Combined Legal Document for FlexiSpirit Ltd

 

Terms of Service, Privacy Policy & Cookie Policy

THE SITE AND SERVICES ARE INTENDED SOLELY FOR PERSONS WHO ARE 18 YEARS OF AGE OR OLDER AND ONLY FOR MERCHANTS. ANY USE OF THE SITE OR SERVICES BY ANYONE UNDER THE AGE OF 18 AND WHO IS NOT A MERCHANT IS EXPRESSLY PROHIBITED. UPON CREATING AN ACCOUNT OR SUBMITTING A BOOKING YOU REPRESENT AND WARRANT THAT YOU ARE 18 YEARS OF AGE OR OLDER AND THAT YOU ARE A MERCHANT.

PLEASE READ THESE TERMS OF SERVICE, PRIVACY POLICY, AND COOKIE POLICY CAREFULLY AS THEY CONTAIN IMPORTANT INFORMATION REGARDING YOUR RIGHTS AND OBLIGATIONS. SERVICES IN TERMS HEREOF ARE SUBJECT TO THE LIMITATIONS AND EXCLUSIONS STATED HEREIN.

Last Updated: 23 Oct 2023

PART I: TERMS OF SERVICE

1. General

www.flexispirit.com is a registered web domain of FlexiSpirit Ltd, a company incorporated in England and Wales under company number 14393966, with its registered office at 66 Potter Crescent, Wokingham, England, RG41 1AN.

FlexiSpirit Ltd shall hereinafter be referred to as “FlexiSpirit”, “we”, “us”, or “our”.

FlexiSpirit provides an online platform that offers temporary bookings which are accessible at www.flexispirit.com (the “Site”).

You agree to comply with and be legally bound by the terms and conditions of these terms (“Terms”), whether or not you become a registered Member. FlexiSpirit reserves all rights in respect of access to and use of the Site and all Content. Please also read our Privacy Policy (Part II) and Cookie Policy (Part III) of this document carefully.

2. Key Terms

• “Agreement” means the booking agreement between FlexiSpirit and you as a Booker, as determined by FlexiSpirit’s booking and a confirmation pursuant to clause 6 of these terms.
• “Content” means all text, graphics, images, music, software, audio, video, information or other materials and Content that FlexiSpirit makes available through the Site, including Member Content.
• “Booking Fees” means the amounts that are due and payable by you in exchange for the booking of a Space, including all ancillary costs and taxes, if applicable, as displayed in the respective Listing.
• “Listing” means a Space that is listed as available for booking via the Site.
• “Member” means a person who completes FlexiSpirit’s account registration process as described under “Account Registration” below.
• “Member Content” means all Content that a Member posts, uploads, publishes, submits or transmits to be made available through the Site.
• “Space” means any room, workshop, kitchen, office, house, apartment, suite, hall, centre, building or other property and/or its facilities and immediate surroundings offered for booking by FlexiSpirit via the Site.
• “Space Provider” means any person or entity who makes a room available for Booking through a Listing, typically, the owner or operator of a space.
• “Services” means any service offered directly by a space or a third-party supplier related to an agreement and offered for booking by FlexiSpirit via the Site.

3. How the Site Works

The Site can be used to book Spaces and related services, including but not limited to rooms, workshops, kitchens, houses, offices, apartments, suites, halls, centres, buildings or other properties and/or related services and/or its immediate surroundings for commercial or other purposes. Such Spaces are included in Listings on the Site. You may view Listings as an unregistered visitor to the Site; however, if you wish to contact, request, or book a Space or to create a listing, you must register to create a FlexiSpirit Account (defined below).

4. Account Registration and Access

In order to access certain features of the Site or create a Listing, you must first register to create an account (“FlexiSpirit Account”) and become a Member. Your personal profile will be created based upon the information you provide. You may not have more than one (1) FlexiSpirit Account. Access to your profile is password protected and you are responsible for safeguarding your password. FlexiSpirit shall not be liable for any claims, liabilities, damages, losses, and expenses, including, without limitation, legal and accounting fees on whatsoever scale, arising out of or in any way connected with any activities or actions under your FlexiSpirit Account, whether or not you have authorised such activities or actions. You have to immediately notify FlexiSpirit of any unauthorised use of your FlexiSpirit Account.

