Privacy Policy
GLOBAL ELITE CLUB's Commitment To Your Privacy
GLOBAL ELITE CLUB respects your privacy and your desire to understand how your information will be handled and used. This Privacy Policy explains how we collect, use and store your information. Using your information in a way that you are comfortable with and keeping your information secure is an integral part of the luxury club experience we aim to provide. GLOBAL ELITE CLUB will ensure that all information protection and customer legislation standards are met when handling any of your personal information.
The Data Protection Act 2018
Following introduction of the Data Protection Act 2018 (the Act), implemented into English law as a result of the General Data Protection Regulation (EU 2016/679) (GDPR) on 25th May 2018, you now have enhanced rights and protections in relation to how we process your personal data. The purpose of this Privacy Policy is to inform you as to what personal data we collect, why we collect that data and how we handle it.
The Data Controller
Any information collected in the course of providing services to you is controlled by Global Elite Club –, and for the purpose of the Act, Global Elite Club is the data controller of your personal data. References in this Privacy Policy to “we”, “ us" “our” and “BRAND NAME” are to GLOBAL ELITE CLUB (company number 66432), whose registered office is at (Apia, Samoa) and whose main place of business is at Reignwood International Investment (Group) Co. Limited. Level 96, ICC, 1 Austin Road West, Kowloon, Hong Kong
Global Elite Club is part of a group of companies. If you would like details of the companies within the group, you can request this information by contacting our Data Protection Officer using the contact details in the paragraph below. We may share personal data with other companies in our group where this is required to manage your membership including enhancements to your membership. All members of our group will handle your personal data in accordance with this Privacy Policy.
We have appointed Data Protection Officer who is responsible for dealing with any questions relating to this Privacy Policy. If you have any questions relating to this Privacy Policy or general questions relating to how and why we process your personal data, please contact our Data Protection Officer by email at alex.field@uk.reignwood.com or by mail to Reignwood International Investment (Group) Co. Limited. Level 96, ICC, 1 Austin Road West, Kowloon, Hong Kong, marked for the attention of the Data Protection Officer.
You have the right to make a complaint at any time to the Information Commissioner's Office(ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk ). However, we always welcome the opportunity to address any concerns you may have before you notify the ICO of any concerns.
Section 1-What Information Do We Collect And How Do We Use It?
We collect and use information about you to ensure that we can provide you with a luxury member programme experience. You provide us with your information directly when you sign up to be part of the GLOBAL ELITE CLUB programme, when you make an enquiry or, if granted, allow us access to your profile held by your Club.
Information collected when you join as a GLOBAL ELITE CLUB Member
When you become a GLOBAL ELITE CLUB Member we collect certain personal information about you and your family members if you choose to have a Family Membership, including your name, address, date of birth, occupation, nationality, your email address and your telephone and/ or mobile number.
The most exclusive news about events, products and services is reserved for GLOBAL ELITE CLUB Members. Should you become a GLOBAL ELITE CLUB Member and opt in to hear about news and exclusive offers, depending on your Membership preferences we will contact you about the many benefits reserved for GLOBAL ELITE CLUB Members including events, third party offers and access, and news from the GLOBAL ELITE CLUB portfolio. Your information will also be used to track your usage so that we can monitor customer engagement to improve our service.
The most exclusive news about events, products and services is reserved for GLOBAL ELITE CLUB Members. Should you become a GLOBAL ELITE CLUB Member and opt in to hear about news and exclusive offers, depending on your Membership preferences we will contact you about the many benefits reserved for GLOBAL ELITE CLUB Members including events, third party offers and access, and news from the GLOBAL ELITE CLUB portfolio. Your information will also be used to track your usage so that we can monitor customer engagement to improve our service.
From time to time, we may also collect publicly available information about you which is not essential to delivery of the exclusive GLOBAL ELITE CLUB experience but which enables us to learn more about you and, in turn, provide a more tailored service. If you would like to stop GLOBAL ELITE CLUB using this information about you in this way, please contact us at gec@uk.reignwood.com
Communication Information
We will process your personal data to maintain your membership with us, to provide our member services to you, to communicate with you and to maintain our member database. The reason we process this data is to ensure we fulfil our membership contract with you, and also to ensure the proper administration of your membership (our legitimate interest).
When you register an interest in GLOBAL ELITE CLUB through our website, and when you report a problem with our website, we may collect certain information from you. The information you give us may include your name, address, email address and phone number.
If you communicate with us, we may process the information contained in your communication. This information may include your name and contact information, the content of your communication and any metadata our website generates where you communicate with us using the contact form on our website.
