Effective date: 10.01.2020

1. Who are we?
1.1 For privacy queries, you can contact us at Other contact details are on our

2. What’s the point of this policy?
2.1 It tells you what to expect when we (or a company acting as agent for us) collects your personal information – including via phone calls, meetings or your use of our website. Please tell us immediately if you are unhappy about anything in this policy.

3. Might the policy change?
Yes. If so, we will notify you by posting the new version on our websites – please check for latest update.

4. What do we collect?
4.1 Information which you give us such as:
• your name and contact details (and your relationship with our client if you are attending a meeting or otherwise liaising with us as a trusted family member, friend or representative);
• ID information such as copies of driving licences and passports;
• other information if relevant to the service being provided such as your date of birth, marital status, income and information about your timeshare and travel arrangements; and
• any personal information which you tell us verbally in a meeting or telcon as we record all such interactions for training, monitoring, legal and dispute resolution purposes.

4.2 If you use our website: Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.

4.3 The following information about you may be provided to us by companies (ChatBox) with whom we have agreements relating to the marketing of our services:
• Name, telephone number, address, email, timeshare ownership details, potential travel dates. (When we contact you, we will re-confirm your wish to opt-in and continue our client relationship with you.)

5. What’s our reason / legal basis for collecting the information?
5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract (i.e., to supply the relevant to services to you).

5.2 Because it’s in our “legitimate interests”, e.g., to manage and improve our website(s) including tracking usage patterns and preventing and detecting fraud or abuse. This applies to data relating to use of our website(s).

5.3 Because you’ve agreed. This applies to contact or other information which you give or allow us to use for newsletters or other marketing. You can withdraw consent at any time as explained on our service or by emailing us at the above email address.

5.4 If you supply us with someone else’s contact details via “Refer A Friend” or similar, to send a referral message to that person, we will retain their information for a maximum of 12 months and delete it if there has been no contact for 12 months.

6. How long do we keep personal information?
6.1 If you don’t contract to use our services at or soon after any relevant meeting / telcon, we will retain your information for a maximum of 12 months from our last contact

6.2 If you enter a contract for our services, we will typically hold on to your personal information for a maximum of seven years if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.

6.3 We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.

7. To whom do we send or make available your personal information?
7.1 To other people who supply us with a service, e.g. other companies in our group who provide part of our service, website hosts, payment providers, customer service providers, telephony providers which help us manage phone call recordings, and businesses which help us send communications or monitor our website and which provide us with e-commerce, online advertising, analytics, review management, live chat and other IT services.

7.2 To other businesses within our group to enable them to send you marketing messages, if you have given permission. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

7.3 To other users of our service, if you include personal information in a testimonial, review, comment, post, uploaded photo or other public action on our service. Testimonials will only be posted providing we have your consent to do so and will be removed immediately if your consent is withdrawn.  You can ask us to remove displayed information by emailing us at

7.4 To credit reference agencies, regulators and the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.

7.5 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.6 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

8. Do we send your information outside the European Union?
8.1 Your personal information which we collect is stored within the EU and is not transferred to any third countries except as follows.

8.2 Your personal information may be transferred to the US by the following companies (Google, Fieldspace, Novak Solutions, Zapier) certified under the EU-US Privacy Shield Framework, which provides certain safeguards for your personal information.

8.3 Your personal information may also be transferred to the US by Infusionsoft, with whom we have entered into a contract which contains certain EU-adopted standard transfer clauses (see here) designed to provide adequate safeguards for your personal information.

9. What about cookies on our website?
9.1 Please see our separate cookies policy on the relevant website.

10. What rights do you have?
10.1 To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).

10.2 You may also have the right to object to use of your personal information in certain circumstances.

10.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the AEPD, Agencia Espanola de Proteccion de Datos.

10.4 For more information about your rights, visit the AEPD, Agencia Espanola de Proteccion de Datos:

11. Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

12. Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
– if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at
We will not sell, distribute or lease your personal information to third parties unless we have your consent or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 2018. If you would like a copy of the information held on you, please email

If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible, at the above email address. We will promptly correct any information found to be incorrect.

Last modified: April 2, 2020