Welcome to Briggs-Riley. This Privacy Notice explains what we do with your personal information when you are visiting https://www.briggs-riley.com or https://briggs-riley.co.uk (including the mobile optimised version accessible from your portable hand-held device) (“Website”) and social media pages, making a purchase or when you contact us by phone. It describes how we collect, use and process your personal information, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your rights.
For the purpose of applicable data protection legislation, Briggs & Riley Travelware LLC, whose registered office is at 400 Wireless Blvd Ste 1, Hauppauge, New York, 11788, USA, is the ‘controller’ of your personal information in the US, and Danzak Ltd, whose registered office is at 10 Station Rd, Henley on Thames, Oxfordshire RG9 1AY, UK, is the ‘controller’ of your personal information in the UK (“we”, “our” or “us”). This means we decide why and how your personal information is used and are responsible for protecting it. Please refer to the end of this notice for our contact and company information.
- INFORMATION WE COLLECT ABOUT YOU
When you use the Website, or interact with us offline, we collect and use information about you in the course of providing you with our products and services and with customer support. We may collect some or all of the information listed below to help us with this:
Contact details, full name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, internet protocol address, social media handle, email address, login credentials and account name
B. Personal information categories
Name, contact information and financial information
C. Protected classification characteristics
Gender and date of birth
D. Commercial information
Transaction information, purchase history, financial details, and payment information
E. Biometric information
Fingerprints and voiceprints
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
G. Geolocation data
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information
Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us
J. Education Information
Student records and directory information
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
Marketing preferences when you subscribe to receive updates or offers from us
L: Enquiry data
Information that you submit via any contact forms on the Website and any correspondence we have with you over email or phone
- HOW WE USE YOUR INFORMATION
The purposes for which we use your personal information and the lawful basis under data protection laws on which we rely to do this are explained below.
Where you have provided CONSENT
We will rely on your consent to send you the following where we invite you to opt-in on the Website:
- electronic marketing communications about our products and services, events, promotions and competitions; and
- personal information collected from non-strictly necessary cookies used on the Website (see our Cookies Notice for more information).
You may withdraw your consent at any time. Please see the Your Rights section below for further details.
Where it is required to complete or, at your request, take steps to enter into, a CONTRACT
The use of your personal information may be necessary to perform a contract that you have with us or perform steps you request to enter into a contract. For example, when you buy a product from us, we need to use your personal information to process your order, to send you the product, for billing purposes and to respond to any requests you may have. We also need to use your personal information to notify you about changes to our services.
Where there is a LEGAL REQUIREMENT
We will use your personal information to comply with our legal obligations, including where the law requires us:
- to respond or assist the public authorities or the police and other criminal investigation bodies;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to identify you when you contact us or to authenticate you when logging into your account;
- to verify the accuracy of data we hold about you; and
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression list in order to be able to comply with your request).
Where it is in your VITAL INTERESTS
We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue the following legitimate interests (whether ours, in connection with our business, or that of a third party), for some of the following purposes:
Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns
- to communicate marketing information to you by phone or by post;
- for analysis and insight conducted to inform our marketing strategies, and to enhance your visitor experience; and
- to tailor and personalise our marketing communications based on your activities and interests.
Processing necessary for us to support Website visitors and customers with their enquiries
- to respond to correspondence you send to us and fulfil the requests you make to us relating to our products and services;
Processing necessary for us to respond to changing market conditions and the needs of our guests and visitors
- to analyse, evaluate and improve our products and services so that your visit and use of the Website and social media pages are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
- to notify you about changes to our services;
- to administer the Website and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
- for the prevention of fraud and other criminal activities;
- to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or visitor;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to correspond or communicate with you in relation to administrative, legal and business matters;
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- to inform you of updates to our terms and conditions and policies;
- for our internal purposes, such as quality control, Website performance, system administration and to evaluate use of the Website, so that we can provide you with enhanced services;
- to assess and improve our service to customers through recordings of any calls with our contact centres; and
- for other general administration including managing your queries (including through social media), complaints, or claims, and to send service messages to you.
