We respect your privacy and are committed to protecting it through our compliance with this
you or that you may provide (“Personal Information”) on the 15degreeslondon.com website
(“Website” or “Service”) and any of its related products and services (collectively, “Services”),
and our practices for collecting, using, maintaining, protecting, and disclosing that Personal
Information. It also describes the choices available to you regarding our use of your Personal
Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and
15DEGREESLONDON (“15DEGREESLONDON”, “we”, “us” or “our”). If you are entering into
this agreement on behalf of a business or other legal entity, you represent that you have the
authority to bind such entity to this agreement, in which case the terms “User”, “you” or
“your” shall refer to such entity. If you do not have such authority, or if you do not agree with
the terms of this agreement, you must not accept this agreement and may not access and
use the Website and Services. By accessing and using the Website and Services, you
acknowledge that you have read, understood, and agree to be bound by the terms of this
Policy. This Policy does not apply to the practices of companies that we do not own or
control, or to individuals that we do not employ or manage.
Automatic collection of information
Our top priority is customer data security and, as such, we exercise the no logs policy. We
may process only minimal user data, only as much as it is absolutely necessary to maintain
the Website and Services. Information collected automatically is used only to identify
potential cases of abuse and establish statistical information regarding the usage and traffic
of the Website and Services. This statistical information is not otherwise aggregated in such
a way that would identify any particular user of the system.
Collection of personal information
You can access and use the Website and Services without telling us who you are or
revealing any information by which someone could identify you as a specific, identifiable
individual. If, however, you wish to use some of the features offered on the Website, you may
be asked to provide certain Personal Information (for example, your name and e-mail
We receive and store any information you knowingly provide to us when you create an
account, make a purchase, or fill any online forms on the Website. When required, this
information may include the following:
- Contact information (such as email address, phone number, etc)
- Basic personal information (such as name, country of residence, etc)
Some of the information we collect is directly from you via the Website and Services.
However, we may also collect Personal Information about you from other sources such as
public databases, social media platforms, third-party data providers, and our joint marketing
partners. Personal Information we collect from other sources may include demographic
information, such as age and gender, device information, such as IP addresses, location,
such as city and state, and online behavioral data, such as information about your use of
social media websites, page view information and search results and links.
You can choose not to provide us with your Personal Information, but then you may not be
able to take advantage of some of the features on the Website. Users who are uncertain
about what information is mandatory are welcome to contact us.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If
you are under the age of 18, please do not submit any Personal Information through the
Website and Services. If you have reason to believe that a child under the age of 18 has
provided Personal Information to us through the Website and Services, please contact us to
request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to
help enforce this Policy by instructing their children never to provide Personal Information
through the Website and Services without their permission. We also ask that all parents and
legal guardians overseeing the care of children take the necessary precautions to ensure
that their children are instructed to never give out Personal Information when online without
Use and processing of collected information
We act as a data controller and a data processor in terms of the GDPR when handling
Personal Information, unless we have entered into a data processing agreement with you in
which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information.
We act in the capacity of a data controller when we ask you to submit your Personal
Information that is necessary to ensure your access and use of the Website and Services. In
such instances, we are a data controller because we determine the purposes and means of
the processing of Personal Information and we comply with data controllers’ obligations set
forth in the GDPR.
We act in the capacity of a data processor in situations when you submit Personal
Information through the Website and Services. We do not own, control, or make decisions
about the submitted Personal Information, and such Personal Information is processed only
in accordance with your instructions. In such instances, the User providing Personal
Information acts as a data controller in terms of the GDPR.
In order to make the Website and Services available to you, or to meet a legal obligation, we
may need to collect and use certain Personal Information. If you do not provide the
information that we request, we may not be able to provide you with the requested products
or services. Any of the information we collect from you may be used for the following
- Fulfill and manage orders
- Deliver products or services
- Send administrative information
- Send marketing and promotional communications
- Respond to inquiries and offer support
- Deliver targeted advertising
- Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and
Services, where you are located in the world and if one of the following applies: (i) you have
given your consent for one or more specific purposes; this, however, does not apply,
whenever the processing of Personal Information is subject to California Consumer Privacy
Act or European data protection law; (ii) provision of information is necessary for the
performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii)
processing is necessary for compliance with a legal obligation to which you are subject; (iv)
processing is related to a task that is carried out in the public interest or in the exercise of
official authority vested in us; (v) processing is necessary for the purposes of the legitimate
interests pursued by us or by a third party.
We rely on the following legal bases as defined in the GDPR upon which we collect and
process your Personal Information:
- User’s consent
Note that under some legislations we may be allowed to process information until you object
to such processing by opting out, without having to rely on consent or any other of the legal
bases above. In any case, we will be happy to clarify the specific legal basis that applies to
the processing, and in particular whether the provision of Personal Information is a statutory
or contractual requirement, or a requirement necessary to enter into a contract.
