Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you contract our services, when you sign up to our newsletter, when you take part in a competition etc.

This website is not intended for children and the only circumstances in which we collect data relating to children, is where you hire property management and related services, and you have children in your party.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Data Controller
WCS BESPOKE MANAGEMENT S.L. (collectively referred to as “we”, “us” or “our” in this Privacy Policy) is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Data Controller
WCS BESPOKE MANAGEMENT S.L. (collectively referred to as “we”, “us” or “our” in this Privacy Policy) is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: WCS BESPOKE MANAGEMENT S.L.
Name or title of data privacy manager: Clare Westwood
Email address: wcs@wcsbespoke.com
Postal address: Calle Forma 8, 11310, Sotogrande, San Roque, Cádiz,
Spain
Telephone number: +34 956 610 474

This website complies with the following regulations:
The RGPD (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the protection of natural persons), which is the normative of the European Union that unifies the regulations for processing personal data in the EU countries.
The LOPD (Organic Law 15/1999, of December 13, for the Protection of Personal Data and Royal Decree 1720/2007, of December 21, the Regulations for the development of the LOPD) which regulates the processing of personal data and the obligations that those responsible for a website or blog must assume when managing this information.

You have the right to make a complaint at any time to the Agencia Española de Protección de Datos (AEPD), the Spanish supervisory authority for data protection issues (https://www.aepd.es/). We would, however, appreciate the chance to deal with your concerns before you approach the AEPD, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. This version was last updated on 30 January 2024 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. Identity Data
   This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data
   This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
3. Financial Data
   This includes data relating to your means and methods of payment, such as your bank account and payment card details.
4. Transaction Data
   This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
5. Technical Data
   This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
6. Profile Data
   This includes the data that we receive when you create a profile on our website and make use of that profile, such as purchases or orders made by you, your interests, preferences, feedback and survey responses.
7. Usage Data
   This includes information about how you use our website, products and services.
8. Marketing and Communications Data
   This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences

Special Categories of Personal Data

We collect the following special categories of personal data about you. Details about your:

• dietary requirements which may disclose your religious or philosophical beliefs;
• health;
• race or ethnicity;
• sex life and/or your sexual orientation;
• political opinions.

We collect and process the above data only where it is strictly necessary to do so in order to deliver the agreed services that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the various services that you have requested or are attempting to contract. As a result, if you do not provide your consent, we will be unable to proceed with your booking.

If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the services you have requested, we will be required to treat any withdrawal of consent as a cancellation of your agreed services with us and the cancellation charges referred to in our Terms and Conditions given with our contract, will become payable.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

In other words, where we require details from you in order to provide you with your chosen property management and other services, if you do not provide us with the necessary details then we will not be able to provide the services you have arranged or are attempting to request.

In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your contract or we may have to cancel your agreed services, in which case we will treat this as a ‘cancellation by you’ in accordance with our Terms and Conditions given with our contract. We will notify you if we are unable to process a contract or are required to cancel your agreed services for this reason.

We use different methods to collect data from and about you including through:

1. Direct interactions
   You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   • request information or agreed a contract for property management and related services;
   • create an account on our website;
   • subscribe to our newsletter or other publications;
   • request marketing to be sent to you;
   • enter a competition, promotion or survey; or
   • give us some feedback.
2. Automated technologies or interactions
   As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.wcsbespoke.com/cookie-policy for further details.
3. Third parties 
   We may receive personal data about you from various third parties as set out below:
   • Technical Data from the following parties:
     • analytics providers such as Google based outside the Spain;
   • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Protected Trust Services based in Spain.
   • Identity and Contact Data from publicly available sources such as the Spanish Registro Mercantil and the Electoral Register based inside Spain.

Please note that when using our website, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them. This will not be the responsibility of WCS BESPOKE MANAGEMENT S.L.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer.	(a) Identity (b) Contact	Performance of a contract with you.
To process and deliver your booking including: (a) Manage payments, fees and charges;(b) Collect and recover money owed to us.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy;(b) Asking you to leave a review or take a survey.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation;(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To monitor our communications with you in order to check any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to defend legal claims.	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (to assist us in training our employees and defend our business in the event of a claim). (b) Necessary to comply with a legal obligation;

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can contact us at wcs@wcsbespoke.com to change your marketing preferences at any time.

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at wcs@wcsbespoke.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase or other transaction.

Monitoring communications

We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://wcsbespoke.com/cookie-policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

1. Internal Third Parties as set out in the Glossary.
2. External Third Parties as set out in the Glossary.
3. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

e have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

1. Request access to your personal data.
2. Request correction of your personal data.
3. Request erasure of your personal data.
4. Object to processing of your personal data.
5. Request restriction of processing your personal data.
6. Request transfer of your personal data.
7. Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS

• Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract 

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation 

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

• Internal Third Parties

Other companies in the WCS Bespoke Management S.L. and who are based in the UK and Spain and provide IT and system administration services, financial accounting and undertake leadership reporting.

• External Third Parties

1. Service providers acting as processors based in the UK and Spain who provide IT and system administration services, marketing services and support.
2. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and Spain who provide consultancy, banking, legal, insurance and accounting services.
3. Spanish Tax Authorities, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

• Request access 

to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction 

of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure 

of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing 

of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing 

of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. if you want us to establish the data’s accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer 

of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time 

where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.