5. Information Provided for Registration or Booking

You agree to provide accurate, current and complete information during the registration process and to update such information. The same applies to the information provided in the booking process.

6. Bookings

6.1. Forms of Bookings (contractual partner for the booking)

Bookings can happen in two different ways where the respective contractual partner of the booker is the following:

• Bookings between you (the ‘booker’) and FlexiSpirit Ltd
• Bookings between you and the space directly

The default form of bookings is with FlexiSpirit Ltd as the contractual partner. FlexiSpirit can, at its sole discretion, deviate from the default. In this case, the contractual partner of the booking will be stated in the booking process.

6.2. Bookings with FlexiSpirit Ltd as contractual partner

6.2.1. General

If you request a booking, you submit an offer to FlexiSpirit to enter into a usage agreement (‘Agreement’) between FlexiSpirit as provider and you as a booker, as determined by the details of the booking which will be finalised in a booking confirmation pursuant to these terms and conditions.

A booking will only become valid upon confirmation by FlexiSpirit. FlexiSpirit is required to either confirm or reject the booking request within the following period:

• if a “Booking Request Period” is displayed in the Listing, such period is decisive;
• if no “Booking Request Period” is displayed in the Listing, the period is one week.

If FlexiSpirit confirms a booking, we will summarise the material terms of the booking (including the applicable cancellation policy) in an email to you (‘booking confirmation’). Such confirmation shall constitute a commercial letter of acknowledgement. If you feel that it does not fully reflect what has been agreed, you have to inform us without undue delay.

Absent a confirmation by FlexiSpirit in such period, the requested booking will be automatically cancelled. If a requested booking is not confirmed by FlexiSpirit, any amounts collected by FlexiSpirit will be refunded to you, depending on the selections you make via the Site and any pre-authorisation of your credit card will be released, if applicable.

(In case of credit card payment, FlexiSpirit does not charge, but only pre-authorises, your credit card until a booking is confirmed.)

6.2.2. Financial Terms

The Booking Fees payable will be displayed to you before you send a booking request. You as a Booker are liable to pay FlexiSpirit using the methods described/chosen on the Site for the Booking Fees for any booking requested if such requested bookings are confirmed. Booking Fees are due immediately with confirmation if not stated otherwise in the booking process.

In connection with your requested booking, you will be asked to provide customary billing information such as name, billing address and/or credit card information either to FlexiSpirit or its third party payment processor(s).

In order to establish a booking, you understand and agree that FlexiSpirit reserves the right, in its sole discretion, to (i) obtain a pre-authorisation via your credit card (or the respective payment method, e.g. PayPal) for the Booking Fees or (ii) charge your credit card (or the respective payment method, e.g. PayPal) a nominal amount, not to exceed one pound (£1), to verify your credit card. Upon confirmation of your booking, FlexiSpirit will charge your credit card (or the respective payment method, e.g. PayPal) for the Booking Fees.

You duly authorise FlexiSpirit or the third party online payment processor, as the case may be, to charge your credit card for said fees and collect said fees without requiring additional or prior approval from you subsequent to your booking request. Please note that FlexiSpirit cannot control any fees that may be charged to you by your bank related to FlexiSpirit’s collection of the Booking Fees, and FlexiSpirit disclaims all liability in this regard. If you are directed to FlexiSpirit’s third party payment processor(s), you may be subject to terms and conditions governing use of that third party’s service and that third party’s personal information collection practices. Please review such terms and conditions and privacy policy before using the services.

Once your confirmed booking transaction is complete, you will receive a confirmation email summarising your confirmed booking.

6.2.3. Cancellations by you

If you cancel your requested booking before the requested booking is confirmed, FlexiSpirit will cancel any pre-authorisation to your credit card and/or refund any nominal amounts charged to you or paid by you in connection with the requested booking within a commercially reasonable time.

