This website is operated by The Source Luxury Group Ltd. We take your privacy very seriously therefore we urge to read this policy very carefully because it contains important information about on:
- who we are,
- how and why we collect, store, use and share personal information,
- your rights in relation to your personal information, and
- how to contact us and supervisory authorities in the event that you have a complaint.
Who we are
The Source Luxury Group Ltd ('we' or 'us') collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.
The personal information we collect and use
a) Personal information you provide to us
We collect the following personal information that you provide to us:
Nature of Business
Some examples of when we collect this information include:
Registering your interest to buy a yacht, property or car
Registering your interest for lifestyle management
b) Personal information you provide about third parties
If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:
shall consent on their behalf to the processing of their personal data;
shall receive any data protection notices on their behalf; and
shall consent on their behalf to the transfer of their personal data abroad.
c) Monitoring and recording communications
We may monitor communications such as emails and telephone calls for the following purposes:
- Quality assurance
How we use your personal information
We collect information about our users for the following purposes:
To provide further information for legitimate interest.
Who your information may be shared with
We may share your information with:
- Credit reference agents in accordance with our credit checking policy below
- Law enforcement agencies in connection with any investigation to help prevent unlawful activity
- We will not share you personal information with any other 3rd parties.
We would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by post, email, telephone, text message or automated call.
We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us you can opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below.
We may do a credit check on you so that we can make credit decisions about you and members of your household, and to prevent and detect fraud and money laundering. Any such search will be recorded on the files of the credit reference agency.
We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.
Other credit businesses may use your information to:
make credit decisions about you and the people with whom you are financially associated
trace debtors, and
prevent and detect fraud and money laundering
If you provide false or inaccurate information to us and we suspect fraud, we will record this. If you want to see your credit file, please contact the credit reference agency which we use Experian.
Whether personal information has to be provided by you, and if so why
No personal information has to be provided by you to us at any time.
How long your personal information will be kept
We will hold your personal information for the following periods:
Name and address - for 6 years to comply with UK tax law but possibly longer if we have ongoing business together.
Email - for as long as we have ongoing business together.
These periods are no longer than necessary in each case.
Reasons we can collect and use your personal information
We rely on the following as the lawful basis on which we collect and use your personal information:
- legal obligation
- legitimate interests
The legitimate interests relied upon are as follows:
The information is necessary for the business to undertake it's commercial activities.
The information is used for marketing purposes with legitimate interests.
Keeping your information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:
All data is secured on a secure server.
We are certified to ISO 27001. This family of standards helps us manage your information and keep it safe and secure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.
Transfers of your information out of the EEA
We will not transfer your personal information outside of the EEA at an time.
Children and the validity of consent
Where we obtain consent from any user we will take reasonable steps to ascertain whether the user is over 13 years of age and whether the child is sufficiently informed to give valid consent. If the user is not, parental consent will be required to provide consent for the processing of any personal information.
What rights do you have?
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
If you would like to exercise any of these rights please:
- email, call or write to us
- let us have enough information to identify you
- let us have proof of your identity (a copy of your driving license, passport or a recent credit card/utility bill)
- let us know the information to which your request relates
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
How to complain
We hope that we can resolve any query or concern you 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. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
By a notice on the website.
If you have any questions about this policy or the information we hold about you, please contact us by:
The Source Luxury Group Ltd.
New Boundary House