In case of Services requiring payment, you may need to provide your credit card details or
other payment account information, which will be used solely for processing payments. We
use third-party payment processors (“Payment Processors”) to assist us in processing your
payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American
Express and Discover. Sensitive and private data exchange happens over a SSL secured
communication channel and is encrypted and protected with digital signatures, and the
Website and Services are also in compliance with strict vulnerability standards in order to
create as secure of an environment as possible for Users. We will share payment data with
the Payment Processors only to the extent necessary for the purposes of processing your
payments, refunding such payments, and dealing with complaints and queries related to
such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you,
which allows them to process your payments (e.g., your email address, address, credit card
details, and bank account number) and handle all the steps in the payment process through
their systems, including data collection and data processing. The Payment Processors’ use
of your Personal Information is governed by their respective privacy policies which may or
may not contain privacy protections as protective as this Policy. We suggest that you review
their respective privacy policies.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or
provide any Service you have requested, we may share your information with our affiliates,
contracted companies, and service providers (collectively, “Service Providers”) we rely upon
to assist in the operation of the Website and Services available to you and whose privacy
policies are consistent with ours or who agree to abide by our policies with respect to
Personal Information. We will not share any personally identifiable information with third
parties and will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as
necessary to perform services on our behalf or comply with legal requirements. Service
Providers are given the information they need only in order to perform their designated
functions, and we do not authorize them to use or disclose any of the provided information
for their own marketing or other purposes.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our
legal obligations, to enforce our agreements, resolve disputes, and unless a longer retention
period is required or permitted by law up to a maximum of 36 months.
We may use any aggregated data derived from or incorporating your Personal Information
after you update or delete it, but not in a manner that would identify you personally. Once the
retention period expires, Personal Information shall be deleted. Therefore, the right to
access, the right to erasure, the right to rectification, and the right to data portability cannot
be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your
information in a country other than your own. However, this will not include countries outside
the European Union and European Economic Area. If any such transfer takes place, you can
find out more by checking the relevant sections of this Policy or inquire with us using the
information provided in the contact section.
Data protection rights under the GDPR
If you are a resident of the European Economic Area (“EEA”), you have certain data
protection rights and we aim to take reasonable steps to allow you to correct, amend, delete,
or limit the use of your Personal Information. If you wish to be informed what Personal
Information we hold about you and if you want it to be removed from our systems, please
contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to
the processing of your Personal Information. To the extent that the legal basis for our
processing of your Personal Information is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of processing before the
(ii) You have the right to learn if your Personal Information is being processed by us, obtain
disclosure regarding certain aspects of the processing, and obtain a copy of your Personal
Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated
or corrected. You also have the right to request us to complete the Personal Information you
believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is
carried out on a legal basis other than consent. Where Personal Information is processed for
the public interest, in the exercise of an official authority vested in us, or for the purposes of
the legitimate interests pursued by us, you may object to such processing by providing a
ground related to your particular situation to justify the objection. You must know that,
however, should your Personal Information be processed for direct marketing purposes, you
can object to that processing at any time without providing any justification. To learn whether
we are processing Personal Information for direct marketing purposes, you may refer to the
relevant sections of this Policy.
(v) You have the right, under certain circumstances, to restrict the processing of your
Personal Information. These circumstances include: the accuracy of your Personal
Information is contested by you and we must verify its accuracy; the processing is unlawful,
but you oppose the erasure of your Personal Information and request the restriction of its
use instead; we no longer need your Personal Information for the purposes of processing,
but you require it to establish, exercise or defend your legal claims; you have objected to
processing pending the verification of whether our legitimate grounds override your
legitimate grounds. Where processing has been restricted, such Personal Information will be
marked accordingly and, with the exception of storage, will be processed only with your
consent or for the establishment, to exercise or defense of legal claims, for the protection of
the rights of another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal
Information from us. These circumstances include: the Personal Information is no longer
necessary in relation to the purposes for which it was collected or otherwise processed; you
withdraw consent to consent-based processing; you object to the processing under certain
rules of applicable data protection law; the processing is for direct marketing purposes; and
the personal data have been unlawfully processed. However, there are exclusions of the
right to erasure such as where processing is necessary: for exercising the right of freedom of
expression and information; for compliance with a legal obligation; or for the establishment,
to exercise or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in a
structured, commonly used, and machine-readable format and, if technically feasible, to
have it transmitted to another controller without any hindrance from us, provided that such
transmission does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and
use of your Personal Information. If you are not satisfied with the outcome of your complaint
directly with us, you have the right to lodge a complaint with your local data protection
authority. For more information, please contact your local data protection authority in the
EEA. This provision is applicable provided that your Personal Information is processed by
automated means and that the processing is based on your consent, on a contract which
you are part of, or on pre-contractual obligations thereof.
California privacy rights
Consumers residing in California are afforded certain additional rights with respect to their
Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a
California resident, this section applies to you.
In addition to the rights as explained in this Policy, California residents who provide Personal
Information as defined in the statute to obtain Services for personal, family, or household use
are entitled to request and obtain from us, once a calendar year, information about the
categories and specific pieces of Personal Information we have collected and disclosed.
