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Privacy Policy

This privacy policy explains what information HPB Management Limited collects and what the information is used for. If you have any questions or concerns regarding this policy, please contact our Data Protection Officer by email at DPO@hpb.co.uk

We take your privacy seriously and we will only use your personal data in line with the provisions of current data protection legislation.

Who We Are

We are HPB Management Limited ("HPBM"), a company incorporated in England. Company Number: 01581593

We are the Promoters and Managers of the Holiday Property Bond issued by HPB Assurance Ltd who are registered in the Isle of Man company number 021075C.

Our registered address is HPB Management Limited, HPB House, Old Station Road, Newmarket, Suffolk, CB8 8EH.

HPB Management Ltd is the sole agent for HPB Assurance in the Isle of Man – the issuer of the Holiday Property Bond www.HPBA.co.im

HPBM is registered with the Information Commissioner’s Office and our registration number is Z5864533.

The website for HPB Management Limited is www.hpb.co.uk

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.


Information for non-Bondholders only

This information is specific to the publicly available part of the website i.e. no password required.

How do HPBM collect personal information?

  • By receiving referrals from existing Bondholders, advertising, online and in print publications
  • Basic personal data is collected by electronic means or paper forms being returned to us
  • Occasionally we may also send postal marketing materials to you, using data we receive from third party sources
  • In addition, we will send unnamed postal advertising by using – for example – post code data rather than anything which personally identifies you.
  • Referrals – 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 the referee’s details to us is required to ensure that permission is sought from the person being referred.
  • From an existing Bondholder who has registered you as a member of the ‘HPB family and friends website’.
  • 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).

What 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 the Personal Data provided by you (or a Bond holder referrer) with some or all of salutation, forename or initial, surname, full postal address, Post Code, email address, telephone number/s
  • In addition, we will have a record of any browsing history on our web site HPBInsight 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 with any responses received

How is your information used?

  • The personal data is processed in order to provide you with information via electronic, postal or telephonic media, depending on the information we hold. For example, we will only contact you by post if we only have your postal address
  • We may also send you marketing information on holidays from other members of our corporate group
  • We will not telephone you if you have not given us your telephone number (but please be aware that we may be given it by a Bondholder who refers you)
  • For those enquirers who first registered their 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. For the records created after May 2018, we rely on the consent given by you (see below for ‘referral mechanism’)
    • Because of the peculiarly long-term nature of the Holiday Property Bond, we will continue to send you marketing material for a maximum of 18 years since we last heard from you, unless you tell us that you no longer wish to receive our communications.
    • There will be frequent opportunities to opt out of such material but in any event, you can stop receiving mailings and information by emailing details@hpb.co.uk or telephoning 01638 660066 quoting your name and postcode and asking to be removed from our mailing list.
  • In first 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 mailings, an opt out option will be available on the prepaid reply card

Sharing information

We treat all information we hold about you as private and confidential. We will not reveal any personal details or details concerning your Holiday Property Bond to anyone not connected with the Quality Holidays Assured Limited group of companies, unless:

  • You ask us to reveal such 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;

 


 

Information for Bondholders only

MyBond area of the website

How do HPBM collect personal information?

  • In order to provide you with information on our products and services we need to collect, use, share and store personal and financial information about you.
  • We will only collect and use your information where we have lawful grounds and
  • Our lawful basis for processing your personal data used in the creation of a Holiday Property Bond is in the pursuance of fulfilling the contractual obligations of your policy and to fulfil our legal obligations.
  • Our lawful basis for providing you with marketing information on HPB and other group companies is consent. This consent is easily maintained or withdrawn on the MyBond area of the website www.hpb.co.uk or by telephoning or emailing us.
  • We will not ask for more information than we need for the purposes for which we are collecting it.
  • Your details are collected when you complete forms, contact us or request information by letter, telephone or send us an e-mail.

What information is used by HPBM?

Personal data collected at point of sale including contact details and ‘special category’ data (for example: health information and copy proofs of identity and address) provided when you applied to become a Bondholder.

This special category data will be destroyed on HPBM’s servers after a short time once HPBA (the life company) have confirmed their records are complete. HPBM will retain contact details and details of the investments to facilitate the running of your Holiday Property Bond. We may need to write, email or telephone you for example on a holiday related matter.

How is your information used?

When you apply to become an HPB Bondholder (HPBM act as agents of HPBA)

The personal data (including special categories of data) provided to us when you apply to become a Holiday Property Bond holder 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.

To provide you with Group services including special offers and travel services tailored to HPB and also other holidays offers

  • Facilitate bookings both online and by telephone
  • Regular points statements
  • HPB Bondholder publications (the Bond magazine – posted)
  • Provide you with marketing information via electronic means, by post or by telephone on the Holiday Property Bond based on the details supplied
  • Where you have confirmed you wish us to send you marketing information on holiday related offers from other companies in our corporate group by electronic means or post
  • 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
  • Correspondence records are held along with holiday and booking records.
  • Your email preferences can be managed or updated on the preferences page of the MyBond area of the website www.hpb.co.uk at any time and you will be periodically prompted to review them

For ongoing contract maintenance

We will share information with HPB Assurance Limited (“HPBA”) for whom HPBM 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.

  • Your points account will be maintained in HPBM offices in Newmarket to allow efficient use of your Bond
  • We will also have records of holidays made under your Bond
  • We will hold that information until six full tax years after the surrender or other cessation of the Bond
  • This data sharing is particularly useful in keeping your personal data accurate;

When you phone us

When you phone us, we may ask you to confirm any requests or changes in writing,

  • Unless deemed trivial, a file note representing the content of your 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

Telephone calls are not currently recorded.