If you wish to cancel a confirmed booking made via the Site, either prior to or after arriving at the Space, the cancellation policy of FlexiSpirit pursuant to the individual Agreement will apply to such cancellation. Our ability to refund the Booking Fees and other amounts charged to you will depend upon the terms of the applicable cancellation policy pursuant to the individual Agreement.

6.2.4. Terms of Booking

Booking Fees include all utilities (electricity, heating and water) unless stated otherwise in the respective Agreement.

Booking Fees may include services that you explicitly selected in the booking process unless noted otherwise in the respective Agreement.

You as a Booker are responsible to return the Space clean and in the same state as handed over unless noted otherwise in the respective Agreement. You may be charged additional fees for cleaning and/or restoration in case you fail to return the space in the same condition. The respective fees will be invoiced to you separately. FlexiSpirit does not guarantee that these fees may be covered by insurance. FlexiSpirit suggests you to document the state of the space on your arrival at the space in case that may be required for insurance claims.

You are responsible to return any keys you may obtain.

You are responsible to obtain any insurance coverage that may be required (e.g. for events) by law, any other regulations, or on request of the space. For some Spaces, mandatory insurance against damages is required. If indicated in the respective Agreement, you have to obtain such insurance. We may request that you submit conclusive evidence that you have obtained such insurance. If we made such request and you have not submitted such evidence, FlexiSpirit may withhold the Space; but you remain liable to pay Booking Fees.

You are responsible to obtain licences that may be required for your event (e.g. noise/alcohol) and to comply with all applicable laws (in particular laws on noise protection).

You must not subcontract the usage of the Space except as expressly approved by FlexiSpirit in writing (it being understood that email shall suffice).

6.3. Bookings directly with the space

In cases where a request is handled between you and the space directly, FlexiSpirit is no contractual partner of the booking. Instead, a contractual agreement for the booking is concluded between the booker and the provider of the space.

In these cases, the confirmation of an offer via the Site does only indicate intend to close a contract but does not constitute the formation of a contract itself unless specifically stated in the booking process.

The individual contractual agreement between booker and space has to include all booking details, these supersede the information on the Site (e.g. cancellation policies) unless stated otherwise.

It is possible in these bookings that FlexiSpirit agrees on parts of the booking individually with the space and/or the booker (e.g. for collection of possible processing fees, delivery of specific services, commission agreements).

7. User Conduct

You understand and agree that you are solely responsible for compliance with any and all laws, rules, regulations, and tax obligations that may apply to your use of the Site and Content. In connection with your use of the Site and Content, you will not:

