Privacy Notice

Version: March 2020

This privacy notice was last updated on 5th March 2020.

This privacy notice sets out the basis on which we collect and process your personal data through the use of our website, our digital applications, and/or signing up for newsletters and other marketing activities either in person or online.

Any changes we make to this policy in the future will be posted on this page so please check this page regularly.

Who We Are

Spacemiles Holdings Ltd is the Data Controller responsible for your personal data within the context of the data you choose to directly pass to us through our website, digital applications, marketing activities, by email, phone or face to face.

Spacemiles Holdings Ltd will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Spacemiles Holdings Ltd determines the purposes and way in which any personal data are, or will be, processed.

Our registered office is at Burleigh Manor, Peel Road, Douglas, Isle of Man .

If you have any questions about this privacy notice, the use of your personal information, your dealings with our website or our digital applications, you can contact us at

When We Are Not The Data Controller

Spacemiles Holdings Ltd provide branding, customer acquisition, workflow automation and digital experience services to our clients who wish to transform their business.

This notice does not apply to our clients businesses where Spacemiles Holdings Ltd is not the Data Controller and where you do not have a relationship with Spacemiles Holdings Ltd.

If you have any questions about our clients use of your personal information, please contact them directly.

In respect of some of our clients business, we may or may not be a data processor. In so far as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

Our Principles of Data Protection

Spacemiles Holdings Ltd are committed to safeguarding the privacy of our website visitors and service users and complying with the General Data Protection Regulation and the Data Protection Act 2018 ("Data Protection Laws").

Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you the best user experience.

We have published this notice to help you understand

  • how and why Spacemiles Holdings Ltd collect information from you;
  • who we share your information with, why and on what basis; and
  • what your rights are.

What information we collect and why?

Information you provide to us directly

When you visit or use some parts of our website and/or services we might ask you to provide personal data to us. For example we ask you for your contact information when you submit an enquiry, submit your CV for a job application, submit a quote request, book an appointment, give feedback, send us a brief etc...

Where you are requested to fill in form (either online or offline), it’s your choice as to which fields to complete and with what data.

If you don’t want to provide us with your personal data you don’t have to but it might mean you can’t use some parts of our website or service.

Information we collect automatically

We collect some information about you automatically when you visit our websites and or use our services, like your IP address and device type. We also collect information when you navigate through our website and digital applications such as what pages you looked at and what links you clicked on and so on. This information is useful as it helps us get a better understanding of how you use our websites and services so that we can continue to provide the best experience possible.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more, take a look at our cookie policy.

When you visit us at our offices Spacemiles Holdings Ltd uses CCTV for security monitoring purposes.

Information we get from third parties

The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publically available materials. We may use this information to supplement the personal data we already hold on you, in order to better inform, personalise and improve our services and to validate the personal information you provide.

Where we collect personal data, we’ll only process it:

  • To perform a contract with you, or
  • Where we have legitimate interests to process the personal data and they’re not overridden by your rights
  • In accordance with a legal obligation or
  • Where we have your consent

How do we use your information?

Data Protection Laws say that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and in relation to our use of your data these are:

  • Contract - your personal information is processed in order to fulfil a contractual arrangement
  • Consent – where you agree to us using your information in this way
  • Legitimate Interests - this means the interests of Spacemiles Holdings Ltd in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Parties in order to deliver you the requested service
  • Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.

What We Use Your Personal Information For

Our Reasons (Legal Basis)

Our Explanation Of Spacemiles Holdings Ltd’s Legitimate Interests

To communicate with you or to market to you

Consent or Legitimate Interest

Marketing communications in accordance with your marketing preferences

Asking you for feedback or to take part in research we are conducting

To advertise to you using targeted display advertising Legitimate interest

Targeted advertising enables us to operate our websites without excessive intrusion to individuals viewing the advertising

To provide you with services

Contract or Legal Obligation

In order to perform a contractual relationship

Provide you with the information you’ve requested

Operational communications like changes to our websites and services, security updates or assistance with using our services

Billing Communications

To analyse, aggregate and report

Legitimate Interest

Monitoring and improving our website and services (whether obtained directly or from third parties).