Information supplied when you participate in Competitions, Prize Draws, Giveaways, Events and Offers
We will process this data so we can deal with your enquiry, or to address your query or concern. The reason we process this data is to ensure the proper administration of your enquiry and our business (our legitimate interest).
When you participate in a competition, prize draw, giveaway or offer, or sign up to attend one of our events, you will provide certain information to participate in the event or promotion. You may also provide personal information for a guest(s) for one of our events. When you do this, please ensure your guest(s) have consented to you providing us with their information. We will assume you have obtained your guest(s)' consent when you provide us with their personal information for these purposes. Your and your guests' information will be deleted shortly after the promotion or event has finished, unless you or they have signed up to receive marketing communications from us.
We will collect this information to ensure we can properly administer and manage the events and promotions we operate, including securing your registration at an event, and selecting and contacting prize winners (our legitimate interest). During the events, we will be taking photos at the event. These images will be used by GLOBAL ELITE CLUB to share news about the event, and to publicise our future events. Images may be published on the GLOBAL ELITE CLUB website. They will be stored securely, and we will delete them after they are no longer needed for publicity purposes. We may also share photos with members of GLOBAL ELITE CLUB for their professional use.
The reason we process this data is to ensure the proper administration of your membership and our business (our legitimate business interest).
Information relating to your Marketing Preferences
GLOBAL ELITE CLUB will only send you marketing communications where you have consented to receive them and using your preferred channels of communication. To ensure that you are still happy to hear from us, we will contact you to ask you whether you want to opt-in of receiving marketing communications from us.
We will only continue to send you marketing communications where you expressly tell us that you want to and our legal basis for processing this data is that you have given you consent to receiving such marketing communications.
If you have opted-in to receive marketing communications from us you can manage your marketing preferences at any time. Please contact gec@uk.reignwood.com to manage your marketing communications preferences and tell us what you want to hear about and how you want GLOBAL ELITE CLUB to communicate with you.
Please note that when you visit one of GLOBAL ELITE CLUB's brand partners or participate in a branded promotion or event, our brand partners may also ask if you want to sign up to receive marketing communications directly from them about their events, products and services. If you provide your personal details to any of our brand partners, the use of that information will be governed by their privacy policy and cannot be managed through GLOBAL ELITE CLUB. Please ask the relevant brand partner for details about their privacy policy and how you can manage your marketing communications preferences with them.
Information we collect about you when you use our website
With regard to each of your visits to our website we will automatically collect the following information:
technical information, such as your Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We will obtain this data through our analytics tracking system. We process this data so we can analyse how our website is used so we can improve our website and our services;
information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page. We process this data so analyse how our website is used so we can improve our website and our services.
Information we collect about you when you use our website
This is information we receive about you if you use any of the other websites we operate or the other services we provide.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We may receive personal data about you from these organisations. Those organisations will have their own privacy policies detailing how they process personal data.
Section 1-Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our
Section 2 – When will we disclose your personal data to others?
We may need to share your personal information with members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. These terms are defined in section 1159 of the UK Companies Act 2006. We will only share such personal information where this is necessary for the purposes set out in this Privacy Policy.
We may need to share your personal information with certain selected third parties including
We may share your information between the clubs and properties within the GLOBAL ELITE CLUB programme. We will only share your personal data if you have consented that we can do this. Your information will be shared in accordance with the Act. If you join the GLOBAL ELITE CLUB programme, your personal data will be processed in accordance with their privacy policies which are available on their websites.
our business partners, suppliers and sub-contractors for the purpose of performing any contract we have with you or them. For example, we may use suppliers to provide services to members on our behalf to enhance our membership experience;
analytics and search engine providers that assist us in the improvement and optimisation of our website;
credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
We will also disclose your personal information to third parties in the following circumstances:
If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets
If all or most of our assets are acquired by a third party, in which case personal data held by us about our members will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any legal agreement we have with you; or to protect our rights or property, or the safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Section 3-Where do we store your personal data and how do we keep your Information Secure?
All data that you provide to GLOBAL ELITE CLUB will be stored securely. We make sure that we have information security measures in place to keep your information secure. Where we ask third parties to work on our behalf, before sharing information we always make sure that they have sufficient information security measures in place.
We will not share your information with any third parties who might wish to market their goods and services to you unless you have provided your consent. Information you provide to GLOBAL ELITE CLUB may be shared within companies forming part of the Reignwood group companies. We also work with a number of third parties to help us deliver an excellent service to you.
