Luxury Sotogrande is responsible as “data controller” to ensuring that your privacy is protected and respected in compliance with the EU General Data Protection Regulation (GDPR).
Should we ask you to provide certain information by which you can be identified when using our website or when purchasing a ticket, at registration or when downloading the event app, then you can be assured that it will only be used in accordance with this privacy statement.
Luxury Sotogrande may change this policy from time to time by updating this page. This policy was updated on 21st September 2018.
What we collect
We may collect the following information:
- Traffic data through google analytics;
- contact information including name, email address, company name and job title;
- demographic information such as location, preferences and interests;
- other information relevant to customer surveys and/or offers.
Our legal basis for collecting personal data
We may process data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between Luxury Sotogrande and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.
Collecting personal data based on consents:-
The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will not be stored and documented in our systems.
Collecting personal data based on contracts:-
We may process personal information for fulfilling our obligations related to contracts and agreements with customers and our partner/sponsors.
What we do with the information
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about an event you have purchased a ticket to, new products, special offers or other information which we think you may find interesting using the email address which you have provided. We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However where consent is needed, we will ask for this separately and clearly. You will always be able to unsubscribe by emailing firstname.lastname@example.org
- We may also use your information to partake in a prize draw, competition or complete a survey.
Who we share your personal information with
We routinely share personal information with:
- third parties we use to help deliver our products and or services to you
- other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link to for example when you download the event App.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- When purchasing an event ticket, you will be asked to comply with our terms and conditions, which allows our sponsors to use your information for direct marketing purposes only. You will also have the option to opt out by selecting that you do not comply with our terms and condition at point of purchase.
- If you have previously agreed to us using your personal information for direct marketing purposes, you can change your mind at any time by contacting us at email@example.com
- We will not sell, distribute or lease your personal information to third parties unless we have your permission 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 will also be asked to enter your personal details when downloading the event App. This may be used for competitions or surveys.
- We may also use photographs and video content throughout the Luxury Sotogrande which will appear on social media and marketing material.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
How long do we keep your personal information
We will only retain your information for as long as required to provide you with the services you request, for the purpose outlined in this policy and for any legal purposes for which we are obliged to keep the information. We will securely delete your information when it is no longer required for these purposes.
Your rights to your personal information
Under certain circumstances you have rights under data protection laws in relation to your personal data . You exercise these rights in relation to personal information which we hold about you by contacting us at firstname.lastname@example.org
You have the right to:
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
We do not generally transfer your personal data outside the European Economic Area (EEA). However if you download the event App, this will involve the transfer of your data outside of the EEA to the United States
Rest assured that this will be done in accordance with the US Privacy Shield which is designed to ensure similar degree of protection applies. For further details, see European Commission: EU-US Privacy Shield.
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.
How to complain
We hope that we 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.