Website Policy

In order to maintain a quality of service for customers and a better user experience, The Hideaways Club Limited collects certain information about visitors to its website using cookies. A cookie is a simple text file that is stored on your computer or mobile device by a website's server and only that server will be able to retrieve or read the contents of that cookie.

Q1 Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how The Hideaways Club Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you register, or as a Club Member.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy, notices or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

The Hideaways Club Limited is the controller and responsible for your personal data (collectively referred to as "Hideaways", "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: The Hideaways Club Limited

Name or title of data privacy manager: Karl Barabich

Email address: KarlBarabich@thehideawaysclub.com

Postal address: 4b College Lane, Gibraltar

Telephone number: +35020073606

You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (GRA) which is the Gibraltar supervisory authority for data protection issues (http://www.gra.gi/data-protection). We would, however, appreciate the chance to deal with your concerns before you approach the GRA so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 17 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Q2 The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Q3 How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

analytics providers such as Google based outside the EU;
advertising networks; and
search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services..

Identity and Contact Data from data brokers or aggregators.

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

Q4 How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose: To register you as a new customer

Type of Data: (a) Identity (b) Contact

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you or to take pre contractual steps

Purpose: To process and deliver your bookings or any orders including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

Type of Data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)

Purpose: To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of Data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose: To enable you to partake in a prize draw, competition or complete a survey

Type of Data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: (a) Identity (b) Contact (c) Technical

Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

Purpose: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data: (a) Technical (b) Usage

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose: To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside The Hideaways Group of Companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Q5 Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the "Glossary" - see paragraph 10.
External Third Parties as set out in the "Glossary" - see paragraph 10.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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

Q6 International transfers

When booking a property which is located outside of the EEA, we need to provide your details in advance in order to perform our contract with you. We will ensure a similar degree of protection is afforded to it to safeguard your data.

Q7 Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Q8 Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Q9 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure 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 to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Q10 Glossary

LAWFUL BASIS

The Hideaways Group of Companies each of The Hideaways Club Limited, The Hideaway Club (UK) Limited, The Hideaways Club Property Company Limited and The Hideaways Club City Collection Property Company Limited. Please click here for further details.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

The Hideaways Club (UK) Limited

The Hideaways Club Property Company Limited

The Hideaways Club City Collections Property Company Limited

External Third Parties

Service providers acting as processors based in countries where the property is located in respect of a booking who provide administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Taxation authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

Company 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 Gibraltar) and we are responsible as 'controller' of that personal information for the purposes of those laws.

Q1 Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: The Hideaways Club Limited, a limited liability corporation incorporated in Gibraltar with registered number 96671 with registered office at 57/63 Line Wall Road Gibraltar and our group companies

Our data privacy manager: Karl Barabich, KarlBarabich@thehideawaysclub.com

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

Q2 Personal information we collect about you

We may collect and use the following personal information about you:

• your title, name and contact information, including address, email address and telephone number and company details

• 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

• 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 systemsyour 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.

Q3 How your personal information is collected

We collect most of this personal information directly from you-from information provided by you in membership agreement, in person, by post, by telephone, text or email and/or via our website (https://www.thehideawaysclub.com). 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;

• from cookies on our website-for more information on our use of cookies, please see our Cookies Policy.

Q4 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 table below explains what we use (process) your personal information for and our reasons for doing so:

Q5 What we use your personal information for

To provide products AND/OR services to you:

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

Screening for financial and other sanctions or embargoes:

To comply with our legal and regulatory obligations

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator:

To comply with our legal and regulatory 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

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

Preventing unauthorised access and modifications to systems:

For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations

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 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

The above do not apply to special category personal information, which we will only process with your explicit consent.

Q6 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 Limited, The Hideaway Club (UK) Limited and The Hideaways Club Property Company Limited and The Hideaways Club City Collection Property Company 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

Karl Barabich

4b College Lane, Gibraltar

KarlBarabich@thehideawaysclub.com

+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.

Q7 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 personal concierges, local concierges, payment service providers, 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 Auditors

• Our Legal Advisors

• Our service providers in respect of properties booked through our website inside or outside of the EEA.

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.

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.

Q8 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 example our local service providers (e.g. personal concierges and local concierges) who help us provide services in respect of properties located outside of the EEA. For more information, including on how we safeguard your personal information when this occurs, see below: 'Transferring your personal information out of the EEA'.

Q9 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 or members for six years after they cease being customers or members.

Q10 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:

• where you have made a booking in respect of a property which is outside of the EEA, in which case we need to send your details outside of the EEA in order to perform our contract with you

• 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 laws.

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 our Data Privacy Manager (see 'How to contact us' below).

Q11 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 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 us OR our Data Protection Officer-see below: 'How to contact us'; and

• let us have enough information to identify you (eg your full name, address and customer or matter reference number);

• 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.

Q12 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 and leading businesses.

Q13 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 info@gra.gi

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.

Q14 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 are shown below:

Our contact details

Karl Barabich

4b College Lane, Gibraltar

KarlBarabich@thehideawaysclub.com

+35020073606

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