Privacy Policy

Privacy Policy for HOPE (www.hope.tt)

Effective Date: 11-Sep-2023

1. Introduction

This Privacy Policy (together with our Terms and Conditions and any other documents referred to in it) describes the type of information that we collect from you (“you/your”) through the use of our services (“Services”), or the use of our website www.hope.tt (“Website”), how that information may be used or disclosed by us, and the safeguards we use to protect it.

Our Website and Services may contain links to third-party websites that are not covered by this Privacy Policy. We, therefore, ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use, and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time, and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Should you have any comments on this Privacy Policy, please email us at admin@hope.tt.

2. Who We Are

2.1 Here are our details:

  • Our Website address is www.hope.tt
  • Our company name is HOPE
  • Our registered address is [Address]
  • Our nominated representative or Data Protection Officer can be contacted via admin@hope.tt

2.2 We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation, which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations, and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

3. What We May Collect

3.1 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).

3.2 We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username, or similar identifier. When you email, phone, live chat, or otherwise, we may collect information such as your first name, last name, email address, and phone number.
  • Contact Data includes billing address, invoicing address, email address, and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments and other details of our Services you have purchased from us.
  • Technical Data includes 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.
  • Profile Data includes your username and password, reservations made by you, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our Website and Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Interaction Data includes any information that you might provide to any discussion forums on the Website.
  • Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use “cookies”?” section below for information about cookies and how we use them and what kind.
  • Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
  • Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.3 We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

3.5 Under GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

  • You have given consent to the processing of your personal data for one or more specific purposes.
  • Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract.
  • Processing is necessary for compliance with a legal obligation to which we are subject.
  • Processing is necessary to protect the vital interests of you or of another natural person.
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child. 

3.6 If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

4. How We May Collect and Use Your Data

4.1 We (or third-party data processors, agents, and sub-contractors acting on our behalf) may collect, store, and use your personal information by way of different methods to collect data from and about you, including through:

  • Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
    • Present Website content;
    • Use any of our Services;
    • Create an account on our Website;
    • Subscribe to our Services or publications;
    • Request marketing to be sent to you;
    • Enter a competition, promotion, or survey; or
    • Give us some feedback.

4.2 In addition to the above, we may use the information in the following ways:

  • To personalize your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  • To administer a contest, promotion, survey, or other site feature.
  • If you have consented to receive our e-mail newsletter, we may send you periodic emails. If you would no longer like to receive promotional e-mail from us, please refer to the “How can you opt-out, remove, or modify information you have provided to us?” section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and “members-only” content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.
  • Present Website content effectively to you.
  • Provide information and services that you request, or (with your consent) which we think may interest you.
  • Carry out our contracts with you.
  • Provide the relevant Services to you.
  • Tell you our charges.

4.3 If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.

4.4 If you are a new customer, you will only be contacted if you agree to it.

4.5 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

4.6 In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section 4, you can let us know at any time by contacting us at admin@hope.tt, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible

services to you.

4.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the

services we can provide you if you don’t provide your personal data in these cases.

4.8 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, for example, compliance with health and safety, tax, or other statutory obligations.

4.9 Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party 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 at admin@hope.tt, and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.

4.10 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news, and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.

5. Cookies

5.1 All Cookies used by and on our website are used in accordance with current UK Cookie Law.

5.2 We use cookies to distinguish users and improve our Website. Please look at our Cookie Policy here for more cookie information.

6. Where We Store Your Data and Security

6.1 We may transfer your collected data to storage outside the UK. It may be processed outside the UK to fulfill your order and to receive our Services and deal with payment. If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the UK if it is necessary for us to do so.

6.2 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your data. We take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.

6.3 We 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.

6.4 We will do our best to protect your personal data; however, the transmission of information over the internet is not completely secure. We cannot guarantee the security of your data transmitted to our Website or Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

7. How Long Do We Keep Your Data?

7.1 We keep your personal data for the duration of your subscription with us. If you withdraw your consent for us to use your personal data, we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.

7.2 We may keep your data for up to 6 years after your subscription has expired. We may not be able to delete your data before this time due to our legal and/or accountancy obligations. However, we will ensure that your personal data is only used for those purposes.

7.3 We have procedures in place to deal with any data breaches. We will notify you and any applicable regulator of a data breach where we are legally required to do so.

7.4 In some circumstances, you can ask us to delete your data; see below for further information.

8. Your Rights

8.1 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 for 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.

8.2 If you wish to exercise any of the rights set out above, please contact us at admin@hope.tt.

8.3 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.

8.4 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.

8.5 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.

9. Contacting Us

9.1 Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at admin@hope.tt.

10. Changes to Our Privacy Policy

10.1 Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

10.2 This Privacy Policy was last updated on 11-Sep-2023.