• violate any local, state, provincial, national, or other law or regulation, or any order of a court, including, without limitation, zoning restrictions and tax regulations;
• use manual or automated software, devices, scripts, robots or other means or processes to access, “scrape,” “crawl” or “spider” any web pages or other services contained in the Site or Content;
• use the Site or Content for any commercial or other purposes that are not expressly permitted by these Terms;
• copy, store or otherwise access any information contained on the Site or Content for purposes not expressly permitted by these Terms;
• infringe the rights of any person or entity, including without limitation, their intellectual property, privacy, publicity or contractual rights;
• interfere with or damage our Site, including, without limitation, through the use of viruses, cancel bots, Trojan horses, harmful code, flood pings, denial-of-service attacks, packet or IP spoofing, forged routing or electronic mail address information or similar methods or technology;
• use our Site to transmit, distribute, post or submit any information concerning any other person or entity, including without limitation, photographs of others without their permission, personal contact information or credit, debit, calling card or account numbers;
• use our Site, services or Content in connection with the distribution of unsolicited commercial email (“spam”) or advertisements;
• “stalk” or harass any other user of our Site, our services or Content, or collect or store any personally identifiable information about any other user other than for purposes of transacting as Member;
• register for more than one FlexiSpirit Account or register for a FlexiSpirit Account on behalf of an individual other than yourself;
• unless FlexiSpirit explicitly permits otherwise, request or book any Space if you will not actually be using the Space yourself;
• contact owners of any Space for any purpose other than asking a question related to a confirmed booking of such owner’s Spaces or replying to such question;
• recruit or otherwise solicit any owner or other Member to join third party services or websites that are competitive to FlexiSpirit, without FlexiSpirit’s prior written approval;
• impersonate any person or entity, or falsify or otherwise misrepresent yourself or your affiliation with any person or entity;
• use automated scripts to collect information from or otherwise interact with the Site or Content;
• use the Site, our services or Content to find the owner of a Space and then complete a booking of a Space independent of the Site, in order to circumvent the obligation to pay any Booking Fees to FlexiSpirit or for any other reasons;
• post, upload, publish, submit or transmit any Content that: (i) infringes, misappropriates or violates a third party’s patent, copyright, trademark, trade secret, moral rights or other intellectual property rights, or rights of publicity or privacy; (ii) violates, or encourages any conduct that would violate, any applicable law or regulation or would give rise to civil liability; (iii) is fraudulent, false, misleading or deceptive; (iv) is defamatory, obscene, pornographic, vulgar or offensive; (v) promotes discrimination, bigotry, racism, hatred, harassment or harm against any individual or group; (vi) is violent or threatening or promotes violence or actions that are threatening to any other person; or (vii) promotes illegal or harmful activities or substances;
• systematically retrieve data or other content from our Site to create or compile, directly or indirectly, in single or multiple downloads, a collection, compilation, database, directory or the like, whether by manual methods, through the use of bots, crawlers, or spiders, or otherwise;
• use, display, mirror or frame the Site or Content, or any individual element within the Site or Content, FlexiSpirit’s name, any FlexiSpirit trademarks, logos or other proprietary information, or the layout and design of any page or form contained on a page in the Site, without FlexiSpirit’s express written consent;
• access, tamper with, or use non-public areas of the Site, FlexiSpirit’s computer systems, or the technical delivery systems of FlexiSpirit’s providers;
• attempt to probe, scan, or test the vulnerability of any FlexiSpirit system or network or breach any security or authentication measures;
• avoid, bypass, remove, deactivate, impair, descramble, or otherwise circumvent any technological measure implemented by FlexiSpirit or any of FlexiSpirit’s providers or any other third party (including another user) to protect the Site or Content;
• forge any TCP/IP packet header or any part of the header information in any email or newsgroup posting, or in any way use the Site or Content to send altered, deceptive or false source-identifying information;
• attempt to decipher, decompile, disassemble or reverse engineer any of the software used to provide the Site or Content; or
• advocate, encourage, or assist any third party in doing any of the foregoing.

FlexiSpirit has the right to investigate and prosecute violations of any of the above to the fullest extent of the law.

8. Ownership

You acknowledge and agree that the Site and Content, including all associated intellectual property rights, are the exclusive property of FlexiSpirit and its licensors. You will not remove, alter or obscure any copyright, trademark, service mark or other proprietary rights notices incorporated in or accompanying the Site or Content, or attempt to contest ownership thereof.

9. Content Licence

Subject to your compliance with the terms and conditions of these Terms, FlexiSpirit grants you a limited, non-exclusive, non-transferable licence, to (i) access and view any Content solely for your personal and non-commercial purposes and (ii) access and view any Content to which you are permitted access, solely for your personal and non-commercial purposes. You have no right to sublicense the licence rights granted in this section.

You will not use, copy, adapt, modify, prepare derivative works based upon, distribute, licence, sell, transfer, publicly display, publicly perform, transmit, broadcast or otherwise exploit the Site or Content, except as expressly permitted in these Terms. No licences or rights are granted to you by implication or otherwise under any intellectual property rights owned or controlled by FlexiSpirit or its licensors, except for the licences and rights expressly granted in these Terms.

