1. WHO WE ARE
Club La Costa (UK) Plc (Company Number: 03123199) (CLC, CLC World, we, us or our) is one of Europe’s most dynamic and diverse holiday providers offering a wide range of products and services.
Our registered office address is: Hallswelle House, 1 Hallswelle Road, London NW11 0DH. We also act as a consumer credit broker and are authorised and regulated by the Financial Conduct Authority (FCA) (with Firm Reference Number: 679466) for these purposes.
Please note the abbreviation CLC may be used either as a generic term referring to the CLC trademark (“CLC” as registered and used in different countries) or when referring to Club La Costa (UK) Plc.
2. YOUR PERSONAL DATA
- 2.1 The personal data that we collect may include:
- 2.1.1 Name
- 2.1.2 Date of Birth
- 2.1.3 Home Address
- 2.1.4 Personal Email
- 2.1.5 Telephone Number
- 2.1.6 Passport Details
- 2.1.7 Business Email
- 2.1.8 Occupation
- 2.1.9 Income Band
- 2.1.10 Marital Status
- 2.1.11 Flight Details
- 2.1.12 Other personal details related to holiday preferences
- 2.2 We may collect such personal data from you:
- 2.2.1 where you provide it by filling in the forms on this website (our Site) through creating a members account on our Site;
- 2.2.2 through your visits to our Site;
- 2.2.3 where you use a hard copy form to send us information;
- 2.2.4 through our correspondence and communications, or a record of them if you contact us (including recording calls for training and monitoring purposes);
- 2.2.5 via surveys that we use for research purposes, which we have asked you to complete;
- 2.2.6 in prize draw entry forms;
- 2.2.7 through details of holidays reserved through us and other information obtained as part of a transaction with us.
- 2.3 We may collect such personal data from third parties:
- 2.3.1 where you fill in forms on websites operated by lead generation companies;
- 2.3.2 as part of lead generation databases; and
- 2.3.3 through surveys that are collected on our behalf by third party companies.
3. HOW WE USE YOUR PERSONAL DATA AND LEGAL BASIS FOR PROCESSING
- 3.1 CLC collects and processes your data in order to provide you with our services or to promote our services to you. This includes using your personal data in the following ways:
- 3.1.1 to set up and maintain your membership;
- 3.1.2 to provide you with the best possible service;
- 3.1.3 to request customer feedback;
- 3.1.4 to develop, improve and update our products to better meet your needs and preferences;
- 3.1.5 for statistical analysis;
- 3.1.6 to notify you about changes to our service;
- 3.1.7 to provide your information to a lender for them to assess your suitability if you have applied to purchase products using credit; and
- 3.1.8 to provide you with information about goods and services which may be of interest to you. We may contact you about these by post, telephone, email, SMS or other method by which you have agreed to us contacting you.
- 3.2 Any information or statistics relating to our business that we disclose to others shall not identify you personally.
- 3.3 CLC and its sister companies (a list of companies providing the key services is available on request) have been in business since 1984 and during that time have developed a number of divisions. CLC and its sister companies offer a wide range of services and products so that our customers can enjoy great holiday experiences in many different destinations, whether it is buying a residence abroad, sailing holidays, using our travel club, timeshare, holiday ownership, points, renting holiday accommodation or simply enjoying our great hospitality and management services, CLC’s portfolio is extensive and has been put together with many years of experience in understanding how you want to holiday. From time to time we would like to share our experiences and promotions with you.
- 3.4 If you have provided us with consent to do so, we may pass your details to named third parties, so that they can provide information about their products and services which may be of interest to you. They may contact you by post, telephone, email, SMS or other method to which you have agreed.
- 3.5 We use your personal data for a variety of different legal bases, including:
- 3.5.1 for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. If you do not provide such personal data we may not be able to satisfy our legal obligations to you under such contract;
- 3.5.2 where necessary for our legitimate interests, for example in relation to undertaking market research and customer profile analysis in particular in relation to occupation, income band and marital status; and
- 3.5.3 in relation to sending our direct marketing materials to you, we rely on you having given consent to us in respect of such communications.
- 3.6 If you would like to opt out of receiving marketing information from us or to revoke your consent for us to pass your details to third parties, you can do so by:
- 3.6.1 selecting unsubscribe on any email sent by us;
- 3.6.2 emailing us at email@example.com;
- 3.6.3 telephoning us on 020 8906 5236; or
- 3.6.4 writing to us at John MacKinnon, Data Protection Officer, CLC World, Athene House, 86 Broadway, Mill Hill, London NW9 3TD.
We reserve the right to take reasonable steps to authenticate your identity with respect to any such request.
4. CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL DATA
You are not obligated to provide your personal data to CLC, however, some of the personal data we request from you (including the data detailed at 2.1 is required for us to provide you with our services. Therefore, we will not be able to offer all of our services without it. Generally, where we ask you to consent to us processing your personal data, this is the data which is not required by us to fulfil our obligations to you and you can withdraw your consent to us processing such personal data at any time.
5. YOUR PROFILE
- 5.1 CLC may analyse your personal data to create a profile of your interests and preferences so that we can tailor your holiday experiences and contact you with relevant information. We may make use of additional information about you when it is available from external sources to help us to do this effectively.
- 5.2 To the extent that we create and store your profile we do not take decisions about you which are based solely on automated processing of your personal data.
- 5.3 When we use your personal data to create your profile the following shall apply:
- 5.3.1 clear information explaining how we compile your profile shall be provided to you, including the significance and likely consequences of creating a profile;
- 5.3.2 the personal data we hold about you which relates to your holiday interests and preferences will be used by our team to create a profile for you which we will then use to provide you with suggested holidays and offers which we think may be of interest to you;
- 5.3.3 all decisions in relation to the offers and suggestions we provide to you will be made by an individual who works for CLC and will not be based on any automated decision making software.
