Privacy Policy

CLCMembers PRIVACY POLICY

BACKGROUND:
CLCMembers.co.uk understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, CLCMembers.co.uk will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy [is deemed to occur upon your first use of Our Site] [You will be required to read and accept this Privacy Policy when signing up for an Account]. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and
[“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]

2. Information About Us
Our Site is owned and operated by Alexanders Associates Ltd as a project to help Timeshare owners of Club La Costa and other defined Timeshare owners and we are registered in England under company number 07255662.
Registered Office address 43 Brynymor Road, Gowerton, Swansea SA4 3EY
Data Protection Officer: Alexanders Associates
Email address: [email protected]
Telephone number: We are currently not resourced to receive phone calls for CLCMembers however this may change in the future. You will be notified on email if you subscribed to receive our emails or this will be updated on our Website.
Postal Address: We do not handle written materials on paper. All information should be emailed to [email protected]
We operate under the Code of Conduct of a Limited Company at Companies house https://www.gov.uk/government/organisations/companies-house
We are also registered with the Information Commissioners office with registration number Z3346189

3. What Does This Policy Cover?
This Privacy Policy applies only to your use of our Site which may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?
Under the GDPR, you have the following rights, which We will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 2.
b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 2 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We have. Please contact us using the details in Part 2 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. [We do not use your personal data in this way.]
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 2.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?
Depending upon your use of our Site, we may collect some or all of the following personal [and non-personal] data (please also see Part 14 on our use of Cookies and similar technologies and our Cookie Policy www.clcmembers.co.uk/cookie-policy
• Name
• Gender
• Address where Verification of ownership is required.
• Email address
• Telephone number if required for Verification
• Business name if applicable to the purpose of your Timeshare ownership
• Information about your preferences and interests;
• IP address
• Web browser type and version
• Operating system
• A list of URLs starting with a referring site, your activity on our Site, and the site you exit to;
• Contract ownership if engaged in legal work
• Only for Verification of Timeshare ownership, information such as Utility or Council Tax Bill (This information is deleted once Verification is complete and passed.

7. How Do You Use My Personal Data?
Under the GDPR, We must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will OR may be used for [one of] the following purposes:
• Providing and managing your Account
• Providing and managing your access to our Site or Forums
• Personalising and tailoring your experience on our Site
• Supplying our products and/or services to you.
• Your personal details are required in order for us to enter into a contract with you to provide assistance
• Personalising and tailoring our products or services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email that you have opted-in to you may unsubscribe or opt-out at any time by updating your preferences contained in our emails, or by your instruction on email to us at [email protected]
• Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by [email] [telephone] [text message] [post] with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
[We use the following automated system[s] for carrying out certain kinds of decision-making that we feel will interest you based on your interests. If at any point you wish to query any action that We take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 2.
• [The following automated decision-making method(s) may be used:
o Where you have opted to work with 3rd Parties we will add you to our mailing list for information related to that 3rd party. This would then allow you to keep abreast of relevant information about the work of that 3rd party. You will be subject to the terms and privacy policy of those 3rd parties as laid out on their websites.

8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Until you inform us that you no longer wish to be contacted or that we become aware you no longer own a Timeshare Product.  Timeshare can be a lifetime product and you may be interested in contacting us in the future.

9. How and Where Do You Store or Transfer My Personal Data?
We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.
We also use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 2 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, We take a number of important measures, including the following:
• We conduct due diligence on 3rd Party organisations and digitally retain a record of doing so. We retain emails demonstrating this and on occasions sign contractual obligations citing mutual confidentiality under agreed national and international terms of conduct.
• Your information is backed up securely and separately on a regular basis and is kept on a secure separate location using 3rd party security services. Our website and data is protected by a Firewall provided by 3rd party security services and is monitored 24/7/365.

10. Do You Share My Personal Data?
We may share your personal data only with other companies in our group for Direct Marketing purposes. This includes Alexanders Associates, EEESafe or LocalitEEE which are part of our holding company and its subsidiaries.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we or you are involved in legal proceedings or complying with legal obligations, work with an appointed solicitor or funder, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or from logins where you may have them.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?
You may access certain areas of our Site without providing any personal data at all. [However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.]
You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy

13. How Can I Access My Personal Data?
If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you please email us with the Subject “Subject Access Request” and email to us at the contact information in Part 2. Please inform us of your requirements, your contact information and what you’d like us to remove. We need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on our Site are used in accordance with current Cookie Law.
Details of our Cookie Policy can be found at www.clcmembers.co.uk/cookie-policy

15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Alexanders Associates the Data Controller
Email address: [email protected]

16. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change our business in a way that affects personal data protection.
Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.