Sharing information

We treat all information we hold about you as private and confidential. We will not reveal any personal details or details concerning your Holiday Property Bond to anyone not connected with the Quality Holidays Assured Limited group of companies, unless mentioned below.

  • 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.

To complete and service your policy 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. These include payment providers; credit reference and other agencies who we may use for the provision of information to assess fraud, credit and/or other security risks. 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.

To prevent and detect fraud we may share your data with other organisations, including the police, and check and/or file your data with fraud prevention agencies and databases.

Your marketing preferences can be altered in the MyBond preferences section of the www.hpb.co.uk website.

 


 

Information for Bondholders and non-Bondholders

Where is my data stored?

The data that we collect from you is securely stored on servers in Newmarket, UK, and in the Isle of Man.

We will ensure that we have appropriate security measures physical, technological and contractual 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 current data protection laws.

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?

For Bondholders

We will retain your data for legal purposes for a period of at least six years from the date the record was created or, if later, at least six years from the date that it ceases to be relevant.

For non-Bondholders

Because of the peculiarly long-term nature of the Holiday Property Bond, we will retain your data for a maximum of 18 years since we last heard from you, unless you tell us that you no longer wish to receive our communications.

What are my rights under Data Protection laws?

Right to access

You are entitled to receive confirmation as to whether your personal information is being processed by us, as well as supplementary information relating to our use of your personal information.

You also have the right to access your personal information which we are handling.

Your right of access allows you to be aware of and verify the lawfulness of the processing of your data.

You can exercise this right by contacting us. The easiest way is by email at dpo@hpb.co.uk

Right to rectification

You have the right to require us to correct any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you rectified, by providing a supplementary statement to us.

Right to erasure

The right to erasure does not provide an absolute ‘right to be forgotten’.

You have the right to request the erasure of your personal information which we are handling, and to prevent the processing of your data in the following specific circumstances:

  • we no longer need to use your personal information for the reasons we told you we collected and processed it for;
  • where we needed your consent to use your personal information and you have withdrawn your consent;
  • you object to our use of your personal information and we have no overriding legitimate reason for continuing the processing of your personal information;
  • our handling of your personal information was unlawfully processed;
  • we must erase your personal information to comply with any legal obligation we are subject to.

Right to restrict processing

You can restrict our processing of your personal information where:

  • you think we hold inaccurate personal information about you, until the accuracy of your personal data has been verified;
  • our handling of your personal information breaks the law, but you do not want us to delete it;
  • we no longer need to process your personal information, but you want us to keep it for legal reasons;
  • you have objected to the processing (where it is necessary for the purpose of legitimate interests or the performance of a public interest task), and we are considering whether HPBA’s legitimate grounds override those of yours.

Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle legal claims.

Right to data portability

In certain circumstances you have the right to receive the personal information held about you in a structured, standard machine-readable format and to send this to another organisation controlling your personal information

Right to object

We are handling your personal information pursuant to our contractual and legal obligations.

You have the right to object to us handling your personal information when:

  • We are handling your personal information based on legitimate interests;
  • If we use it for marketing purposes;
  • If we process your data for the purposes of scientific/historical research and statistics.

If you ask us to stop handling your personal data in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue.

Rights related to automated decision making, including profiling

We do not undertake any automated decision making (making a decision solely by automated means without any human involvement).

We do not undertake profiling (automated processing of personal data to evaluate certain things about an individual).

YOUR RIGHT TO COMPLAIN

You have the right to lodge a complaint with 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.

WHAT ABOUT WEBSITES WE LINK TO?

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 policies.

We do not accept any responsibility or liability for these policies or websites. Please check their policies before you submit any personal information to these websites.

CHANGES TO THIS PRIVACY POLICY

We keep our privacy notice under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or post.

Please check back frequently to see any updates or changes to our privacy policy.

This privacy policy was last updated on 25-10-18

HOW DO I CONTACT YOU WITH FEEDBACK?

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to DPO@hpb.co.uk

LEGAL AND CONTACT INFORMATION

The registered and Head Office of HPB Management Limited is:

HPB House
24/28 Old Station Road
Newmarket
Suffolk
CB8 8EH

You have a right to access the personal data held about you. To obtain a copy of the personal information we hold about you, please email DPO@hpb.co.uk or write to the Data Protection Officer at our address shown above.

This advertisement is issued by HPB Management Limited ("HPBM") registered at HPB House, Newmarket, Suffolk, CB8 8EH. HPBM is authorised and regulated by the Financial Conduct Authority and is the main UK agent and the property manager for HPB, issued by HPB Assurance Limited ("HPBA") registered in the Isle of Man and authorised by the Financial Services Authority there. The Trustee of HPB is HSBC Trustee (C.I.) Limited registered at HSBC House, Esplanade, St Helier, Jersey, JE1 1GT. The Securities Manager is Stanhope Capital LLP of 35 Portman Square, London, W1H 6LR.

Holders of policies issued by HPBA will not be protected by the Financial Services Compensation Scheme if the company becomes unable to meet its liabilities to them but Isle of Man compensation arrangements apply to new policies. No medical examination required. HPB is available exclusively through HPBM who will only charge for their services if you invest. HPBM promotes only HPB and is not independent of HPBA.

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