6. CREDIT REFERENCE AND FRAUD PREVENTION AGENCIES
- 6.1 Some lenders who we pass your information to may run a credit check with credit references agencies (CRAs) and fraud protection agencies to make a decision as to whether to provide you with a loan.
- 6.2 If your loan application is refused by one of our lender partners on the basis of information they have received from a credit reference agency, they must inform you of this and provide you with the details of the agency concerned.
- 6.3 More information about CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA information notice (CRAIN) available at: http://www.experian.co.uk/crain/index.html
- 6.4 If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
- 6.5 Law enforcement agencies may access and use this information.
- 6.6 We and other organisations may also access and use your information to prevent fraud and money laundering.
7. WHERE WE STORE YOUR PERSONAL DATA AND SECURITY
- 7.1 All information you provide to us is, as far as reasonably practicable, stored on our, our parent’s or sister companies’ secure servers or trusted internet service providers (ISP). Any financial information, such as credit/debit card numbers will never be stored on our servers or ISP and payments will be processed by secure third party merchant service suppliers. We ask you not to permit anyone to use your name.
- 7.2 Your personal data may be transferred to and stored at a destination outside of the European Economic Area (EEA). It may also be processed by staff operating outside of the EEA who work for us, one of our group companies or our suppliers for the purposes set out in this policy. In order to ensure that any third party processes your personal data in a way which is consistent with the UK and EU’s laws on data protection, we have put in place agreements with those third parties, including with our group companies, which contain provisions approved by the EU for protecting personal data.
- 7.3 CLC takes your privacy seriously and take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place including encryptions, practices, restrictions, IT and authentication procedures.
- 7.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
8. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
- 8.1 We may disclose your personal information to our parent company, subsidiaries, sister companies or to third parties:
- 8.1.1 to enable lenders to make a lending decision (where you wish to apply for credit to one of our lender partners);
- 8.1.2 to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;
- 8.1.3 if CLC or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- 8.1.4 to anyone whom we transfer our rights and duties to; and
- 8.1.6 We will never disclose, share or sell your data without your consent, unless required to do so by law.
- 8.3 Third parties include but are not restricted to the following:
- 8.3.1 Resort Condominium International for holiday exchange services – Please refer to the privacy statement on www.rci.com;
- 8.3.2 Interval International for holiday exchange services – Please refer to the privacy statement on www.intervalworld.com; and
- 8.3.3 Vacation Resorts International resort operation services – copy of their privacy statement is available on request (using the same contact details as set out in 12.1 below).
9. HOW LONG WE KEEP YOUR DATA
CLC only ever retains personal data for as long as is necessary and we have strict review and retention policies in place to meet these obligations. Generally, where we have a contractual relationship with you, we will retain your data for a period of seven (7) years from the date our contractual relationship ends unless we are legally required to retain it for a longer period. Where you have consented to us using your details for direct marketing we will keep such data for 24 months from the date of your latest consent or until you notify us otherwise and withdraw your consent.
10. YOUR RIGHTS
Your personal data is protected under data protection laws and you have a number of rights (explained below) which you can seek to exercise. Please contact us using the details shown below if you wish to do so, or if you have any queries in relation to your rights. If you seek to exercise your rights we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances.
- 10.1 Right of access – You have a right to access the personal data we hold about you upon request. This is known as a “Data Subject Access Request”. You can exercise this right by making a request in writing, by email or by telephone using the contact details in the contact section below.
- 10.2 Right of rectification – You can ask us to correct or update your information to ensure it is accurate and complete.
- 10.3 Right to erasure and right to restrict processing – You can ask us to stop processing and to delete your data in certain circumstances (for example where it is processed with your consent, or it is no longer necessary for us to process it).
- 10.4 Right to data portability – You have a right to ask us to provide you with information in a form that suits you, and/or to provide your information to a third party.
- 10.5 Right to object – You have a right to object to our processing of your information.
- 10.6 Profiling and automated decisions – You have a right not to be subject to automated decisions which have a legal effect and to be protected by safeguards in respect of any profiling.
- 10.7 Right to object to direct marketing – Where you have consented to receive direct marketing you can change your mind at any time by contacting us or following the directions in each message. Please allow a few days for us to action your request.
11. LINKS AND CALL RECORDING
- 11.2 Our Site may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
- 11.3 Calls between us may be recorded and/or monitored for training and compliance purposes.
12. CONTACT AND COMPLAINTS
- 12.1 If you have any questions, want to exercise any of your rights or make a complaint, please contact our Data Protection Officer, John MacKinnon by writing to us at CLC World, Athene House, 86 Broadway, Mill Hill, London NW7 3TD; emailing firstname.lastname@example.org or by telephoning 020 8906 5236.
- 12.2 You also have the right to complain to the Information Commissioner’s Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF telephone number: 0303 123 1113.
14. COMPUTER INFORMATION AND COOKIES POLICY
We may collect information about your computer, including where available your IP address, operating system and browser type, for analytical purposes and to help us develop and improve our websites. This is statistical data about our users’ browsing actions and patterns; it does not identify any individual.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site and therefore not get the best experience from the Site. You can find out how to do this by visiting http://www.aboutcookies.org. This site has a guide on how to change the settings for most of the major internet browsers.
http://www.youronlinechoices.com has a good guide to online behavioural advertising and online privacy.
We might also use web tools to collect information about your browsing activities while on our Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
Google Analytics and Google Website Optimizer