Last updated: January 2025
1. Introduction
Tracklyt Ltd ("we", "our", or "us") is committed to protecting and respecting your privacy. This
Privacy Policy explains how we collect, use, disclose, and safeguard your personal information
when you use our luxury concierge services, website, and mobile application.
We are registered in England and Wales (Company Number: 12345678) with our registered office at 1
Mayfair Place, London W1J 8AJ. For the purposes of the UK General Data Protection Regulation (UK
GDPR) and the Data Protection Act 2018, we are the data controller.
2. Information We Collect
We collect information that you provide directly to us, including:
- Identity Information: Name, date of birth, passport details, and
identification documents
- Contact Information: Email address, telephone numbers, and postal address
- Financial Information: Payment card details, billing address, and
transaction history
- Service Preferences: Travel preferences, dietary requirements,
accommodation preferences, and special requests
- Communication Records: Records of correspondence with our concierge team
- Technical Data: IP address, browser type, device information, and usage
data when using our digital platforms
3. How We Use Your Information
We use your personal information for the following purposes:
- To provide and personalise our concierge services
- To process bookings, reservations, and payments
- To communicate with you about your requests and our services
- To anticipate your needs and preferences based on previous interactions
- To comply with legal and regulatory obligations
- To improve our services and develop new offerings
- To send marketing communications (with your consent)
4. Legal Basis for Processing
We process your personal information based on the following legal grounds:
- Contract Performance: Processing necessary to provide our concierge
services
- Legitimate Interests: Where processing is necessary for our legitimate
business interests
- Consent: Where you have given explicit consent for specific processing
activities
- Legal Obligation: Where processing is required by law
5. Information Sharing
We may share your personal information with:
- Service Partners: Hotels, airlines, restaurants, and other vendors
necessary to fulfil your requests
- Payment Processors: Secure payment processing providers
- Professional Advisors: Lawyers, accountants, and auditors where necessary
- Regulatory Authorities: Government and law enforcement agencies when
legally required
We ensure all third parties are bound by appropriate confidentiality and data protection
obligations.
6. International Transfers
As we provide global concierge services, your information may be transferred to and processed in
countries outside the UK and European Economic Area. We ensure appropriate safeguards are in
place, including:
- Standard Contractual Clauses approved by the UK Information Commissioner
- Transfers to countries with adequate data protection laws
- Binding corporate rules for intra-group transfers
7. Data Security
We implement robust security measures to protect your personal information, including:
- End-to-end encryption for all communications
- Secure servers with enterprise-grade protection
- Strict access controls and staff training
- Regular security audits and penetration testing
- Compliance with PCI DSS for payment data
8. Data Retention
We retain your personal information for as long as necessary to provide our services and comply
with legal obligations. Member data is typically retained for:
- Active membership: Duration of membership plus 7 years
- Financial records: 7 years from transaction date
- Communication records: 3 years from last interaction
- Marketing preferences: Until consent is withdrawn
9. Your Rights
Under data protection law, you have the following rights:
- Access: Request a copy of your personal information
- Rectification: Request correction of inaccurate data
- Erasure: Request deletion of your data in certain circumstances
- Restriction: Request limitation of processing
- Portability: Receive your data in a portable format
- Objection: Object to processing based on legitimate interests
- Withdraw Consent: Withdraw consent at any time
To exercise any of these rights, please contact us at privacy@tracklyt.com.
10. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact:
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at
ico.org.uk.