Privacy Policy

I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, The Shed Coworking (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Scope of This Privacy Policy

This Privacy Policy applies to personal data processed through The Shed Coworking’s website, web forms, email communications, referral partners, customer relationship management (CRM) systems, and initial inquiry triage workflow.

Laws incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force regarding the protection of personal data on the Internet. Specifically, it respects the following rules:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, 2007, approving the Regulations for the development of Organic Law 15/1999, of December 13, 1999, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected in The Shed Coworking is: Acelera Labs S.L, provided with NIF/CIF: B86978350 and registered in: Commercial Registry of Madrid (Provicional) with the following registry data: (Provicional), whose representative is: Gonzalo Navarro (hereinafter, Data Controller). Its contact details are as follows:

Address: Calle Hermosilla, 48, 1º Dcha., 28001, Madrid

Contact telephone: 910821072

Contact email: info@theshedcoworking.com

Personal Data Registry

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by The Shed Coworking, through the forms provided on its pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between The Shed Coworking and the User or the maintenance of the relationship established in the forms that this fills, or to meet a request or query from the same. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided in Article 30.5 of the RGPD is applicable, a record of processing activities is kept that specifies, according to their purposes, the processing activities carried out and other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of Lawfulness, Fairness, and Transparency: Personal data will be processed fairly and transparently in accordance with the legal basis applicable to each purpose. Consent will only be requested when it is the appropriate legal basis or is legally required.
  • Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
  • Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and always up to date.
  • Principle of limitation of the storage period: personal data will only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
  • Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

Depending on the inquiry, The Shed Coworking may process:

Identifying and contact information, such as name, email address, and phone number.
Professional and business information, such as company name, job title, website, or business domain.
Inquiry and reservation information, such as the requested service, dates, duration, number of people, preferences, and message.
Derived operational data, such as the inquiry category, its completeness, the assigned team, the qualification status, and the estimated commercial value.

The Shed Coworking does not intentionally request special categories of personal data. However, free-text emails, web form submissions, and attachments may contain health data or other sensitive information that the sender includes without being asked. Incidental sensitive information is not used to qualify, score, direct, or investigate an inquiry. Access is limited to authorized staff and service providers who need it to address the inquiry, investigate a specific error or security incident, or comply with the law. The inquiry classification service may forward attachments when operationally necessary, but it does not inspect, extract, classify, summarize, or send their content to artificial intelligence providers or public source research providers.

Sources of Personal Data

Personal data is typically obtained from the person who sends an email or submits a web form. An inquiry may also be referred by a business partner or referral source. For certain business inquiries, limited information about the relevant organization may be obtained from publicly available business sources.

Legal basis for the processing of personal data

When a person requests that The Shed Coworking take precontractual measures to enter into a contract with them, the processing will be based on Article 6(1)(b) of the GDPR. The Shed Coworking relies on its legitimate interests under Article 6(1)(f) of the GDPR to manage business inquiries, prepare quotes for organizations, categorize and route inquiries, maintain records in the CRM, prevent spam, measure service performance, qualify business opportunities, conduct limited research on relevant organizations, and allow for the review of certain inquiries to investigate errors, monitor security, and improve the inquiry management service provided to The Shed Coworking. Consent under Article 6.1.a) of the GDPR will only be used when specifically necessary, for example, for optional marketing communications. Processing may also be necessary to comply with legal obligations under Article 6.1.c) of the GDPR.

The User shall have the right to withdraw consent at any time. It shall be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

In the occasions in which the User must or may provide his/her data through forms to make inquiries, request information or for reasons related to the content of the Website, he/she will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing for which the personal data is used

Personal data may be used to receive, classify, qualify, and route inquiries; request missing information; create or update records in the CRM; prevent spam; measure service performance; and conduct limited research in public sources on organizations related to specific business inquiries. These tasks may be supported by artificial intelligence-powered tools. Certain inquiry records may be reviewed by authorized personnel of the service provider to investigate errors, monitor security, and improve the reliability of the inquiry management service provided to The Shed Coworking. Automated messages sent to customers will use pre-approved templates, while ambiguous cases and follow-up responses will be handled by staff.