10. Member Content

We may, in our sole discretion, permit you to post, upload, publish, submit or transmit Member Content. By making available any Member Content on or through the Site, you grant to FlexiSpirit a worldwide, irrevocable, perpetual, non-exclusive, transferable, royalty-free licence, with the right to sublicense, to use, view, copy, adapt, modify, distribute, licence, sell, transfer, publicly display, publicly perform, transmit, stream, broadcast, access, and otherwise exploit such Member Content on, through, by means of, or to promote or market the Site.

FlexiSpirit does not claim any ownership rights in any such Member Content and nothing in these Terms will be deemed to restrict any rights that you may have to use and exploit any such Member Content.

You acknowledge and agree that you are solely responsible for all Member Content that you make available through the Site. Accordingly, you represent and warrant that: (i) you either are the sole and exclusive owner of all Member Content that you make available through the Site or you have all rights, licences, authorities, consents and releases that are necessary to grant to FlexiSpirit the rights in such Member Content, as contemplated under these Terms; and (ii) neither the Member Content nor your posting, uploading, publication, submission or transmittal of the Member Content or FlexiSpirit’s use of the Member Content (or any portion thereof) on, through or by means of the Site and our services will infringe, misappropriate or violate a third party’s patent, copyright, trademark, trade secret, moral rights or other proprietary or intellectual property rights, or rights of publicity or privacy, or result in the violation of any applicable law or regulation.

11. Links

The Site may contain links to third party websites or resources. You acknowledge and agree that FlexiSpirit is not responsible or liable for: (i) the availability or accuracy of such websites or resources; or (ii) the content, products, or services on or available from such websites or resources. Links to such websites or resources do not imply any endorsement by FlexiSpirit of such websites or resources or the content, products, or services available from such websites or resources. You acknowledge sole responsibility for and assume all risk arising from your use of any such websites or resources or the Content, products or services on or available from such websites or resources.

Some portions of the FlexiSpirit platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use.

12. Feedback

We welcome and encourage you to provide feedback, comments and suggestions for improvements to the Site or our services (“Feedback”). You may submit Feedback by emailing us at support@flexispirit.com or through the “Contact” section of the Site. You acknowledge and agree that all Feedback will be the sole and exclusive property of FlexiSpirit and you hereby irrevocably assign to FlexiSpirit and agree to irrevocably assign to FlexiSpirit all of your right, title, and interest in and to all Feedback, including without limitation all worldwide patent, copyright, trade secret, moral and other proprietary or intellectual property rights therein. At FlexiSpirit’s request and expense, you will execute documents and take such further acts as FlexiSpirit may reasonably request to assist FlexiSpirit to acquire, perfect, and maintain its intellectual property rights and other legal protections for the Feedback.

13. Copyright Policy

FlexiSpirit respects copyright law and expects its users to do the same. It is FlexiSpirit’s policy to terminate in appropriate circumstances the FlexiSpirit Accounts of Members or other account holders who repeatedly infringe or are believed to be repeatedly infringing the rights of copyright holders.

14. Suspension, Termination and FlexiSpirit Account Cancellation

We may, in our discretion and without liability to you, with or without cause, with or without prior notice and at any time, decide to limit, suspend, deactivate or cancel your FlexiSpirit Account or access thereto. In respect of the aforementioned, causes for limitation, suspension, deactivation or cancellation may include the creation of more than one (1) FlexiSpirit Account by a Member or a Member providing information during the registration process or thereafter which proves to be inaccurate, fraudulent, outdated or incomplete. If we exercise our discretion under these Terms to do so, any or all of the following can occur with or without prior notice or explanation to you: (a) your FlexiSpirit Account will be deactivated or suspended, your password will be disabled, and you will not be able to access the Site, services, your FlexiSpirit Account, your Member Content, or receive assistance from FlexiSpirit Customer Service, (b) we will not accept any offers or reservations, and (c) we may cancel bookings.

You may cancel your FlexiSpirit Account at any time via the “Cancel Account” feature or by sending an email to support@flexispirit.com. Please note that if your FlexiSpirit Account is cancelled, we do not have an obligation to delete or return to you any Content you have posted to the Site, including, but not limited to, any reviews or Feedback, except where required by data protection law.

