This privacy policy explains what personal data ALT‑15° collects, how it is used, who it is shared with, and the rights you have under UK and EU data protection law.
ALT‑15° is based in the United Kingdom and works with clients in the UK and internationally, including the United States. This policy sets out our obligations under the UK GDPR and the Data Protection Act 2018. Depending on where you or your company are located, additional privacy or data protection laws may also apply to the information we hold about you. Where they do, we will meet those obligations alongside the ones described here. This website and the ALT‑15° services are operated by Iconic CEO Limited, a company registered in England and Wales (Company No: 12223405).
Iconic CEO Limited is the data controller for personal data collected through this website and in the course of enquiries, client records and our own business administration.
Iconic CEO Limited acts as data controller for personal data it determines is necessary to provide and administer the ALT‑15° service. In some engagements we may also process personal data on behalf of a client, for example where we are given access to client systems or to information relating to members of the client’s business, and process that information solely on the client’s documented instructions. Where Iconic CEO Limited acts as a processor, that processing is governed by the appropriate data processing terms in the engagement documentation. This policy covers the data we control. It does not replace the terms agreed with a client for the data we process on their behalf. If you have questions about this policy or how your data is handled, email Papillon Luck directly at papillon@papillonluck.com.
The personal data we collect depends on how you interact with us.
If you enquire about working with us or book a call: your name, email address, phone number, the answers you submit through our enquiry form via Typeform, and your timezone and chosen call time via Calendly are collected.
If you go on to work with us: we collect the information needed to deliver the engagement, which may include details of your property, your commercial, brand and wellness objectives, and the contacts within your team we work with. During an engagement we may be given access to relevant systems and to confidential commercial information about the property and its guest experience. What we can access and how it is handled is set out in the engagement letter.
If we record a session: with your knowledge, meetings may be recorded and transcribed so decisions, actions and context are captured accurately. Recordings, transcripts and the notes taken from them are used only to carry out the engagement. You can ask us not to record, or to exclude specific material, at any time.
If you email us directly: your email address and the content of the message.
We collect personal data only where there is a clear and lawful basis for doing so under UK GDPR.
We use trusted third-party service providers to help operate our business and deliver our services. Where required, we put appropriate data protection terms in place with those providers. We do not sell your personal data to anyone.
Meeting recording and transcription, used to capture meetings during an engagement. Read Fathom's privacy policy.
Meeting notes and transcription, used to capture meetings during an engagement. Read Granola's security and privacy information.
AI tool used in the course of delivering the service, including analysis, planning and drafting. We use settings intended to prevent your material being used to train models. Read Anthropic's privacy policy.
AI tool used in the course of delivering the service, including analysis, planning and drafting. We have disabled the setting that permits new ChatGPT conversations to be used to improve OpenAI’s models. Read OpenAI's privacy policy.
Payment processing for card payments. Read Stripe's privacy policy.
Invoicing and bank transfer payments. Read Wise's privacy policy.
Document platform used to issue and sign letters of engagement. Read PandaDoc's privacy notice.
Form platform used to take and qualify enquiries and collect responses. Read Typeform's privacy policy.
Scheduling platform used to book ALT‑15° calls. Collects name, email, timezone and meeting time. Read Calendly's privacy policy.
Direct email correspondence for enquiries and scheduling. Messages you send us are received and stored through our email provider, and we use the details you share only to respond to your enquiry.
Several of the providers above may process personal data outside the UK, including in the United States. Where this involves a restricted transfer under UK data protection law, we rely on an applicable UK adequacy regulation or put in place an appropriate safeguard or other lawful transfer mechanism recognised under UK law.
Under the UK GDPR you have the following rights regarding your personal data. If you are located elsewhere, you may have comparable or additional rights under the law that applies to you.
To exercise any of these rights, email papillon@papillonluck.com. We will respond to legitimate requests within one month. Occasionally it may take longer if your request is particularly complex or you have made a number of requests, in which case we will notify you.
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, or refuse to comply with your request in those circumstances. We may also need to request specific information from you to confirm your identity before fulfilling a data request. This is a security measure to ensure personal data is not disclosed to anyone without the right to receive it.
We do not add enquirers or clients to a marketing list. If you contact us, we use your details to respond to you and to conduct the conversation about a possible engagement. If we introduce marketing emails in future, we will do so only where we have the permission required and every message will carry a clear unsubscribe option.
Our website sets one cookie, which records your response to the cookie banner. We do not use analytics, advertising, social media cookies or tracking pixels. Our Cookie Policy sets out the full detail, including the third-party services used by the site and the technical information they may receive.
We take the security of your personal data seriously. Data is held in encrypted form by the processors we use. We select providers that maintain recognised information security standards and, where required, we put appropriate data protection terms in place with them.
Our services are intended for adults aged 18 or over. By providing us with your data, you warrant that you are at least 18 years of age. We do not knowingly collect data from anyone under 18. If you believe a minor has provided us with personal data, please contact us so we can delete it.
If you have a complaint about how your data is handled, please contact us first at papillon@papillonluck.com and we will work to resolve it. You also have the right to lodge a complaint with a data protection authority. In the UK this is the Information Commissioner's Office (ICO), at ico.org.uk.
We may update this privacy policy from time to time, particularly when we add new tools or change how data flows through our systems. Any material changes will be reflected in the effective date below and, where required, we will notify affected individuals directly.
Effective date: 15 September 2026. Material changes will be reflected in the date above.
ALT‑15° is provided by Iconic CEO Limited, registered in England & Wales at Swift House, Ground Floor, 18 Hoffmans Way, Chelmsford, Essex, CM1 1GU, United Kingdom. Company Number: 12223405 · VAT Number: GB 335 4313 23.