The inquiry workflow does not make decisions based solely on automated processing that produces legal effects or similarly and significantly affects individuals. The screening of organizations does not determine the routing of an inquiry or automatically result in its rejection.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses to which the collected information will be put.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 10 years (Provicional), or until the User requests its deletion.

Specifically for the inquiry classification service, operational records and raw data obtained from public sources and retained by the third-party provider will be kept for a maximum of 60 days. Data intentionally transferred to The Shed Coworking’s inbox or CRM becomes part of those business records controlled by the Client and is subject to the retention rules applicable to those systems. With the current configuration of the artificial intelligence service, the AI provider may retain certain abuse monitoring records containing the submitted content for a maximum of 30 days.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

Personal data may be disclosed, only when necessary for the purposes described above, to:

Authorized staff at The Shed Coworking and business or referral partners involved in the relevant inquiry.
Technology and service providers that supply email, CRM, and document collaboration services; hosting and database infrastructure; AI-assisted processing; and limited business research from public sources.
Authorized personnel from the inquiry management service who review certain records solely to investigate errors, monitor security, and improve the service provided to The Shed Coworking.
Professional advisors, public authorities, courts, or other recipients when disclosure is required by law or necessary to establish, exercise, or defend legal claims.

These providers are subject to contractual obligations regarding confidentiality, security, and data protection that are appropriate to their role. The Shed Coworking may use categories of providers instead of identifying each provider in this Public Policy.

Some providers or their authorized subprocessors may process personal data outside the European Economic Area. Where necessary, such transfers will be protected by an applicable adequacy decision by the European Commission, the European Commission’s standard contractual clauses, or another lawful safeguard. You may request information from the Data Controller regarding the applicable safeguard and how to obtain a copy by using the contact information provided above.

Personal data of minors

Respecting the provisions of Articles 8 of the RGPD and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by The Shed Coworking. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

The Shed Coworking undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

However, because The Shed Coworking cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights deriving from the processing of personal data

The User has over The Shed Coworking and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

  • Right of access: This is the User's right to obtain confirmation of whether or not The Shed Coworking is processing their personal data and, if so, to obtain information about their specific personal data and the processing that The Shed Coworking has carried out or will carry out, as well as, among others, the available information about the origin of such data and the recipients of the communications made or planned for such data.
  • Right of rectification: This is the User's right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
  • Right of deletion ("the right to be forgotten"): This is the User's right, unless otherwise provided for by the legislation in force, to obtain the erasure of his or her personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject's request for the deletion of any link to such personal data.
  • Right to limitation of processing: This is the User's right to limit the processing of his/her personal data. The User has the right to obtain the limitation of the processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
  • Right to data portability: In case the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Data Controller. Whenever technically possible, the Controller shall transmit the data directly to such other controller.
  • Right of opposition: This is the User's right not to have his or her personal data processed or to cease the processing of such data by The Shed Coworking.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by applicable law.

Thus, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD-www.theshedcoworking.com", specifying:

  • Name, surname of the User and copy of the ID card. In cases where representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other means valid in law that proves the identity.
  • Request with the specific reasons for the request or information to be accessed.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that accredits the request you are making.

This application and any attachments may be sent to the following address and/or e-mail address:

Postal address: Calle Hermosilla, 48, 1º Dcha., 28001, Madrid

E-mail: info@theshedcoworking.com

Links to third party websites

The Website may include hyperlinks or links that allow access to third party websites other than The Shed Coworking, and therefore are not operated by The Shed Coworking. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

This Privacy Policy explains how personal data is processed and does not require general acceptance as a condition for reading or using the Website. When consent is required for a specific purpose, it will be requested separately. Use of the Website does not in itself constitute consent to all processing activities described in this Policy.

The Shed Coworking reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.

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