We take the security of and our legal responsibilities around your personal data seriously. This statement explains relevant information about our processing of your personal data collected via this website. Please read this Privacy Notice carefully before using our website or registering to use our services. This Privacy Notice sets out our views and practices regarding your personal data and how we collect, process, and treat it.
References in this Privacy Notice and on our website to “we”, “our” or “us” are references to the villa named Alta Palma and our agents. References to “you” and “your” means each natural or legal person who uses our website or the associated services.
We do not share your personal data collected through this website with outside organisations unless to not do so would mean that we were not complying with our statutory and regulatory obligations. We do not sell or rent your personal data for any purpose.
The personal data we process because of your visiting our website depends on the data you provide to us. If you access our site but do not interact further with us, we will only process the data contained in cookies (see ‘Cookies’ for more info). Should you decide to interact with us by, for example, submitting a request form we will process the data you provide for the purposes stated on the form. Some fields are mandatory as without them we will be unable to make further contact with you to answer your request.
By visiting www.altapalma.com and using our website services you are accepting and consenting to the practices described in this Privacy Notice. Our Data Protection Officer can be contacted by emailing firstname.lastname@example.org
Please note that communications over the internet cannot be guaranteed as secure. Whilst we take appropriate steps to protect your data we cannot guarantee that it will remain secure in transit; any transmission is at your own risk. Once data reaches you or your network it is your responsibility to ensure it remains secure. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access, loss, or damage.
How we protect your information
We take the security of your data very seriously and use strict procedures to protect it. All information you provide to us is stored on remote secure servers within Europe. Where possible, we try to only process your information within the UK and European Economic Area (EEA). We may be required transfer your information outside the European Economic Area (EEA) e.g., if requested to by law or to fulfil any legal obligation. These countries may not have similar data protection laws to the EEA so, if we do transfer your information, we will take the necessary steps to ensure that your privacy rights are still protected.
All the personal data we hold about you will be processed by our staff. No third parties will have access to your personal data unless there is a legal obligation for us to provide them with this. We may also process your personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with providing you with services.
Where your information is used other than in accordance with one of these uses, we will first obtain your consent to that use. We take all reasonable steps to ensure that your personal data is processed securely.
Sharing your personal data
Your personal data will only be shared with third parties including other data controllers where it is necessary for the performance of the data controllers’ duties or where you first give us your prior consent. It is likely that we will need to share your data with:
Members of staff and subcontractors
Our agents, suppliers, and contractors.
Data Subject Rights
Andrew Rourke acts as the Data Controller for all personal data submitted through our website.
Accordingly, you may exercise several rights over your data including:
Correct your data: you will be able to amend any information that we hold about you that is inaccurate or incomplete.
Request access to your data: You can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with data protection law.
Erase your data: you can ask us to delete your personal data fully or partially where there is no statutory or regulatory obligation for us to keep using it. We may retain your email address to make sure the restriction is respected in future. We also have the right to continue using your information if such usage is necessary for compliance with our legal obligations.
Download your data or send it to another controller: You can obtain a copy of the data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
Object to the use of your data: you can ask that we no longer use your personal data where that use is based on a legitimate interest.
Restrict the use of your data: You have the right to ‘block’ or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your information, but may not use it further.
Right to withdraw consent: If you have given your consent for us to use your information, you have the right to withdraw your consent at any time. This can be done by contacting our Data Protection Officer.
We will handle your data subject rights in accordance with the requirements of the General Data Protection Regulation (“GDPR”) and any national laws. Should you need to exercise any of your data subject rights please contact our Data Protection Officer at email@example.com If you are dissatisfied with the way we have handled your personal data and we are unable to resolve the issue for you, you may take the matter to the Information Commissioner’s Office. Further details can be found via their website at www.ico.org.uk.
What is the legal basis for us using this information?
If you have any questions about the lawful bases upon which we collect and use your personal data, you can contact our Data Protection Officer.
Our lawful bases include :
Consent. We will always seek your consent to process certain types of information where we are legally required to do so. You have the right to withdraw or decline your consent at any time.
Performance of a contract. We need you to give us the information you provide, and to collect information about you from the Credit Reference Agencies or other third parties for us to provide you with our services as agreed in our contract with you. We cannot provide our services to you without collecting the information as we are required, for example, to carry out anti money laundering checks on clients to verify identity. For other types of information (such as the information we collect based on your use of the website and information we receive from you), we process this information for the purposes of providing our services to you.
