Privacy policy

15below Limited, a company registered in England and Wales with company number 03945289, having its registered office at Lyndean House 43-46 Queens Road, Brighton, East Sussex, BN1 3XB (“15below” “We”).

This Privacy Policy sets out how 15below uses and protects any personal data that you provide to 15below (including personal data provided through the website https://15below.com/ (“Website”)). 15below provides services to its business clients on a worldwide basis, including access to software and technology to notify passengers of clients about delays or cancellations to their travel arrangements, which may include the collection and processing of personal data about individuals on behalf of its clients or potential clients (“Services”). In addition to this, the Website also collects certain personal data from users.

15below and its affiliated Group companies (“15below Group”) are firmly committed to respecting and protecting the privacy of all personal data received or collected, in strict adherence to Data Protection Legislation (defined below) and best business practice. The 15below Group has established this Policy so that you can understand the care with which we intend to treat personal data, as a standard. Although legal requirements may vary from country to country, the 15below Group intends to adhere to the principles set out in this Privacy Policy even if, in connection with the above, we transfer your personal information from your country to countries outside of the EEA that may not require a high level of protection for your personal information.

How to contact us

If you have any questions regarding your personal data and how we may use it, including any queries relating to this Policy, please contact us at [email protected] or writing to the “Data Protection Officer” at the office address noted above.

It is important that the personal data we hold about you is accurate and current. Please keep us (or our clients, where appropriate) informed if your personal data changes.

Our role

15below’s data protection and privacy measures are governed by applicable data protection legislation. For the purpose of applicable data protection legislation:

where personal data is provided directly to 15below through use of the Website, email, or other means where 15below is determining the way in which that personal data is processed for its own use, then 15below will be a data controller of such information;
where 15below is provided personal data in its capacity of providing Services to its clients, then 15below will only process that personal data in accordance with the instructions of its clients and 15below will, therefore, act as a data processor in respect of such personal data; 15below’s client will be the data controller of that personal data for that purpose and will be responsible to data subjects for the way in which their personal data is processed as the data controller.
where 15below acts as a data processor on behalf of its clients, 15below will process that personal data on the instructions of its clients, who would have collected that personal data in accordance with that client’s own privacy policy. Individuals who have contracts with our clients should, therefore, check that client’s own privacy policy, to ensure they understand how their personal data may be processed.

Personal data and Basis for Collection

Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Where 15below is acting as a data controller, 15below may collect, use, store and transfer different kinds of personal data about you which 15below has grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, job title and date.
Contact Data includes the billing address, delivery address, email address and telephone numbers.
Usage Data includes information about how you use 15below’s Services or submit an enquiry or query through the Website.
Preferences and interests including information about 15below’s Services that you might wish to hear about.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.

Subject to where 15below needs to verify your identity and you provide your express consent for 15below to process such information, 15below does not process any Special Category personal data (as defined by Data Protection Legislation) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor does 15below collect any information about criminal convictions and offences. As mentioned above, 15below may process Special Category personal data about individuals on behalf of its clients, in which case our client’s own privacy policy will explain the Special Category data being processed and the purposes for which it will be processed.

How is your personal data collected?

15below uses different methods to collect personal data from and about you including through:

Direct interactions.

You may give us your contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when 15below provides its Services;

Events.

We may meet you at events and you may provide us with your contact details in order for us to contact you about our Services; or

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources such as:

Contact data from providers, including third-party debt agencies.
Internet / LinkedIn / websites.

How 15below uses your personal data

15below will only use your personal data when the law allows us to, ie, if we have a legal basis for doing so, as outlined in this Policy or as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Where we act as the data controller for client contact information, we have set out below in the table a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact 15below if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you or the company that you are connected to as a new client and verify your identity (where required)	(a) Identity,(b) Contact	Performance of a contract or Legitimate interests or Consent
To process and deliver the Services including: (a) Manage accounts, payments, fees and charge, (b) contacting you and corresponding about the Services	(a) Identity, (b) Contact	Performance of a contract or Legitimate interests
To respond to queries and enquiries and dealing with your preferences and interests	(a) Identity, (b) Contact	Performance of a contract or Legitimate interests
To undertake marketing to you	(a) Identity,(b) Contact	Legitimate interests or Consent

Where we act as a data processor of personal data on behalf of our clients, we will process personal data in accordance with our clients’ instructions and for providing the Services, or in order to comply with a legal or regulatory obligation.

