Privacy Policy
We take your privacy seriously and only use your personal information as allowed by data protection law.
This Privacy Policy explains what personal information (data) HPB Management Limited collects, how we use it and the legal bases for doing so.
If you have any questions about this policy, please contact our Data Protection Officer at dpo@hpb.co.uk
Request our brochureWho We Are
We are HPB Management Limited [“HPBM”], a company incorporated in England. Company Number: 01581593.
Our registered address and head office is HPB Management Limited, HPB House, Old Station Road, Newmarket, Suffolk, CB8 8EH.
Our telephone number is 01638 660066.
Our website is www.hpb.co.uk
We are the Promoters and Managers of the Holiday Property Bond issued by HPB Assurance Ltd [“HPBA”] who are registered in the Isle of Man company number 021075C. HPBA’s website is www.hpba.co.im
We are the sole agent for HPBA.
HPBM is registered with the Information Commissioner’s Office, registration number Z5864533.
We are part of the Quality Holidays Assured Limited group of companies. You can find more information about the other companies in our group here.
Before we start
Our site contains links to the websites of other companies in the Quality Holidays Assured Limited Group. In addition, there are links in the site to other useful external websites. For example, local tourist information close to our locations. If you follow a link to any of these websites, please note that you have left our site and these websites have their own privacy notices which we encourage you to read before submitting any personal information to them.
We do not accept any responsibility or liability for these third party notices or websites.
Our legal basis for using your personal information
If you are interested in becoming a Holiday Property Bond Bondholder and made an enquiry after May 2018, we rely on your consent to send you marketing materials and information about the Holiday Property Bond. You may withdraw this consent at any time by clicking on a link in an email or contacting us via telephone or letter as above or email to details@hpb.co.uk
If you first registered your interest prior to May 2018, we use the legal basis of legitimate interest to justify our continued marketing to you. This is because we have a legitimate interest to promote our business.
Our lawful basis for processing your personal data if you are a Bondholder is to fulfil the contractual details of a Holiday Property Bond policy and to fulfil our legal obligations.
As a Bondholder you may also receive marketing materials about your Bond or selected other associated travel opportunities. We rely on your consent to do this, and you may change your marketing preferences in the Preferences section of the MyBond website, or by clicking on a link in an email or contacting us via telephone or letter as above or email to details@hpb.co.uk
How do HPBM collect personal information?
If you are not a Bondholder, we collect your personal information by a number of methods.
- By advertising, online and in print publications where you submit your information electronically or on paper forms.
- By using bought in third party marketing lists.
- By using post code data where we send unnamed postal advertising.
- By referrals from Bondholders. This is a well-established method of receiving the names of potentially interested parties from our existing customer base. It is carefully laid out that the individual providing your details to us is required to ensure that permission is sought from you before being referred.
- From an existing Bondholder who has registered you as a member of the HPB Family and Friends website at hpbfamilyandfriends.co.uk
- By receiving your information from prospective or existing Bondholders or directly from you as an Additional Life Assured (which may include sensitive personal data, such as health data).
Bondholder and Additional Lives Assured details are collected at point of sale when you complete forms, contact us or request information by letter, telephone or send us an e-mail.
We will not ask for more information than we need for the purposes for which we are collecting it.
What personal information is used by HPBM?
Prior to becoming a Bondholder or as an Additional Life Assured or as a registered member of HPB Family and Friends we will have your name and contact details which may include postal and email address and telephone number if you have given it yourself.
In addition, we will have a record of any browsing history on our web site www.HPBInsight.co.uk which we may use to further personalise your experience.
We will also have a record of any interaction you may have with us – for example we would have a note against your record of further information requests and marketing material sent to you together with any responses we receive.
When you become a Bondholder, we will use contact details and ‘special category’ data (for example: health information and copy proofs of identity including biometric data and address).
How is your personal information used?
If you have enquired about becoming a Bondholder, we use your personal information to provide you with information about the Holiday Property Bond via electronic mail, postal mail or telephone according to your preference.
We may also send you marketing information on holidays from other members of the Quality Holidays Assured Group.
When you apply to become a Holiday Property Bond Bondholder we act as agents of HPBA. The personal information (including special categories of data) provided to us as part of your application process is used to:
- Assess the application;
- Form the basis of the contract between you and HPBA;
- Confirm compliance with ‘Anti-Money Laundering’ and ‘Countering the Financing of Terrorism’ regulations and guidelines. This may involve carrying out checks with credit reference agencies and other specialised databases in order to comply with our regulatory obligations.
As a Bondholder, your contact information is used to provide you with Group services including special offers and travel services tailored to Bondholders and also other holiday offers as follows:
- Facilitate bookings both online via The MyBond website and by telephone.
- Provide you with Bondholder publications (The Bond magazine).
- Provide you with marketing information about the Holiday Property Bond.
- Where you have confirmed you wish us to send you marketing information on holiday related offers from other companies in our corporate group.
- Identify which areas of the web site are of interest to you so we can be more specific in the information we provide to you – see cookie policy.
In addition, we use your contact information for ongoing contract maintenance of your Holiday Property Bond. This includes:
- Regular points statements. Your points account will be maintained in HPBM offices in Newmarket to allow efficient use of your Holiday Property Bond.
- Correspondence records. Unless deemed trivial, a file note representing the content of any phone call, along with the details of the matter that you contacted us about, will be made and saved electronically. This will not take place for a normal booking for example where the audit trail is based on the computer record created at point of booking. We may still ask you to confirm any verbal requests or changes in writing.