We will always try to ensure that your personal data is processed within the UK and the European Economic Area. In some circumstances this will not be possible. In circumstances where it is necessary for us to transfer your personal outside the UK and European Economic Area, we will only transfer such personal data to third parties where we have carried out due diligence on such third parties to ensure they will protect your personal data using similar standards and safeguards as we have. We will also have contractual provisions in place with such third parties to ensure your personal data is protected. Such contractual provisions will be based on the standard contractual clauses approved by the European Commission for the transfer of data outside the UK and the EEA or such other appropriate standards as are required from time to time by the European Commission or the UK Government. You consent to the transfer of your personal data outside of the EEA, as long as we comply with these requirements.
All information you provide to us is stored on our secure servers, including payment information.. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have appropriate security measures in place to prevent personal information from being accidentally lost or from being 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 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.
Section 4-How Long Will GLOBAL ELITE CLUB Keep My Information?
GLOBAL ELITE CLUB is committed to keeping your personal information only for so long as is reasonably necessary to fulfil the purposes we collected it for or where we have a legitimate interest to continue doing so. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it which will include satisfying any legal, accounting, or reporting requirements. Any personal data that we process will be deleted from our systems once we have completed the purpose for which we were processing the personal data. In some cases, the purpose for which we are processing your personal data will last for a considerable period (for example, if you are a long term member of ours, we will need to store your data until our relationship with you comes to an end) .
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We will take into consideration a number of factors such as your relationship with us, your engagement with us, and the fulfilment of contracts we have with you. Where Wentworth no longer requires information to be in a format where you can be identified personally, eg where we keep information for analytical and research purposes or transaction information, we will remove any personal details about you..
We may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interest or the vital interests of another natural person.
Section 5 – Your Rights
Under the Act you have the following fundamental rights:
The right to access the personal data we hold about you;
The right to have your personal data corrected if there are errors or inaccuracies in it, or your personal data is incomplete;
The right to restrict the processing we carry out in relation to your personal data;
The right to object to the processing we carry out in relation to your personal data;
The right to have the personal data we hold about you provided to you in a useable format;
The right to complain to a supervisory authority (in the UK this is the Information Commissioner's Office (www.ico.org.uk)) about how and/or why we are processing your personal data;
The right to tell us you no longer consent to us processing your personal data.
Section 6-How Can You Manage The Information We Hold About You?
As part of our commitment to exceptional customer service, where you have provided your consent, we personalise your experience, by only sending marketing communications about the most exclusive products, services and events that we believe you will be interested in. You have always been able to withdrawn your consent for these communications but now it is easier than ever to manage your preferences:
If you have an online account, you can manage your communication preferences through our Preference Centre by logging in to your account here
Alternatively, contact GEC@uk.reignwood.com You can also unsubscribe from all email marketing communications via the “Unsubscribe” link at the bottom of each of our email marketing communications.
It can take up to two weeks for your preferences to be registered on our system, so you may still receive communications from us during this period.
Making a Data Subject Access Request
Should you wish to know more about what information we hold about you including making changes to, or requesting the deletion of, information that we hold about you, you are also entitled by law to make a Data Subject Request. You can make such a request by emailing us at gec@uk.reignwood.com (quoting “Data Subject Request”). Please note that we may need to exclude certain information as part of your request, eg in order to protect the privacy of other individuals or if we are permitted to exclude the information for legal or other reasons.
We will ask you to provide appropriate evidence of your identity before we respond to your request. Typically this identification evidence will be a photocopy of your passport or photo driving licence, which a solicitor or bank has certified as being a true copy of the original and a copy of a recent utility bill detailing your current address.
Contacting Us
If you have any questions about this Privacy Policy or our privacy practices or if you want to ask us to delete your data, please contact us in the following ways:
Full name of legal entity: Global Elite Club
Email address: gec@uk.reignwood.com
Postal address: Reignwood International Investment (Group) Co. Limited. Level 96, ICC, 1 Austin Road West, Kowloon, Hong Kong
How Will I Know If This Privacy Policy Changes?
If we specifically change the way in which we use your personal information or if we need to notify you about a change to the information that we hold about you, we will specifically contact you.
Any future changes to our Privacy Policy will be updated online at wentworthclub.com with the last date of update displayed as below. We encourage you to check this site periodically to learn about the information that we collect, use and share.
This Privacy Policy was last updated in July 2020
Security Policy
Security of our website is of utmost importance to us. Our site uses software to provide high level encryption technology. Although we use advanced security measures to protect your information against loss, misuse and alteration, as is the case with all computer networks linked to the internet, we cannot make absolute guarantees over the security of the information you provide over the internet and as such we cannot be held responsible for it.
We will never contact you by email to ask you to send or confirm any of your personal details, if we need any information of this nature we will only contact you by telephone.
We advise that you never send any sensitive information, such as passwords or credit card information, via email.
Where you have chosen to create a password to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.