Furthermore, California residents have the right to request deletion of their Personal
Information or opt-out of the sale of their Personal Information which may include selling,
disclosing, or transferring Personal Information to another business or a third party for
monetary or other valuable consideration. To do so, simply contact us. We will not
discriminate against you if you exercise your rights under the CCPA.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details
provided in this document. Please note that we may ask you to verify your identity before
responding to such requests. Your request must provide sufficient information that allows us
to verify that you are the person you are claiming to be or that you are the authorized
representative of such person. If we receive your request from an authorized representative,
we may request evidence that you have provided such an authorized representative with
power of attorney or that the authorized representative otherwise has valid written authority
to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and
respond to it. We cannot respond to your request or provide you with Personal Information
unless we first verify your identity or authority to make such a request and confirm that the
Personal Information relates to you.
Our Website and Services use “cookies” to help personalize your online experience. A
cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be
used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to
you, and can only be read by a web server in the domain that issued the cookie to you. You
may learn more about cookies and how they work in this guide.
and for statistical purposes. For further information on the cookies we collect and their
cookies. Most web browsers automatically accept cookies by default, but you can modify
your browser settings to decline cookies if you prefer.
beacons, or other similar information-gathering technologies to collect standard internet
activity and usage information. The information gathered is used to compile statistical reports
on User activity such as how often Users visit our Website and Services, what pages they
visit and for how long, etc. We use the information obtained from these analytics tools to
monitor the performance and improve our Website and Services. We do not use third-party
analytics tools to track or to collect any personally identifiable information of our Users and
we will not associate any information gathered from the statistical reports with any individual
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you
do not want to have your online activity tracked. Tracking is not the same as using or
collecting information in connection with a website. For these purposes, tracking refers to
collecting personally identifiable information from consumers who use or visit a website or
online service as they move across different websites over time. How browsers
communicate the Do Not Track signal is not yet uniform. As a result, the Website and
Services are not yet set up to interpret or respond to Do Not Track signals communicated by
your browser. Even so, as described in more detail throughout this Policy, we limit our use
and collection of your Personal Information.
We may permit certain third-party companies to help us tailor advertising that we think may
be of interest to Users and to collect and use other data about User activities on the
Website. These companies may deliver ads that might place cookies and otherwise track
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are
committed to keeping your e-mail address confidential and will not disclose your email
address to any third parties except as allowed in the information use and processing section
or for the purposes of utilizing a third-party provider to send such emails. We will maintain
the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the
e-mail is from and provide clear information on how to contact the sender. You may choose
to stop receiving our newsletter or marketing emails by following the unsubscribe instructions
included in these emails or by contacting us. However, you will continue to receive essential
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled
by us. Please be aware that we are not responsible for the privacy practices of such other
resources or third parties. We encourage you to be aware when you leave the Website and
Services and to read the privacy statements of each and every resource that may collect
We secure information you provide on computer servers in a controlled, secure environment,
protected from unauthorized access, use, or disclosure. We maintain reasonable
administrative, technical, and physical safeguards in an effort to protect against unauthorized
access, use, modification, and disclosure of Personal Information in our control and custody.
However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i)
there are security and privacy limitations of the Internet which are beyond our control; (ii) the
security, integrity, and privacy of any and all information and data exchanged between you
and the Website and Services cannot be guaranteed; and (iii) any such information and data
may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use
to communicate with us and the security you use to protect your credentials, please take
appropriate measures to protect this information.
In the event we become aware that the security of the Website and Services has been
compromised or Users’ Personal Information has been disclosed to unrelated third parties as
a result of external activity, including, but not limited to, security attacks or fraud, we reserve
the right to take reasonably appropriate measures, including, but not limited to, investigation
and reporting, as well as notification to and cooperation with law enforcement authorities. In
the event of a data breach, we will make reasonable efforts to notify affected individuals if we
believe that there is a reasonable risk of harm to the User as a result of the breach or if
notice is otherwise required by law. When we do, we will send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at
any time at our discretion. When we do, we will revise the updated date at the bottom of this
page. We may also provide notice to you in other ways at our discretion, such as through the
contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the
revised Policy unless otherwise specified. Your continued use of the Website and Services
after the effective date of the revised Policy (or such other act specified at that time) will
constitute your consent to those changes. However, we will not, without your consent, use
your Personal Information in a manner materially different than what was stated at the time
your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By
accessing and using the Website and Services and submitting your information you agree to
be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not
authorized to access or use the Website and Services.
If you have any questions, concerns, or complaints regarding this Policy, the information we
hold about you, or if you wish to exercise your rights, we encourage you to contact us using
the details below:
We will attempt to resolve complaints and disputes and make every reasonable effort to
honor your wish to exercise your rights as quickly as possible and in any event, within the
timescales provided by applicable data protection laws.
This document was last updated on August 5, 2021