- Holiday and booking records made under your Holiday Property Bond.
- Contacting you about a holiday related matter.
- Verification of identity data.
Telephone calls are not currently recorded.
Who do you share my personal information with?
We treat all information we hold about you as private and confidential.
We will share information with HPBA for whom we act as agent in the marketing and property management of the Holiday Property Bond and the provision of the holiday rights included within the Holiday Property Bond.
We will not reveal any personal details or details concerning your relationship with HPBM or your Holiday Property Bond to anyone not connected with the Quality Holiday Assured Limited Group of companies, unless:
- You ask us to reveal information or we have your permission to do so;
- We are required or permitted to do so by law, including meeting our regulatory obligations;
- It is required by law enforcement, fraud prevention or credit reference agencies;
- There is a duty to the public to reveal the information e.g. to governmental bodies, tax authorities or regulatory bodies.
We are required to share your personal information with selected third parties, or those who are acting as our agents, to perform tasks for us to help service your Bond and fulfil the contract in place between us. These include:
- Payment providers. We do not collect or retain payment card details as this processing is outsourced, but we may (with your consent) retain an authorisation to charge a payment method.
- Credit reference, identity checking and other databases and agencies including the police. We have a legal obligation to reduce fraud and assess security risks and so check and/or file your data with fraud prevention agencies and databases. We will ensure that these third parties agree to treat your data with the same level of protection as if we were dealing with it ourselves.
We do not sell your information to any third party companies for marketing purposes.
How do I change my marketing preferences?
If you are not a Bondholder, you can stop receiving mailings and information by emailing details@hpb.co.uk or telephoning 01638 660066 or writing to us at the address above quoting your name and postcode and asking to be removed from our mailing list.
In first postal correspondence to the individuals referred to us, we will offer the opportunity to use a prepaid reply card to remove your name in case there has been any misunderstanding, or the rules have not been followed properly.
In all subsequent postal mailings, an opt out option will be available on a prepaid reply card.
You may opt out of electronic mailings by using the unsubscribe link in each email received.
If you are a Bondholder, you may manage or update your email preferences on the Preferences page of the MyBond area of the website www.hpb.co.uk at any time. You will be periodically prompted to review them in any case.
Where is my data stored?
The data that we collect from you is securely stored on the Isle of Man and in the UK on cloud based servers. Data collected during the course of identity checking is securely stored in Dublin and Frankfurt. This data is deleted after 14 days.
We will ensure that we have appropriate physical and technological security measures to protect your information regardless of where it is held.
When we outsource any processes, we will ensure that the supplier has appropriate security measures in place and will contractually require them to comply with data protection legislation.
We will ensure that suitable safeguards are in place before personal information is transferred to other countries.
How long do we retain your data for?
If you are enquiring about becoming a Bondholder, we will keep your personal information for up to 18 years from the last time we heard from you, due to the particularly long-term nature of the Holiday Property Bond, unless you ask us to stop contacting you.
If you are a Bondholder, any special category data you may have given to us as part of your application or identity verification process will be destroyed on HPBM’s servers after a short time once HPBA have confirmed their records are complete.
We will retain contact details and details of the investments to facilitate the management of your Holiday Property Bond. We need to retain this information for legal purposes for a period of at least six full tax years from the date the record was created or, if later, at least six years from the date that it ceases to be relevant (such as when you are no longer a Bondholder).
What are my rights?
You have various rights that allow you to control how your personal information is used by us as follows:
| 1. | Right to be informed |
We have to tell you how we are using your personal information. We use this Privacy Policy to do that, but you may request additional information about your own personal circumstances. |
| 2. | Right to access your personal data |
You may ask us for a copy of your personal information that we hold. This allows you to check the information that we have. |
| 3. | Right to correct your personal data |
We are obliged to ensure your personal information is accurate and you can contact us to update existing information or provide additional information. |
| 4. | Right to delete (erase) your personal data |
This does not provide an absolute ‘right to be forgotten’, but you may make this request in the following circumstances: We no longer need your personal information for the purpose we collected it for. Where you have withdrawn your consent to us using your personal information.
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| 5. | Right to limit (restrict) how we use your personal data |
You can ask us to limit how we use your personal information if:
If you exercise this right, we will only use your personal information with your agreement, or to store it or for legal claims. |
| 6. | Right to data portability |
In certain circumstances we will provide you with your personal information in a way that is accessible or machine-readable, or that will allow us to transfer it to another organisation if you request it. |
| 7. | Right to object to us using your data |
We are using your personal data according to one of the legal bases stated above, but you can object to us doing this where
If you object, we will stop using your personal information in this way unless we can show we have compelling legitimate grounds to continue. |
| 8. | Rights around automatic decision making including profiling |
We undertake limited automated decision making (making a decision solely by automated means without any human involvement) when verifying ID digitally. If the automated system initially decides to reject any data, this is always referred to a human for a final decision. We do not undertake profiling (automated processing of personal data to evaluate certain things about an individual). |
| 9. | Right to raise a concern |
If you have any concerns about how we are handling your information, please contact us directly as above. |
How can I complain?
If you are unhappy with how we are handling your personal information, we would prefer it if you contacted us directly on the contact details above so we can put it right for you.
If you still feel we have not handled your complaint correctly, you can complain to the UK’s Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales. Their postal address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone 0303 123 1113, website www.ico.org.uk
Changes to this privacy policy
We keep this Privacy Policy under regular review. Any changes we make will be posted on this page and, where appropriate, notified to you by e-mail or post.
This Privacy Policy was last updated on 05-06-2026
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