity for security purposes. Your rights are outlined below:

  • The right to access information we hold about you, why we have that information, who has access to the information and where we obtained the information from.
  • The right to correct and update the information we hold about you. If the data we hold about you is out of date, incomplete or incorrect you can inform us and your data will be updated.
  • The right to have your information erased. If you feel we should no longer be using your data you can request that we erase the data that we hold. Upon receiving a request for erasure we will confirm whether it has been deleted or a reason why it cannot be deleted (for example because we have a legal obligation to keep the information or we need it for a legitimate business interest).
  • The right to object to processing of your data. You may request that we stop processing information about you. Upon receiving your request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or bring or defend legal claims.
  • The right to data portability. You have the right to request that we transfer your data to another controller.
  • The right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • The right to withdraw consent at any time where we are relying on consent to process your personal data.

We will comply with your request where it is feasible to do so, within 30 days of receiving your request.  There are no fees or charges for the first request.  However additional requests for the same data may be subject to an administrative fee of £25 per request.

To exercise your rights please do so by writing to:

Data Protection, Level 30, One Canada Square, Canary Wharf, London E14 5AB.

Or e-mail DataProtection@canarywharf.com

10. Use of Cookies

Level39 utilises cookies to enhance your browsing experience on Level39’s website. Details can be found in Level39’s Cookies Policy available here http://www.level39.co/cookie-policy/

11. Complaints process

At Level39 we aim to ensure all information collected about you is done so fairly and lawfully, whilst implementing robust measures to keep your information secure. If you are not satisfied with the information provided in this policy, please contact us in the first instance so we can resolve your queries or provide you with any additional information required.

Alternatively it is your right to contact your local Data Protection Authority and lodge a complaint. In the UK the lead Data Protection Authority is the Information Commissioner. For more information please visit the Information Commissioner’s office at www.ico.org.uk/concerns  or call them on 0303 123 1113