Next 15 Group Plc Privacy Notice

Last Updated: 13 March 2024

About this Notice

This privacy notice (Notice) explains how Next 15 Group Plc, (we, our, us, Next 15) collects, uses and shares ("processes") personal data in the course of its business activities.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice alongside any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Next 15 is a growth consultancy group made up of different companies globally, details of which can be found here https://www.next15.com/portfolio/. This privacy notice is issued on behalf of Next 15, but each of our brands will have their own privacy notices set out on their own websites.

Data Controller and Data Protection Officer Details

For the purposes of any applicable data protection laws in England and Wales, including the Data Protection Act 2018 (DPA) the UK General Data Protection Regulation (UK GDPR) and General Data Protection Regulation EU 2016/679 (EU GDPR), Next 15 is the data controller of your personal data. Next 15 has appointed a Data Protection Officer, who can be contacted via:

  • Email at dpo-hub@next15.com or
  • By writing to: FAO Data Protection and Privacy Office, Next 15 Group plc., 60 Great Portland Street, London, W1W 7RT. 

The Data We Collect About You

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

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you.
  • Online and Transactional Data includes internet protocol (IP) address, your login data, 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.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Data related to your opinions and preferences such as when you interact with us by email, phone or otherwise online or when you complete surveys in order to give us feedback in relation to our services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

There may be times where we process Special Categories of Personal Data 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). If we have occasion to do so we will always provide you with specific information around that processing activity and the relevant lawful basis that will apply.

If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • fill in our contact form on our website; 
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • give us some feedback; or
    • provide us with services.
  • Automated technologies or interactions. As you interact with our website, we may ask for your consent to collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy  for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • From publicly available sources such as internet search engines, social media sites, companies house and the electoral register.
    • From third parties that provide us with services such as providers of technical services, payment providers, ticket vendors and delivery services.
    • From data contributors and intermediaries such as software houses, data brokers or aggregators.
    • From professional service providers such as lawyers, accountants and from financial brokers when engaging with them in the M&A process.
    • From risk analysis, fraud prevention, credit reference agencies and identity verification companies.
    • From third parties in connection with any acquisition or merger of a business by us.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to process your personal data in order to enter into a contract with you or to perform processing activities as set out in the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have your consent in order to process your personal data.

Purposes For Which We Will Use Your Personal Data

We have set out below, in table format, a description of all the ways we may use your personal data, and which of the legal bases we would rely on to do so. We have also identified what our legitimate interests would be 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 us if you need details about the specific legal grounds 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 as a new supplier or client of a Next 15 group company (a) Identity
(b) Contact
 		 (a) Performance of a contract with you
To process and deliver
any services (or our receipt of services):
(a)Manage payments, fees and charges
(b)Collect and recover money owed to us
 		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
 		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
 
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

 (a) Identity
(b) Contact
(c) Marketing and Communications
 		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services)
(d) Consent 
 

 

Purpose/Activity Purpose/Activity Lawful basis for processing including basis of legitimate interest
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
 		 (a) Identity
(b) Contact
(c) Online and Transactional Data
 		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation.
(c) Consent 
 
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Usage
(d) Marketing and
Communications
(e) Online and Transactional Data
 		 (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
(b) Consent 
 
To use data analytics to improve our website, products/ services, marketing, customer relationships and experiences (a) Online and Transactional Data Usage (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Consent 
 
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity
(b) Contact
(c) Online and Transactional Data Usage
 		 (a) Necessary for our legitimate interests (to develop our products/ services and grow our business)
To process any data related to the merger and acquisition process.  (a) Identity
(b) Contact 
 		 (a) Necessary in order to enter into a contract with you
(b) Necessary for our legitimate interests (in order to ensure that we are running a robust due diligence process)
(c) Legal Obligation 
 

 

Marketing

We will only send you marketing information regarding:

  • our own products and services.
  • industry related insights and news.