How your personal data may be shared

Where we act as the data controller for client contact information, or where permitted by 15below’s data controller clients, personal data processed by 15below may be shared as follows:

with any member of the 15below Group, which means 15below’s subsidiaries, 15below’s ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
with permitted third-party contractors of 15below for the purposes of providing Services to 15below or for performing its Services, helping us to deliver our products and information (“Data Processors” or “Sub-Processors”);
where 15below is under a duty to disclose your personal data to comply with any legal obligation or to enforce or apply 15below’s or terms and conditions and other agreements;
to protect the rights, property, or safety of 15below, 15below’s client, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws; or
with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

Where we provide your personal data to Data Processors or Sub-Processors we will have in place a written agreement with each third party confirming on what basis the third party will handle your personal data and will ensure that there are sufficient safeguards and processes in place to protect your personal data. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and only process that personal data in accordance with our (or our client’s) instructions.The third parties that we may send your personal data to are either within the European Economic Area (“EEA”) or to third parties under suitable protection mechanisms as laid out inapplicable Data Protection Legislation.

How 15below stores personal data

We are part of a Group of companies with offices in locations in the UK and Australia. We also contract with third parties who we may share your personal data with who are located outside of the UK and EEA. This means that from time to time we may transfer your personal data from within the UK or EEA to locations outside of the UK or EEA. In that case, we will ensure that the recipient is either located in a country to which the UK or EEA (as applicable) considers to be deemed to provide an adequate level of protection for personal data or to other countries where we have put in place adequate security mechanisms to ensure your personal data will be handled in a way that is required under applicable data protection legislation.

Data security

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed and have an Information Security Policy in place to which we adhere to. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Personal Data Retention

We will only retain personal data in accordance with our retention policy, which includes:

where we act as a data controller in connection with client contact information, for as long as necessary to fulfil the purposes we collected it for, eg, contracts information is kept for 7 years;
where we act as a data processor on behalf of its clients, for the period as notified or agreed with the data controller client;
in either case, for the period required for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

The right to be informed – this is information on for what purpose we are processing it and what personal data we are processing.
The right of access – you have the right to be provided with copies of the personal data of you that we are processing as well as confirmation of the processing we are doing. You can do this by sending a “subject access request” to the contact details noted above for our consideration.
The right to rectification – if you think the personal data that we hold on you is wrong you can tell us and we will fix it.
The right to erasure (also known as the right to be forgotten) – if you want us to permanently delete the personal data we hold for you then you can ask us to do so.
The right to restrict processing – if you do not like how we are using your personal data then you can let us know and we will stop processing it in that way.
The right to data portability – if you want us to pass on your personal data to someone else then please let us know. This transfer should not affect the integrity or otherwise damage your personal data.
The right to withdraw your consent – you can withdraw your consent for us to process your personal data (if we have relied on your consent to process your personal data) at any time by contacting us. If we have relied only on your consent as the basis to process your personal data then we will stop processing your personal data at the point you withdraw your consent. Please note that if we can also rely on other bases to process your personal data aside from consent then we may do so even if you have withdrawn your consent.
Rights in relation to automated decision making and profiling – if we use either automated decision making or profiling then you have a right to know. Also, we need your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

To exercise any of the above rights please email your request to [email protected].

Where you exercise your right to erasure (and we do not have another legal basis to hold on to that personal data) or where information is deleted in accordance with 15below’s retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period 15below retains the data.

Where you exercise your right to request access to the information 15below processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 15below will try to respond to all legitimate access requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Children

The Website is not intended for children and 15below will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.

Complaints

If you would like to make a complaint in relation to how 15below may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 15below would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

External Websites

The Website may, from time to time, contain links to and from the websites of 15below partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. 15below is not responsible for the content of external internet sites and you are advised to read the privacy policy of external sites before disclosing any personal data.

Use of cookies by us

Cookies

For information relation to the cookies we use on this website please see our cookies policy.
To find out more about cookies, generally including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Other tracking technologies

Tracking technologies may record information such as internet domain and host names, internet protocol addresses, browser software and operating system types, clickstream patterns and dates and times that our website is accessed. Our use of cookies and other tracking technologies allows us to improve our website and your experience. Please note that the tracking technologies record could include your personal data if we are, for example, tracking your internet protocol address. If you have any questions on this, please contact our data protection officer at [email protected]. You can also request that we stop processing such personal data.

We may also analyse information that does not contain personal data for trends and statistics.

Remember the Risks Whenever You Use the Internet

15below is committed to ensuring that your information is secure and has in place reasonable and proportionate safeguards and procedures to protect your personal data. While 15below does its best to protect your personal data, 15below cannot guarantee the security of any information that you transmit to 15below and you are solely responsible for maintaining the secrecy of any passwords or other account information.

Changes to this Privacy Policy and your duty to inform us of changes

As and when necessary, changes to this Privacy Policy will be posted here. Where changes are significant, we may also email all our registered users with the new details, and where required by law, we will obtain your consent to these changes.

This Privacy Policy was last updated on 11 May 2022.

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