Legitimate interests. We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of our product providers or other suppliers provided that such processing does not outweigh your rights and freedoms. As an example, we may process your personal data to:
comply with laws and regulations that apply to us
protect you and us from fraud or other threats
improve our service and manage our customer relationships
where we rely on legitimate interests, you have the right to object at any time.
Who we may share your data with
We may share your data with third parties such credit reference agencies and fraud prevention agencies
How we use the information
We may use the information to verify your identity as part of our identity authentication process and notify you about changes to our services. We may also use this information to enable to fulfil our business contract with you and to maintain our professional relationship.
We may collect and process the following data about you:
We need to know basic personal data to provide you with our services, and to claim our right to be paid in return for our services. If you do not provide this information, then we will be unable to provide the services you have requested. We will not collect any personal data from you that we do not need to provide and oversee the services we have agreed to provide you with. We are also required to process your data for purposes such as carrying out AML due diligence and detecting and preventing fraud. Therefore, when you enter a business relationship with us you may be asked to provide us with some or all the following information. This information is used to enable us to carry out our regulatory duties. This information could include:
Date of birth
Proof of identity (passport and/or utility bill)
If we contact a credit reference agency to enable us to verify your identity we will use that information only to allow us to fulfil our regulatory obligations.
Information we collect about you based on your use of our website.
We will use this information:
to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
to improve the service, we offer you.
as part of our efforts to keep our website safe and secure and to prevent fraud
We collect and process information which:
you give to us when you register with us, such as your name and contact details
we obtain from a Credit Reference Agency
we receive from other sources, such as third parties who give us information about you
is collected from cookies.
How long we keep your information for
We will keep your information for no longer than is necessary depending on the purpose for which we are using it. How long we keep your information will depend on the purpose for which we use it. While you are a client of ours, we will only retain your information for as long as is necessary for those purposes. If we have entered into a contract with you, we will only keep your information until the contract has been fulfilled. We may keep your email address to ensure that you no longer receive any communications from us.
A cookie is a tiny element of data that a website can send to the computer browser of a visitor, so that this computer will be recognised by the site on their return. Cookies allow our web server to recognise a computer on connection to the Site, which in turn allows the server to make downloading of pages faster than on first viewing. In addition, cookies may also be used by us to establish statistics about the use of the Site by Internet users by gathering and analysing data such as: most visited pages, time spent by users on each page, site performance, etc. By collecting and using such data our aim is to improve the quality of the Site. The data collected by our servers and/or through cookies that may be placed on your computer will not be kept for longer than is necessary to fulfil the purposes mentioned above. In any event, such information may not be kept for longer than one year. You can adjust your browser settings to block the recording of cookies and notify you when a cookie is being recorded to your computer’s hard drive. Most browsers can also be set to keep cookies from being recorded on their computer. However, for optimal use of the Site, we recommend that visitors do not block the recording of cookies on their computer. Our servers and computer systems are protected from outside intrusions. As a result, all data that may be collected about Site viewers using cookies will be protected from unauthorised access.
Cookies used on the Site are only active for the duration of the visit. Cookies used on this site are not stored on a visitor’s computer once you have closed your web browser. Information generated using cookies may be compiled into an aggregate form so that no individual can be identified. For more information about cookies, please see the Information Commissioner’s website home page or the Interactive Advertising Bureau.
All documents, programmes, publications, designs, products, processes, software, technology, information, and ideas (Content) provided by or described in this Site are the property of Alta Palma and are protected by U.K. and international copyright laws and other intellectual property laws, unless stated otherwise.
The Content is provided to users of this Site for informational purposes only. Except as expressly permitted below or by applicable law, users may not copy (except to the extent required in order to use the site in accordance with the Legal Notice), store in any medium (including in any other website), distribute, transmit, re-transmit, broadcast, modify, or otherwise make available or communicate to the public any part of the Site or systematically extract material from the Site or any document available through it or in any other way exploit commercially all or any part of the Site or any document available through it without our prior written permission.
Changes to this statement
This statement was last updated in July 2018. Any changes will be published on this page and we recommend you check here regularly to ensure you remain in agreement with our data processing activities. Should any significant changes be made which may directly impact on the way you interact with us through this website, we will make these clear to you at the start of your interaction with our site.
You can address any questions, comments, complaints, or requests regarding this Privacy Notice to the Data Protection Officer at firstname.lastname@example.org
Your right to lodge a complaint with the ICO
If you are not satisfied with our response to any complaints you raise with us or you believe our processing of your information does not comply with the data protection law, we suggest you contact our Data Protection Officer. However, you can make a complaint to the Information Commissioner’s Office (ICO) at any time. Please see the ICO website for further information : https://ico.org.uk/for-the-public/raising-concerns