We may collect your preferences to receive marketing information directly from us by email or SMS in the following ways:
- if you fill out the form to receive more information and opt in to receive other communications from us; or
- if you register for an account, we will ask you if you would like to opt in to receive marketing information directly from us.
You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above at any time. Please see Your Rights below for further details on how you can do this.
- SHARING YOUR INFORMATION WITH THIRD PARTIES
We may share your information with any of the following trusted third parties:
- any of our group companies, where this is necessary, and in accordance with laws on data transfers;
- we use Shopify and their Shopify Partners to power our online store - you can read more about how Shopify uses your personal information here: https://www.shopify.com/legal/privacy;
- our payment providers when you make a purchase on this Website;
- tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- third party providers who assist with delivering our products to you;
- lawyers who provide us with legal and regulatory advice;
- third party data service providers who help us to understand our audience by providing additional information so that we can send the more relevant and targeted communications to you and other users;
- third party outsourced IT providers where we have an appropriate data processing agreement (or similar protections) in place;
- social media platforms, such as Meta;
- if a group company merges with or is acquired by another business or company in the future, we may share your personal information with the new owners of the business or company, as well as with any administrators or insolvency practitioners, where they are involved (and provide you with notice of this disclosure); and
- if we have to share your information to comply with legal or regulatory requirements. This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- SOCIAL MEDIA PLATFORMS
We use social media platforms to communicate with you and to promote products and services. We process your personal information as follows:
Meta uses this information to provide services to us and also for further processing for its own business purposes. We and Meta are joint controllers of the processing involved in collecting and sending your personal information to Meta using cookies and similar technologies as each of us has a business interest in Meta receiving this information. You can find out more about these technologies by visiting our Cookies Notice. The services we receive from Meta that use this information are delivered to us through Meta’s Business Tools. These tools allow us to target advertising to you within Meta’s social media platform by creating audiences based on your actions on our website and allow Meta to improve and optimise the targeting and delivery of our advertising campaigns for us.
Our relationship with Meta. As we are joint controllers with Meta for certain processing, we have:
- entered into an agreement in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
- agreed that we are responsible for providing you with the information in this privacy notice about our relationship with Meta; and
- agreed that Meta is responsible for responding to you when you exercise your rights under data protection laws in relation to the platform’s processing of your personal information as a joint controller.
Meta also processes, as our processor, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include processing carried out by the platform when they display our advertisements to you in your news feed at our request after matching contact details for you that we have uploaded to them. These advertisements may include forms through which we collect contact information you give to us.
Further information. The Meta company that is a joint controller of your personal information is Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4 Ireland in the EU and Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA in the UK. For further information regarding Meta and their use of your personal information, please see:
- Meta’s EU Controller Addendum for Business Tools and UK Controller Addendum for Business Tools which include information regarding how our and Meta’s responsibilities to you are allocated as controllers of your personal information; and
- Meta's Data Policy at https://www.facebook.com/about/privacy which includes details of the legal reasons (known as ‘lawful bases’) on which the platform relies to process your personal information, together with details regarding your data protection rights.
- WHERE WE STORE YOUR INFORMATION
We are headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard contractual clauses, UK Addendum to the standard contractual clauses and a global data transfer agreement, to ensure that any transferred personal information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below.
- HOW WE SAFEGUARD YOUR INFORMATION
We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal information.
We have a management system and implements appropriate security measures to maintain integrity and security and prevent unauthorised access, loss, manipulation or leaks etc., of personal information. Furthermore, where the processing of personal information is subcontracted, we make efforts to protect such personal information by selecting subcontractors who handle personal information appropriately and by prescribing the necessary measures to the subcontractor for appropriate management of personal information.
If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately by contacting us using the details provided at the end of this notice.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to the Website and any transmission is at your own risk.
The Website may from time to time contain links to and from other websites. If you follow a link to any of those websites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies. Please check those privacy policies before you submit your information to those websites.
- HOW LONG WE KEEP YOUR INFORMATION
We will retain your personal information for as long as you have a relationship with us and for a period of time after your relationship with us has ended.
When determining how long this retention period will last once the purpose of processing the personal information has been satisfied, we take into account the length of time personal information is required to:
- Continue to develop, tailor, upgrade, and improve our services;
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under the law;
- Defend or bring any existing or potential legal claims; or
- Address any complaints you may have.
