Mobile Companion Privacy Notice
Personal Data Processing Notice
This notice serves to provide you with information about the collection and processing of your personal data by the BEEAH Group (“BEEAH“, “we” or “us”), as data controller, in the context of the Office of the Future Application (the “Solution”) which comprises of the following products: (i) the Companion App; (ii) the Guest Portal; (iii) Employee Portal; (iv) Virtual Concierge; and (v) Hardware End-points across the BEEAH office building (CCTV cameras, Facial recognition cameras, Wifi Aps, etc.). Please continue reading below for more details about the personal data we collect, how we gather it, and how it is used and shared.
This Personal Data Processing Notice (“Notice”) is not intended to cover all processing activities performed by BEEAH and is limited only to the processing activities performed by BEEAH in connection with the Solution.
If you have any questions regarding this Privacy Notice or our processing of your personal data, please contact BEEAH Legal.
2. Categories of Personal Information Processed
We process the following personal data in the context of the Solution:
- facial recognition data (i.e. your image);
- first name(s) and last name(s);
- business telephone number;
- business email address;
- device IP address;
- device mac address;
- company entity name;
- job title;
- absence information / time tracking information;
- geolocation (via wi-fi);
- vehicle information;
- food and beverage preferences; and
- information with respect to any disability you may have, as a Person of Determination.
If you are BEEAH employee, contractor, consultant, contingent worker, volunteers or intern (“Employee”) we may also process the following categories of personal data in the context of the Solution:
- home telephone number;
- line reporting manager;
- SAP ID
- office location;
- start date;
- end date;
- geolocation information (Bluetooth Location Beacon); and
- device microphone (where you have enabled microphone access in the Companion App for speech-to-text and text to speak functionality).
If you are a visitor to our premises we may also process the following categories of personal data in the context of the Solution:
- Government ID (Including photograph).
3. Method of Collection
We may collect your personal data in the context of the Solution in the following ways:
- Via other systems which we operate, or which are operated on our behalf, which already store your personal data (including, but not limited to, Cisco Spaces, Captive Portal and Azure Active Directory); and
- Where you directly input your personal data into the Solution.
4. Purpose of Processing
We process your personal data in the context of the Solution for the following purposes:
- Improving security;
- Improving working conditions and comfort for our Employees; and
- Resource optimisation (i.e. Energy usage for building cooling).
5. Lawful Basis
We only process your personal data where we are able to justify the processing in accordance with applicable law. We rely on the following legal bases for processing:
- the processing is necessary to protect the interests of the data subject;
- the processing is necessary for the controller or data subject to fulfil his/her obligations and exercise his/her legally established rights in the field of employment, social security or laws on social protection, to the extent permitted by those laws; and
- the processing is necessary to fulfil obligations imposed by other laws of the state on controllers.
We rely on your consent only if and to the extent to which the lawful bases listed above do not apply.
The third parties with whom we may share your personal include:
- other entities within the BEEAH group;
- our third-party service providers, including IT service providers including, but limited to, Johnson Controls Incorporated and Microsoft; and
- other third parties (such as advisors, potential transaction partners or interested third parties) in connection with the consideration, negotiation or completion of a corporate transaction or restructuring of the business or assets of BEEAH.
We may also be required to disclose your personal data to third parties in response to orders or requests from a court, regulators, government agencies, parties to a legal proceeding or public authorities, or to comply with regulatory requirements or as part of a dialogue with a regulator.
7. International Transfers
Personal data collected via the Solution will be stored in a third-party data centre in the Netherlands. Whilst in transit, your personal data will also pass through data centres in the United States of America. When storing your personal data we use industry leading cloud service provides who provide contractual guarantees with respect to their data security measures.
8. Retention Period
BEEAH only retains personal data for as long as is required to satisfy the purpose for which it was collected by us, or provided to us by you.
However, under certain circumstances, some personal data may be retained for longer time periods where necessary to comply with our legal and regulatory obligations.
9. Your Rights
You have the following rights in relation to your personal data:
- Right to Obtain Information: You have the right to obtain certain information about how your personal data is processed by BEEAH. For ease, we have included most of this information in this Notice.
- Right to Request Personal Data Transfer: You have the right to request a copy of the personal data that BEEAH holds about you in a structed, machine-readable format. You also have the right to have such personal data transferred to a third party, where this is possible.
- Right to Correction or Erasure of Personal Data: You have the right to request the correction of any inaccurate data relating to you and the right to request deletion of certain personal data we hold about you.
- Right to Restrict Processing: You have the right to restrict our processing of your personal data in certain circumstances.
- Right to Stop Processing: You have the right to stop us processing your personal data in certain circumstances.
- Right to Processing and Automated Processing: You have the right to object to decisions that we have made about you when the decision has been made based solely on automated processing, including profiling.
Please note that the rights listed above are not absolute rights. Some of the rights only apply in certain circumstances (for example, where BEEAH relies on a particular lawful basis for processing your personal data) and BEEAH has certain rights to refuse your requests.
We may update this Notice from time-to-time to reflect changes to the type of personal data that we process and/or the way in which it is processed.
This Notice was last updated and reviewed on 29 May 2023.