We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in Gibraltar ) and we are responsible as 'controller' of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
We, us, our:
Our data privacy manager:
Special category personal information:
We may collect and use the following personal information about you:
This personal information is required to provide products AND/OR services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products AND/OR services to you.
We collect most of this personal information directly from you-from information provided by you as part of the subscription agreement you entered into with The Hideaways Club Property Company Limited, in person, by post, by telephone, text or email and/or via our website. However, we may also collect information:
• from publicly accessible sources, eg Companies House or HM Land Registry;
• directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- customer due diligence providers;
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The information below explains what we use (process) your personal information for and our reasons for doing so:
To provide products AND/OR services to you, in particular in connection with the terms of the Subscription Agreement:
To prevent and detect fraud against you:
Conducting checks to identify our customers and verify their identity:
Screening for financial and other sanctions or embargoes:
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg rules issued by our professional regulator:
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies:
Operational reasons, such as improving efficiency, training and quality control:
Ensuring the confidentiality of commercially sensitive information:
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures:
Updating and enhancing customer records:
Ensuring safe working practices, staff administration and assessments:
Credit reference checks via external credit reference agencies:
External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts
The above do not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions, or new products AND/OR services.
We have a legitimate interest in processing your personal information for promotional purposes (see above 'How and why we use your personal information'). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organisations outside The Hideaways Group of Companies for marketing purposes.
The Hideaways Group of Companies means each of The Hideaways Club Property Company Limited, The Hideaways Club City Collection Property Company Limited, The Hideaways Club Limited, The Hideaway Club (UK) Limited. Please click here for further details.
You have the right to opt out of receiving promotional communications at any time by:
• contacting us at
21 Engineer Lane Gibraltar
• using the 'unsubscribe' link in emails or 'STOP' number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.
We routinely share personal information with:
• companies within The Hideaways Group of Companies
• third parties we use to help deliver our products AND/OR services to you, eg payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, eg marketing agencies or website hosts;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
• our Banks;
• our Alternative Investment Fund Manager and Manager;
• our Private Equity Depositary
• our Administrator, Deal Arranger and Secretary
• Our Auditors
• Our Gibraltar Legal Advisors
• Our English Legal Advisors
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: 'Who we share your personal information with').
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: 'Transferring your personal information out of the EEA'.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:
• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Generally we keep basic information about our customers for six years after they cease being customers.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
• with your and our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European data protection law.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework)
Except for the countries listed above, non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
If you would like further information please contact us (see 'How to contact us' below).
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal information (the right of access)
The right to require us to correct any mistakes in your personal information
To be forgotten
The right to require us to delete your personal information-in certain situations
Restriction of processing
The right to require us to restrict processing of your personal information-in certain circumstances, eg if you contest the accuracy of the data
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party-in certain situations
The right to object:
-at any time to your personal information being processed for direct marketing (including profiling);
-in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of our Supervisory Authority for data protection, the Gibraltar Regulatory Authority under the section "Guidance for the General Data Protection Regulation http://www.gra.gi/data-protection/general-data-protection-regulation
If you would like to exercise any of those rights, please:
• email, call or write to our Data Privacy Manager-see below: 'How to contact us'; and
• let us have enough information to identify you eg your full name, address;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government of the United Kingdom and leading businesses.
We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority. Their contact details are as follows:
Gibraltar Regulatory Authority,
2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar.
(+350) 20074636 (+350) 20072166 firstname.lastname@example.org
This privacy notice was published on 17 May 2018.
We may change this privacy notice from time to time-when we do we will inform you via email.
Our contact details:
21 Engineer Lane Gibraltar
INVESTMENT IN THIS SCHEME IS RESTRICTED TO CERTIFIED HIGH NET WORTH INDIVIDUALS OR SOPHISTICATED INVESTORS. EVIDENCE OF THE CERTIFICATION WILL BE REQUIRED BEFORE DETAILED INFORMATION CAN BE PROVIDED TO YOU. THE PRICE OR VALUE OF, OR INCOME FROM, INVESTMENTS CAN FALL AS WELL AS RISE. THIS INVESTMENT CARRIES A RISK TO YOUR CAPITAL AND AN INVESTOR MAY GET BACK LESS THAN THE SUM INVESTED. YOU MAY HAVE DIFFICULTY SELLING THIS INVESTMENT AT A REASONABLE PRICE AND IN SOME CIRCUMSTANCES IT MAY BE DIFFICULT TO SELL AT ANY PRICE. DO NOT INVEST IN THIS UNLESS YOU HAVE CAREFULLY THOUGHT ABOUT WHETHER YOU CAN AFFORD IT AND WHETHER IT IS RIGHT FOR YOU. ‘ THIS FINANCIAL PROMOTION HAS BEEN APPROVED BY VELAY FINANCIAL SERVICES LIMITED, 210 NEPTUNE HOUSE, MARINA BAY, GIBRALTAR WHICH IS LICENCED BY THE GIBRALTAR FINANCIAL SERVICES COMMISSION AS AN EXTERNAL ALTERNATIVE INVESTMENT FUND MANAGER UNDER THE ALTERNATIVE INVESTMENT FUND MANAGERS REGULATIONS 2013 (LICENCE NO. FSC0103AIF). THIS INVESTMENT IS NOT BEING OFFERED TO (1) ANY PERSONS RESIDENT OR LOCATED IN THE UNITED STATES OF AMERICA; (2) ANY UNITED STATES CITIZEN WHO IS STATIONED OR SERVING OUTSIDE THE UNITED STATES AS A MEMBER OF THE US ARMED FORCES OR DIPLOMATIC CORPS OR ANY OTHER GOVERNMENTAL AGENCY EITHER AT THE TIME OF OFFER IS MADE OR WHEN THE PURCHASE ORDER IS INITIATED.