City Fund Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
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.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our:
The Hideaways Club City Collection Property Company Limited, a limited liability corporation incorporated in Gibraltar with Registered Number 105275 with registered office at 21 Engineer Lane Gibraltar and our group of companies
Our data privacy manager:
Colin Bruen, [email protected]
Personal information:
Any information relating to an identified or identifiable individual
Special category personal information:
Personal information revealing racial or ethnic origin,
political opinions, religious beliefs, philosophical beliefs or
trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
Personal information we collect about you
We may collect and use the following personal information about you:
Your name and contact information, including address, email
address, telephone and fax number and company details
Your nationality
Information to enable us to check and verify your identity, eg your
date of birth
Your gender information, if you choose to give this to us
Information to enable us to check and verify your address
Information to enable us to verify and check source of the fund you
will use to subscribe for a share in the Property Company, which
may include your employment details
Your billing information, transaction and payment card information
and bank account details
Your personal or professional interests
Information to enable us to undertake credit or other financial
checks on you
Information about how you use our website, IT, communication and
other systems
Politically Exposed Person status
Letters of reference
Information about how you use our website, IT, communication and
other systems
Your responses to surveys, competitions and promotions
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.
How your personal information is collected
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 City Collection 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;
How and why we use your personal information
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:
What we use your personal information for
To provide products AND/OR services to you, in particular in connection with the terms of the Subscription Agreement:
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you:
For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you.
Conducting checks to identify our customers and verify their identity:
To comply with our legal and regulatory obligations, including Anti Money Laundering and Know Your Customer obligations.
Screening for financial and other sanctions or embargoes:
To comply with our legal and regulatory obligations, including Anti Money Laundering and Know Your Customer obligations.
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg rules issued by our professional regulator:
To comply with our legal and regulatory obligations, including Anti Money Laundering and Know Your Customer obligations.
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies:
To comply with our legal and regulatory obligations.
Operational reasons, such as improving efficiency, training and quality control:
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information:
For our legitimate interests or those of a third party, ie to
protect trade secrets and other commercially valuable
information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures:
For our legitimate interests or those of a third party, ie to be as efficient as we can so we can delivery the best service for you at the best price
Updating and enhancing customer records:
For the performance of our contract with you or to take steps at
your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making
sure that we can keep in touch with our customers about existing
orders and new products
Statutory returns:
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments:
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg to make
sure we are following our own internal procedures and working
efficiently so we can deliver the best service to you
Credit reference checks via external credit reference agencies:
For our legitimate interests or those of a third party, eg to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts:
For our legitimate interests or a those of a third party, ie to
maintain our accreditations so we can demonstrate we operate at the
highest standards
To comply with our legal and regulatory obligations
The above do not apply to special category personal information, which we will only process with your explicit consent.
Promotional communications
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
+35020073606
• 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.
Who we share your personal information with
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.
Where your personal information is held
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).
Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal information (the right of access)
Rectification
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
Data portability
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
To object
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.
Keeping your personal information secure
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.
How to complain
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 [email protected]
Changes to this privacy policy
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.
How to contact us
Please contact us and/or our Data Privacy manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details:
Colin Bruen
21 Engineer Lane Gibraltar
+35020073606