Fifteen24, Inc. ("we", "our", "us" or "Fifteen24") are committed to protecting the privacy of all users of our websites, fifteen24.be and theupcrew.com(together, the "Sites"). Please read the following privacy policy that explains how we use and protect your information. We’ll be the "data controller" of the information you provide to us.

1. CONTACT DETAILS

If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us using the following email address: hello@fifteen24.co.

2. HOW WE COLLECT YOUR INFORMATION

  1. We collect your personal information when you interact with us or use our services, such as when you use our Sites. We also look at how visitors use our Sites, to help us improve our services and optimize customer experience.
  2. We collect information:
    • when you contact us directly via email, phone, post, message or via our chat function; and
    • when you browse and use our Sites (before and after you create an account with us).
  3. We also collect information from third-party sites, such as advertising platforms.

3. INFORMATION THAT WE COLLECT FROM YOU

  1. As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you.
  2. We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via email, letter, phone or chat function. If you contact us by phone, we make notes in relation to your call.
  3. We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.
  4. We also collect information about your use of our services through a mobile device, for example, carrier and location data. Unless you have elected to remain anonymous through your device or platform settings, this information may be collected and used by us automatically if you visit our Sites through your mobile browser or otherwise.

4. USE OF YOUR INFORMATION

  1. We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.
  2. We also process your data where we have a justifiable reason for doing so— for example:
    • to personalize our marketing communications;
    • to contact you for your views and feedback;
    • to analyze your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes;
    • to tailor content we display to you based on characteristics determined by us;
    • or if you submit comments or feedback regarding the Sites, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you with your first name and city you live in after asking a written permission.
  3. Where we rely on justifiable reasons for processing your personal information, we carry out a 'balancing test' to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our justifiable reasons for processing your data.
  4. Where we are under a legal obligation to do so we may use your information to:
    • comply with any legal obligation or regulatory requirement to which we are subject.

5. COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly.

6. EMAIL MARKETING

Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services that may be of interest to you and we may contact you to do so by email. Our emails always provide an option below to unsubscribe from further emails from Fifteen24.

7. RETENTION OF YOUR INFORMATION

  1. We will not retain your information for any longer than we think is necessary.
  2. When determining the relevant retention periods, we will take into account factors including:
    • legal obligation(s) under applicable law to retain data for a certain period of time;
    • the statute of limitations under applicable law(s);
    • our legitimate interest for processing;
    • guidelines issued by relevant data protection authorities.

8. DISCLOSURE OF YOUR INFORMATION

  1. The information we collect about you will be transferred to and stored on our servers. We are very careful and transparent about who else your information is shared with globally.
  2. Sharing your information with third parties. We share your information with third-party service providers. The types of third party service providers whom we share your information with includes:
    • IT service providers (including cloud providers): for the purposes of data storage and analysis;
    • Customer support partners: who will help us to resolve any issues you may have with our services; and
    • Marketing and advertising partners: so that they can ensure that you receive advertising which is the most relevant to you and send you email marketing on our behalf.
  3. If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
  4. International transfers of data
    • In some cases, the personal data we collect from you might be processed outside the European Economic Area ("EEA"), such as the United States. These countries may not have the same protections for your personal data as the EEA has. However, we are obliged to ensure that the personal data that is processed by us and our suppliers outside of the EEA is protected in the same ways as it would be if it was processed within the EEA.

9. SECURITY

  1. We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.
  2. We take steps to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction, and damage.
  3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to us via the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

10. YOUR RIGHTS

  1. Under data protection law, you have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact us using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.
  2. The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
  3. The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
  4. The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in the information that we hold by contacting us (see Contact Details). This right is not absolute and only applies in particular circumstances.
  5. The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details).
  6. The right to restrict processing. You have rights to 'block' or 'suppress' further use of your information. When processing is restricted, we can still store your information, but will not use it further.
  7. The right to data portability. You have the right to obtain your personal information in a structured format, commonly used so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
  8. The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the competent data protection authority.
  9. The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. if we rely on consent as a legal basis for processing certain information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not, however, make unlawful our use of your information while consent had been apparent.
  10. The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling.

11. CHANGES TO OUR PRIVACY POLICY

Any changes to our privacy policy will be posted to the Sites and, where appropriate, we will notify you of the changes for example by email.

This privacy policy was last updated: 24/05/2018

12. COMPLAINTS

If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:

The Belgian Data Protection Authority:

  • Address: Commission for the Protection of Privacy, Rue de la Presse, 35, 1000 Brussels (Belgium)
  • Telephone number: +32 (0) 2 274 48 00
  • Website: https://www.privacycommission.be