You have the right to stop the use of your personal data for direct marketing activity. Please contact us if you no longer wish to receive marketing communications.

If you do choose to stop receiving marketing communications from us, we will ensure that you do not receive such material going forward unless you specifically request it in the future.

Please note even although you have opted out of receiving marketing communication from us, we will still continue to send you any necessary information regarding any products of services you continue to have with us or communications we are required to issue in order to fulfil or legal and regulatory obligations.

Third Party Websites

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Automated Decision Making and Profiling

Your data will not be subject to automated decision making or profiling.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Data Protection and Privacy Office. 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 so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data and data sharing

We might share you personal information with two types of organisation – companies within our Group or other third parties. We will not share any of your personal data other than for the purposes described in this Notice.

Intra Group Data Sharing

In order to provide our services your personal information may be shared with other companies in the our Group. Your personal information might be shared for our general business administration, efficiency, for the prevention and detection of fraud, when giving effect to a multi brand tender or project or when we make changes to our Group company structure.

Disclosure to third parties outside our Group

We also disclose your personal data to the types of third party listed below for the purposes described I this privacy notice. This might include: 

  • Regulators who govern how we operate including the HRMC, the ICO and the Advertising Standards Authority. 
  • The police, courts and other third partes or law enforcement agencies where reasonably necessary for the prevents or detection of crime;
  • Debt collection, credit reference and fraud prevents agencies or any organization we instruct to commence legal proceedings against you;
  • Legal advisers, accountants, auditors, financial institutions and professional service firms who act on our or your behalf, or who represent a third-party claimant;
  • Our third-party services providers such as IT suppliers, actuaries, auditors, marketing agencies, providers of market research services, including customer feedback surveys, referral administrators, document management providers and tax advisers;
  • Third parties in connection with any sale, transfer, or disposal of our business;
  • We may also disclose your personal information to other third parties where the disclosure is required by law or by a regulator with authority over us on the grounds of substantial public interest.
  • 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 notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Data Transfers

As set about above we may share your personal data within our Group. This may involve transferring your data outside of the UK and the European Economic Area (EEA). We have therefore entered into a specific intra-group contract utilising the International Data Transfer Addendum to the European Commission’s Standard Contractual clauses for International data transfers.

Many of our external third party services providers are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the UK or the EEA to these third parties, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government. 
  • Where we use certain service providers, we may use specific contracts approved by the European Commission or the Security of State for the United Kingdom as affected by the Information Commissioners Office which give personal data the same protection it has in Europe and the UK

Please contact the Data Protection and Privacy Office if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances we may retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your relationship with us. Where your personal data is no longer required, we will ensure it is either securely deleted or stored in a way that no longer identifies you. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you would like further details regarding our records retention, please contact the Data Protection and Privacy Office. 

Your Rights

Under the applicable data protection laws you have the following rights:

  • to obtain access to, and copies of, the personal data we hold about you;
  • to require that we cease processing your personal data if the processing is causing you damage or distress;
  • to require us not to send you marketing communications;
  • to request that we erase your personal data;
  • to request that we restrict our data processing activities in relation to your personal data;
  • to receive from us the personal data we hold about you, which you have provided to us, in a reasonable format specified by you, including for the purpose of transmitting that personal data to another data controller; and
  • to require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and requests may be refused where exceptions apply.

If you have any questions about these rights or how your personal data is used by us, you should contact the Data Protection and Privacy Office.

No Fee Usually Required

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.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Contact and Complaints

If you have any queries about this privacy notice or how we process your personal data, if you would like to make a complaint or if you wish to exercise any of your right please contact the Data Protection and Privacy Office at dpo-hub@next15.com or in writing to:

The Data Protection and Privacy Office
60 Great Portland Street, 
London, 
W1W 7RT

If following such referral, you are still not satisfied with how your personal data is used by Next 15 you can make a complaint to the Information Commissioner (www.ico.org.uk).

Changes To This Notice

Next 15 will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.