resort-trustees.com is owned and operated by Resort Trustees Ltd.
We take your privacy seriously. This policy describes what personal information we collect and how we use it.
- 1. Introduction
- 1.1) We are committed to safeguarding the privacy of our website visitors and service users.
- 1.2) This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
- 1.4) Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://www.resort-truestees.com/contact-us
- 1.5) In this policy, “we”, “us” and “our” refer to Resort Trustees Ltd. For more information about us, see Section 19.
- 2. How we use your personal data
- 2.1) In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
- 2.2) We may process data about your use of our website and services (“usage data”). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
- 2.3) We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include [your name phone number and email address. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent
- 2.4) We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you]. The legal basis for this processing is consent
- 2.5) We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is consent
- 2.6) We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- 2.7) We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- 2.8) In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.
- 2.9) Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- 3. Automated decision-making
- 3.1) We will use your personal data for the purposes of automated decision-making in relation to marketing using google analytics and google remarketing.
- 4. Providing your personal data to others
- 4.1) We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
- 4.2) We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- 4.3) We may disclose your name phone number and email address to our suppliers or subcontractors insofar as reasonably necessary for the purposes of operating our website, providing our services and or ensuring the security of our website and services
- 4.4) In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- 5. International transfers of your personal data
- 5.1) In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].
- 5.2) The hosting facilities for our website are situated in United Kingdom.
- 5.3) You acknowledge that personal data that you submit for publication through our website or services]may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- 6. Retaining and deleting personal data
- 6.1) This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- 6.2) Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- 6.3) We will retain your personal data as follows:
(a) Your name, company name, company address, phone mobile and email address will be retained for a minimum period of 6 months following 25th May 2018 or the date you enter your details onto our website, and for a maximum period of one year following 25th May 2018 or or the date you entered your details onto our system whatever is the later.
- 6.4) In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a)the period of retention of personal data category will be determined based on he company policy of deleting all emails after 2 years criteria].
- 6.5) Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- 7. Security of personal data
- 7.1) We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
- 7.2) We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
- 7.3) The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data].
- 7.4) Data[relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
- 7.5) You acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- 7.6) You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password except when you log in to our website.
- 8. Amendments
- 8.1) We may update this policy from time to time by publishing a new version on our website.
- 8.2) You should check this page occasionally to ensure you are happy with any changes to this policy.
- 8.3) We may notify you of changes to this policy by email.
- 9. Your rights
- 9.1) You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and(b) the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address
- 9.2) We may withhold personal information that you request to the extent permitted by law.
- 9.3) You may instruct us at any time not to process your personal information for marketing purposes.
- 9.4) In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- 9.5) To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- 9.6) If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- 9.7) To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- 9.8) You may exercise any of your rights in relation to your personal data [by written notice to us.
- 10. Third party websites
- 10.1) Our website includes hyperlinks to, and details of, third party websites.
- 10.2) We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- 11. Personal data of children
- 11.1) Our website and services are targeted at persons over the age of 
- 11.2) If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- 12. Updating information
- 12.1) Please let us know if the personal information that we hold about you needs to be corrected or updated.
- 13. Acting as a data processor
- 13.1) In respect of Websites we host for clients we do not act as a data controller; instead, we act as a data processor.
- 13.2) Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.