Effective June 1st 2020
We at GBAF Publications Ltd understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, luxuryadviser.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“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 section 13, below;
“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our Site. This definition shall, where applicable, incorporate the definitions provided in the General Data Protection Regulation 2016/679 (“GDPR”); and
“We/Us/Our” means GBAF Publications Ltd, a company registered in England and Wales under company number 07403411, whose registered office address is at Alpha House, 100 Borough High Street, London, Greater London SE1 1LB United Kingdom.
2. Information About Us
2.1 We own and operate this Site.
2.2 Our main point of contact for data protection related queries is Robert Mathew who can be contacted by email at [email protected], or by post at Alpha House, 100 Borough High Street, London, Greater London SE1 1LB United Kingdom.
2.3 GBAF Publications Ltd is registered at Data Protection Register – our ICO Registration Number is ZA518218
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:
4.1.1 The right to be informed about our collection and use of personal data;
4.1.2 The right of access to the personal data we hold about you (see section 12);
4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens’ Advice Bureau.
5. What Data Do We Collect?
5.1.3 contact information such as email addresses and telephone numbers;
5.1.4 demographic information such as post code, preferences, and interests;
5.1.5 IP address;
5.1.6 web browser type and version; and
5.1.7 operating system.
5.2 If you provide us with the personal data of any other person when using our Site, it is your responsibility to ensure you have gained consent from that person to transfer their personal data to us.
5.3 Please note our Site may ask you for payment details, such as billing information or credit or debit card information, however all payments made on our Site will go through a third party processor such as PayPal or Realex and as such, we shall have no access to this data. A separate contractual relationship shall be created between you and the payment processor on their terms and conditions and we cannot be held liable for any errors, actions, omissions or incorrect charges that may be made by them.
5.4 Please be aware that if you opt in to receiving job alerts we will use your email address to send periodic emails relevant to positions you are looking for.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 Providing and managing your access to our Site;
6.2.2 Personalising and tailoring your experience on our Site;
6.2.3 Supplying our services to you (please note that we require your personal data in order to enter into a contract with you);
6.2.4 Replying to emails from you;
6.2.5 Supplying you with emails that you have opted into (you may unsubscribe using the link at the bottom of each email or you may opt-out at any time by emailing us directly);
6.2.6 Analysing your use of our Site to enable us to continually improve our Site and your user experience.
6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 Third parties whose content appears on our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use, and we advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
7. How Do We Store Your Data?
7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
7.2 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.
8. Do We Share Your Data?
8.1 We may sometimes contract with other third parties to supply services to you on our behalf. These may include search engine facilities, courier companies and sub-contractors. In some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
8.2 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.3 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.4 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data to us via email or via our Site, you may be given options to restrict our use of your 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, at the point of providing your details and by contacting us).
10.2 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.
11. Your Right to Withhold Information
11.1 You may access certain areas of our Site without providing any 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.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details using the contact details below in section 14. Alternatively, please refer to our Data Protection Policy.
13.2 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.
13.3 Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.5 In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.6 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently.
13.7 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us