This is typically but not always anonymised analytics and reports.

To develop new sites and offerings in order to offer you new and more effective services.

To detect, investigate and report financial crime (e.g. Fraud) and ensure compliance with a legal obligation

Legal Obligation / Legitimate Interests

Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators. Complying with any regulations that apply to us. Complying with legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Process efficiency in dealing with such activity, and to make service and process improvements.

To undertake website and or service personalisation

Legitimate Interests

Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites. Defining types of customers for new products or services

Maintaining network and data security

Legitimate Interests

To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.

Logistics planning, demand forecasting, management information and research

Legitimate Interests

We use information about buying habits, services bought and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges.

Who we share your information with and why

There may be times when we need to share your data with third parties. We will only disclose your personal data to:

Other companies in the Spacemiles Holdings Ltd Group of Companies where it is a shareholder or stakeholder and for the purposes of performing its contractual obligations and services

Third party providers and partners who assist and enable us to use the personal data to support delivery of services or functionality of services or to market services and products to you

Regulators, law enforcement, government agencies, courts or other third parties where we think its necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights

An actual or potential buyer and or its advisers in connection with a purchase, merger or acquisition of any part of our business

Other people where we have your consent

Payment processors

Sub processors who are vetted for GDPR compliance

Debt Recovery, Credit Checking Services and Fraud Prevention Services

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and subject to appropriate contractual terms. We do not allow our third-party service providers and partners 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.

Transfers to third countries

Spacemiles Holdings Ltd operates Internationally.

Some of the information you provide to us may be transferred outside the European Economic Area. This is a transfer to a “third country”.

Whilst your data is held in UK, Ireland or Isle of Man data centres, our colleagues and partners in third countries may access it to undertake services necessary for the fulfillment of our contracts and services.

Spacemiles Holdings Ltd also works with suppliers and partners who may make use of cloud and/or hosted technologies. We undertake data security due diligence on our partners and ensure that that these partners conform to appropriate accreditations.

Wherever transfers of data to third counties occurs The Space Miles Co Ltd will put in place an appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information. To find out more please contact us at

Keeping in touch with you

We want to keep you up to date with information about new products and improvements to our websites and services. When you initially contact us over the website we will ask you if you want to receive this type of marketing information.

The Space Miles Co Ltd will not share your information with companies outside of those listed in “Who we share your information with and why”.

If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at the address provided above or emailing

You may continue to receive mailings for a short period while your request is dealt with.

How long we keep your information

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain some of your personal information for 7 years after the date it is no longer needed by us for any of the other purposes listed under How we use your information above. The only exceptions to this are where:

  • the law requires us to hold your personal information for a longer period, or delete it sooner;
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
  • we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
  • in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.


Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.

You may be able to access third party websites via our websites. We are not responsible for the privacy policies and practices of other websites. We recommend that you check the policy of each website and contact the operator of the website or publisher of the app if you have concerns or questions.

What are your rights

You are entitled to request the following from Spacemiles Holdings Ltd, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website

Right of access –to request access to your personal information and information about how we process it

Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed

Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. Email

Right to restriction of processing – to restrict processing of your personal information

Right to data portability - to electronically move, copy or transfer your personal information in a standard form

Right to object - to object to processing of your personal information

Rights with regards to automated individual decision making, including profiling – rights relating to automated decision making, including profiling

We will respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests and it is likely to take us longer than a month to respond, we will notify you of that and keep you updated as to progress.

When exercising your legal rights above, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that requests are made by the individual themselves and 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.

If your personal information has or is being used in a way that you believe does not comply with Data Protection Laws, you have the right to lodge a complaint with your local data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed (see The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (

We are committed to protecting your personal data and would appreciate the opportunity to address any concerns or complaints you may have before you approach the ICO so that we can remedy them. Any concerns or complaints should be raised with the us in the first instance and we will seek to resolve any issues or concerns you may have.