15. Limitation of Liability

FlexiSpirit’s liability is limited as follows: FlexiSpirit shall only be liable for damages if the cause of damage is based on gross negligence or intentional breach of obligations by FlexiSpirit or by one of FlexiSpirit’s legal representatives or agents.

In addition, FlexiSpirit shall be liable for the negligent breach of fundamental obligations whose breach endangers the fulfilment of the purpose of the Agreement or for the breach of obligations whose fulfilment enables the proper execution of the Agreement in the first place and on the fulfilment of which the customer regularly relies. FlexiSpirit shall not assume liability for the slightly negligent breach of obligations other than the ones stated in the preceding sentences.

The aforementioned limitation of liability shall not apply in the case of culpable injury to life, body or health, for a defect after assumption of a guarantee for the quality of the product, and for the fraudulent concealment of deficiencies. The liability under applicable consumer protection laws shall remain unaffected.

Nothing in these Terms excludes or limits FlexiSpirit’s liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, breach of the terms implied by Section 2 of the Supply of Goods and Services Act 1982 (title and quiet possession), or any other liability which cannot be excluded or limited under English law.

16. Indemnification

You agree to release, defend, indemnify, and hold FlexiSpirit harmless from and against any claims, liabilities, damages, losses, and expenses, arising out of or in any way connected with: a) your Member Content and/or b) your non-compliance with the terms of the Agreement concluded with FlexiSpirit (in particular claims of owners).

17. Changing these Terms

FlexiSpirit might, at any time, change these terms. FlexiSpirit will notify members via email and via publishing of the updated terms on the site. Notifications will happen at least two weeks in advance of any changes taking effect.

If the user does not state any written objections (e.g. via email) within two weeks after being notified, the changed terms will become effective on the day that was determined in the notification.

In case of written objection received on-time, FlexiSpirit is entitled – taking into account the legitimate interest of the member – to cancel all existing contracts with the member. Cancellation will take effect at the same time the new terms are becoming effective and the user account will be locked. You cannot derive claims from that, in particular no claims of compensation against FlexiSpirit.

18. Individual Agreements

Individual agreements shall prevail over these Terms. The content of such individual agreements shall in each case be confirmed by both FlexiSpirit and you in writing (it being understood that e-mail shall suffice).

19. Controlling Law and Jurisdiction

The use of the Site and contesting of the validity, enforceability and termination of any Agreement are subject to English law and the jurisdiction of the courts of England and Wales.

20. Severability

If any provision of these Terms is found to be unenforceable or invalid under any applicable law, such unenforceability or invalidity shall not render these Terms unenforceable or invalid as a whole, and such provisions shall be deleted without affecting the remaining provisions herein.

PART II: PRIVACY POLICY

21. Introduction to Privacy Policy

FlexiSpirit Ltd (“FlexiSpirit”, “we”, “us”, or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website www.flexispirit.com (the “Site”) and our services.

Company Details:

• FlexiSpirit Ltd, Company Number: 14393966
• Registered Office: 66 Potter Crescent, Wokingham, England, RG41 1AN
• Data Protection Contact: dpo@flexispirit.com

This Privacy Policy should be read in conjunction with our Terms of Service (Part I) and Cookie Policy (Part III) of this document.

22. Legal Basis for Processing

We process your personal data under the following legal bases as defined by UK GDPR:

• Contract Performance: To fulfil our contractual obligations when you book spaces through our platform
• Legitimate Interests: To improve our services, prevent fraud, and communicate with you about our services
• Legal Obligation: To comply with legal requirements, including tax and accounting obligations
• Consent: Where you have provided explicit consent for specific processing activities

23. Information We Collect

23.1. Information You Provide Directly

Account Registration:

• Full name and contact details (email address, phone number)
• Business/company information (if applicable)
• Billing address and payment information
• Username and password

Booking Information:

• Space preferences and requirements
• Event details and special requests
• Communication with Space Providers
• Booking history and preferences

