Privacy and Cookies Policy

1. Introduction

This Privacy Policy explains how Cohere Spaces Ltd ("we," "us," or "our") collects, uses, and protects your personal data. Please read this policy carefully to understand our practices regarding your personal information.

If you have any questions or comments about this policy, please contact us at hello@coherespaces.co.uk.

2. Who We Are and How to Contact Us

Cohere Spaces Ltd is the data controller responsible for your personal data.

• Registered address: 34 Commercial Street, Dundee, DD1 3EJ
• Website address: www.flourmilldundee.com
• Email: hello@coherespaces.co.uk

3. Personal Data We Process

We may collect, use, store, and process the following categories of personal data:

• Identity Data: Name, title, date of birth.
• Contact Information: Address, billing address, email address, telephone number.
• Payment Information: Bank account and payment card details.
• Transaction Information: Details of payments to and from you, and details of services purchased.
• Interaction Data: Information provided through forms, surveys, reviews, or website chat functions.
• Correspondence Data: Records of any correspondence between us.
• Office Space Requirements: Information regarding your office space needs.
• Website Usage Data: Details of your visits to our websites and the resources you use.
• Technical Data: IP address, browser information, operating system information.
• Browsing Data: Information about how you use our websites, including browsing actions and patterns.
• Marketing Preferences: Your preferences for receiving marketing communications.

We do not collect any special categories of personal data (including details about race, ethnicity, religion, sexual orientation, health, or genetic/biometric data) or information about criminal convictions and offenses.

What we record when you complete our quiz or contact form

When you submit our quiz or contact form, the specific information we record alongside the categories above includes:

• Your name, email, and (where you provide it) phone number.
• Your answers to our quiz questions — the type of space you are interested in (private office, coworking, or meeting room), team size, intended move-in timeline, and booking preference where applicable.
• Any free-text requirements you choose to share with us.
• Marketing attribution data, such as the page you arrived on, the referring website, UTM parameters, and Google or Facebook click identifiers, where available.
• A timestamped snapshot of your cookie consent choices, which we retain as a compliance record.
• A hashed version of your IP address and your browser's user-agent string at the time of submission, for security and fraud-prevention purposes.

4. Keeping Your Information Updated

It is important that the personal data we hold about you is accurate and current. Please inform us of any changes to your personal data.

5. Failure to Provide Personal Data

If you do not provide personal data that we require by law or under a contract, we may not be able to fulfil our obligations. In such cases, we may have to cancel a service, and we will notify you accordingly.

6. How Your Personal Data Is Collected

We collect data through:

• Direct Interactions: Information provided through forms, correspondence, or in-person visits.
• Automated Technologies: Technical and usage data collected through cookies and similar technologies (see our Cookies Policy).
• Third Parties:
  • Providers of cookies and similar technologies for analytics and advertising (see our Cookies Policy).
  • Office space brokers who provide identity, contact, and office space requirement information.

7. Purposes of Data Processing

We use your personal data to:

• Fulfil contractual obligations.
• Process transactions and manage payments.
• Manage our relationship with you.
• Administer and protect our business and websites.
• Deliver relevant website content and advertisements.
• Improve our websites, products, and services.
• Provide requested information.
• Protect against fraud and credit risks.
• Comply with legal obligations.
• Provide you with marketing information (subject to your preferences).
• Use third party software solutions that provide us with booking, accounting, customer relationship management, and marketing services.

8. Direct Marketing

You may receive marketing communications if you have requested information or used our services and have not opted out. You can opt out at any time by contacting us.

9. Change of Purpose

We will only use your data for the original purpose, unless a compatible new purpose arises. We will notify you of any unrelated new purposes and their legal basis. We may process data without your consent when required by law.

10. Legal Basis for Processing

We process data based on:

• Your consent.
• Contractual necessity.
• Legal obligations.
• Protection of vital interests.
• Legitimate interests (see below).

11. Our Legitimate Interests

Our legitimate interests include:

• Enforcing contracts and recovering payments.
• Maintaining records and understanding customer use.
• Business development and management.
• Security and fraud prevention.
• Customer relationship management.
• Business reorganisation.
• Protection of property, safety, and rights.
• Marketing strategy.
• Website maintenance.

We may process data under multiple lawful grounds. Contact us for details on specific grounds.

12. Cookies and Similar Technologies

What are cookies?

Cookies are small text files placed on your device when you visit a website. Similar technologies can include pixels, tags, local storage, and other tools that store or access information on your device. They help the site function properly, remember your choices, and improve user experience.

Categories of cookies and technologies we use

Our website uses three categories of cookies and similar technologies. The specific tools listed below are the providers we use today; we may swap providers over time, in which case this policy will be updated.

• Essential — required for the website to function. These include cookie-consent management (provided by Cohere via Consent.io / Inth) that stores your consent choices, basic session management, and form-security tools that protect against spam and abuse. Essential cookies are always active.
• Analytics — used to understand how visitors arrive at and use the website. We use Google Analytics 4 (GA4), loaded through Google Tag Manager, only where you have given analytics consent. These cookies record information such as the pages you visit, how long you spend on each, the marketing campaign that brought you to the site, and a randomly-generated identifier so Google can measure visits accurately.
• Marketing — used to support advertising on platforms such as Google Ads and (where enabled) Meta/Facebook and Instagram. These cookies remember that you visited our site so we can show you relevant adverts on other websites and measure how well our adverts perform. Marketing cookies are only set where you have given marketing consent.

Managing cookies

You can manage or change your cookie choices at any time using the "Cookies preferences" link in our website footer, which reopens the consent panel. You can also clear cookies through your browser's privacy settings. Note that disabling essential cookies (where your browser allows it) may affect website functionality.

13. International Data Transfers

We may transfer personal data outside the UK. For example, some of our service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure adequate protection through:

• Transfers to countries with adequate protection.
• Standard contractual clauses.

Contact us for details on specific transfer mechanisms.

14. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We conduct an annual review in line with the above criteria to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

15. Disclosure of Information

We may share data with:

• Our website hosting and infrastructure providers (currently Vercel) that serve the website.
• Our backend data providers (currently Convex) that store form submissions for our team to follow up.
• Consent management providers (currently Cohere via Consent.io / Inth) that store and audit your cookie consent choices.
• Tag management providers (currently Google Tag Manager) that load the analytics and advertising tools listed in our cookies policy above.
• Analytics providers (currently Google Analytics 4) where you have given analytics consent.
• Advertising platforms (currently Google Ads, with Meta/Facebook and Instagram available where enabled) where you have given marketing consent.
• Third-party service providers (e.g., for payment processing, IT, marketing).
• Potential buyers in business transfers.
• Group companies.
• Law enforcement and regulators.
• Credit reference and fraud prevention agencies.
• Debt collection agencies.
• Courts and tribunals.
• Professional advisors.

We require third parties to protect your data.

16. Your Rights

You can:

• Opt out of direct marketing.
• Request access, deletion, or correction of your data.
• Request data portability.
• Request restriction of processing.
• Withdraw consent.
• Object to processing.
• Complain to the ICO.

Contact us at hello@coherespaces.co.uk to exercise your rights.

17. Links to Other Sites

Please note that our terms and conditions and our policies will not apply to third party websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by such other websites and we advise you to check the privacy policies of any such websites.

18. Changes

We will post changes to this policy on this page and may email you.

19. Automated Decision-Making and Profiling

Unless required by law or where you have given us your explicit consent, if we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.