When personal information is no longer required due to the expiration of the personal information holding period, or the purpose for which the personal information has been obtained has been achieved, we will destroy the personal information in accordance with our retention policy.
- DO WE COLLECT INFORMATION FROM MINORS
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us on the details provided below in 13. How to contact us.
- YOUR RIGHTS
In accordance with applicable law, you may have a number of rights in relation to your information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either: (i) the date that we have confirmed your identity; or (ii) where we do not need to do this because we already have this information, from the date we received your request.
We will process all such requests in accordance with applicable local laws.
Right to confirm
You may have the right to confirm whether or night we process your personal information.
Right to object
This right enables you to object to us processing your personal information where we do so for one of the following reasons:
- where we rely on our legitimate interests to do process your information;
- to enable us to perform a task in the public interest or exercise official authority; or
- to send you direct marketing materials and where your right to withdraw consent does not apply.
Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your personal information for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your personal information.
Right to withdraw consent
Where we have obtained your consent to process your personal information for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your personal information for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
To withdraw your consent to marketing communications, please use the unsubscribe tool in the relevant communication. Alternatively, you can contact us using the contact details provided below in 13. How to contact us.
Right of access (‘Data Subject Access Requests’)
You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.
If you would like to request access to your information, it would assist us with dealing with your request if you could use the subject heading ‘Data Subject Access Request’, or quote this over the phone, when contacting us. Please note that this is not mandatory, and we will still deal with any requests without this reference.
Right to erasure
You have the right to request that we erase your personal information in certain circumstances. Normally, this right exists where:
- the data is no longer necessary;
- you have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
- the data has been processed unlawfully;
- it is necessary for the data to be erased in order for us to comply with our obligations under law; or
- you object to the processing of your data and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
Right to restrict processing
You have the right to request that we restrict our processing of your personal information in certain circumstances, for example if you dispute the accuracy of the personal information that we hold about you, you object to our processing of your personal information for our legitimate interests or you require us to keep it in connection with legal proceedings. If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.
We may only process your information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties to whom we have disclosed the inaccurate or incomplete personal information. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability
If you wish, you have the right to transfer your personal information between service providers where we rely on your consent or the performance of your contract as the lawful basis to use that information. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you if technically possible.
Rights relating to automated decisions
In certain circumstances, you may contest a decision made about you based purely on automated processing and where the processing is not required by law. You may also ask us to stop making such decisions using automated processing alone.
Right to complain
If you would like to make a complaint or if you have any questions about how we use or keep your personal information, you may contact us using the contact details provided below in 13. How to contact us.
You may have the right to lodge a complaint with the relevant supervisory authority for your jurisdiction (e.g., your attorney general’s office or supervisory authority), if you believe our processing of your personal information violates applicable law.
You have the right not to receive discriminatory treatment by us for the exercise of your rights conferred by local privacy laws.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us on the details provided below in 13. How to contact us.
Opt-out of profiling
You may have the right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, including automated decisions.
Targeted advertising opt-out
You may have the right to opt-out of personal information processing for targeted advertising purposes.
Right to appeal
You may have the right to appeal when we determine we will not act on a request made by you. To appeal any decision made by us, please contact us on the details provided below in 13. How to contact us.
Opt-out of sale
We do not currently sell the personal information of our consumers. However, if we do sell any personal information, you may also have a right to opt-out of certain personal information sales.
Upon receiving your request, we will need to verify your identity to determine you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
How to exercise your rights
If you would like to exercise any of these rights, please contact us on the details provided below in 13. How to contact us. Please note that we may keep a record of your communications to help us resolve any issues that you raise.
- Do Not Track
Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.
We may make changes to this Privacy Notice at any time by posting a copy of the modified notice on the Website or, where appropriate, by sending you an email with that notice. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Website, whichever is the earlier.
- HOW TO CONTACT US
If you have any queries about this Privacy Notice, including your rights in relation to your personal information, please contact us at:
UK: email@example.com or call us at +44 (0) 1491 642 333.
US: firstname.lastname@example.org or call us at 1-877-745-3978.
UPDATED OCTOBER 2023