Communications:

• Support enquiries and correspondence
• Feedback and reviews
• Marketing preference selections

23.2. Information We Collect Automatically

Technical Information:

• IP address and device identifiers
• Browser type and version
• Operating system and device information
• Website usage data and analytics
• Cookies and similar tracking technologies (see Part III – Cookie Policy)

Usage Data:

• Pages visited and time spent on our Site
• Search queries and booking interactions
• Referral sources and exit pages
• Error logs and performance data

23.3. Information from Third Parties

Payment Processors:

• Transaction details and payment status
• Fraud prevention information

Space Providers:

• Booking confirmations and modifications
• Service delivery information
• Reviews and ratings (where applicable)

24. How We Use Your Information

We use your personal data for the following purposes:

24.1. Service Provision

• Processing and managing your bookings
• Facilitating communication with Space Providers
• Providing customer support and assistance
• Managing your FlexiSpirit Account

24.2. Business Operations

• Processing payments and managing billing
• Preventing fraud and ensuring platform security
• Improving our services and user experience
• Conducting analytics and market research

24.3. Legal and Compliance

• Complying with legal obligations
• Resolving disputes and enforcing agreements
• Maintaining records for tax and accounting purposes

24.4. Marketing and Communications

• Sending booking confirmations and updates
• Providing information about new services (with consent)
• Sending newsletters and promotional materials (with consent)
• Conducting customer satisfaction surveys

25. Data Sharing and Transfers

25.1. Space Providers

We share necessary booking information with Space Providers to facilitate your reservations, including:

• Your name and contact details
• Company information (where applicable)
• Booking requirements and special requests
• Communication preferences

25.2. Service Providers

We may share your data with trusted third-party service providers who assist us in:

• Payment processing (payment gateways, fraud prevention)
• Technical services (hosting, analytics, customer support)
• Marketing services (email platforms, advertising networks)
• Legal and professional services

25.3. Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes or government requests
• Protect our rights, property, or safety
• Prevent fraud or other illegal activities
• Enforce our Terms of Service

25.4. Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity, subject to the same privacy protections.

26. International Data Transfers

Where we transfer your personal data outside the UK, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the UK government
• Standard Contractual Clauses approved by the UK authorities
• Binding Corporate Rules or certification schemes
• Other approved transfer mechanisms under UK GDPR

27. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy:

Account Information: Until account deletion plus 7 years for legal/tax purposes Booking Records: 7 years from booking date for legal and tax compliance Payment Information: As required by payment card industry standards Marketing Communications: Until you withdraw consent or we no longer have a legitimate interest Technical Data: Typically 2 years, unless required for security or legal purposes

28. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

28.1. Right of Access

You can request a copy of the personal data we hold about you.

28.2. Right to Rectification

You can request correction of inaccurate or incomplete personal data.

28.3. Right to Erasure (“Right to be Forgotten”)

You can request deletion of your personal data in certain circumstances.

28.4. Right to Restrict Processing

You can request that we limit how we use your personal data.

28.5. Right to Data Portability

You can request a copy of your data in a machine-readable format.

28.6. Right to Object

You can object to processing based on legitimate interests or for direct marketing.

28.7. Rights Related to Automated Decision-Making

You have rights regarding automated decision-making and profiling.

28.8. Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time.

Exercising Your Rights: To exercise any of these rights, contact us at dpo@flexispirit.com. We will respond within one month of receiving your request.

29. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

Technical Measures:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication systems
• Secure hosting and data storage solutions

Organisational Measures:

• • Staff training on data protection
  • Regular review of data processing activities
  • Data breach response procedures
  • Privacy by design principles

30. Children’s Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information.

PART III: COOKIE POLICY

Our Cookie Policy explains how FlexiSpirit Ltd (“FlexiSpirit”, “we”, “us”, or “our”) uses cookies and similar technologies on our website www.flexispirit.com/cookie-policy (the “Site”). This policy should be read alongside our Terms of Service (Part I) and Privacy Policy (Part II) of this document.