Privacy Policy

Privacy Policy

NORTH SIDE INTERNATIONAL LTD
First Floor - 26, Cowper Street
London, UK EC2A 4AP

Welcome to RED CIRCLE.
We are committed to respecting and protecting your privacy. This privacy notice sets out how we collect and use the personal data that you provide to us via this website, www.thesunsecretcollection.com (our "Site"), and our mobile app, RED CIRCLE (our "App", and together with Site, and any other services we provide to you, our "Services"). It also tells you about your privacy rights and how certain laws may apply to you.
If you have any queries about this notice or how we use your personal information, please contact us at [email protected]


1. Introduction

Our Services are operated by NORTH SIDE INTERNATIONAL LTD – owners of the brands The Sun Secret Collection and RED CIRCLE ("The Sun Secret Collection" and "RED CIRCLE", "Our", "Us" or "We")
NORTH SIDE INTERNATIONAL LTD is a limited company registered in England & Wales with company number No. 11440097 - VAT No. 303746420
Registered office: First Floor - 26, Cowper Street - London - EC2A 4AP.
Telephone No: + 44 (0) 203 7693 631.
For more information please see: www.clubredcircle.com
You can contact us about any queries you have regarding this privacy notice at either our postal address above, or at [email protected]com


2. What Personal Data Do We Collect

'Personal data' means any data which can be associated with you as an individual, either directly or indirectly. We collect different information depending on how you use the Services and how you interact with us.

The personal data we collect via the Services may include:

  1. Identity information, such as your name, organisation name and position, and your driving licence and passport information.
  2. Contact data, such as your address and email and telephone details.
  3. Usage data, which includes information about how you use the Services (including any bookings, reservations or other services we have provided to you, and our conversations with you), and your location.
  4. Log-in information, such as your user name and password.
  5. Payment and transaction information, including your booking history, and certain other information associated with your payments. This does not include your payment card details, which you provide direct to our payment processors. We do not collect or store payment card details.
  6. Technical data, such as the device you are using to access our Services, your unique device ID, your internet protocol (IP), browser type and version, time zone and location, display settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.
  7. Marketing and communications data, including any communications we may receive from you, and your preferences in receiving notifications, marketing and other communications from us.

3. What Personal Data Do We Collect

here are numerous ways through which We collect Your personal data, including:

  1. your identity, contact, and log-in information, and your marketing and communications preferences;
  2. information supplied by You, when filling out Our application forms, when communicating with Us through letters and emails, over the phone or through the device You use;
  3. When you enter your payment card details via our Services, they are provided direct to our payment processors. We do not collect or store payment card details. You will also provide us with personal data when you correspond with Us;
  4. Information from Our analysis of how You operate and make use of Our products and services, including the frequency, nature, location, origin and recipients of any payments You make while using Our services;
  5. Information from, or through, other organisations (for example travel agencies, travel designers, social media, and public information sources)

We also use Google Analytics, a third-party service provided by Google, to help us analyse user habits to help increase the functionality of our Services. The information will be used by Google only for the purpose of evaluating the use of our Services. Google Analytics has its own privacy notice, which can be viewed here.


4. How We Use Personal Data

The personal data We collect from You has multiple uses, including the following:

  1. in order to be able to render Our services to You and therefore fulfil Our legitimate interests;
  2. to carry out Our contractual obligations to You in relation to any of Our services which You make use of;
  3. in order to manage Your relationship with Us, as well as managing Our relationship with and complying with Our regulators and therefore fulfilling Our legal obligations;
  4. to ensure that content from Our App is presented in the most effective and efficient way on Your device; to inform You about Our products, services and upgrades, which We feel may interest You, only in cases where You have consented to be contacted for such purposes;
  5. to allow You to make use of the interactive features of Our App, only when You choose to do so;
  6. to notify You and keep You up to date about changes to Our service.

5. With Whom Do We Share Your Personal Data?

In order to be able to render Our most effective and efficient service to You through the App, We may share Your personal information with third parties, which render their services to Us, and consequently You.

Such sharing and transfers of Your personal data might occur to areas outside the EU i.e. third countries. We will only transfer Your personal data to such third countries if We have a data processing agreement in place with such third country, which has a standard of data protection which equals those laid out in the GDPR as well as Our own data protection policies.

If such data processing agreement is not present, We will not transfer Your personal data unless We have acquired Your explicit consent beforehand.


6. Why Do We Need Your Personal Data?

In order for Us to be able to render Our services to You, for You to be able to use Our App and for Us to fulfil the contractual obligation which We have entered into with You, We must collect Your personal data. When We first onboard You as Our client, We collect certain data from You as well as input You into Our system and then maintain an accurate record of You, and Your personal information with Us. We require Your personal data in this manner in order to comply with national and EU legislation, particularly anti-money laundering legislation, and countering of financing of terrorism (AML & CFT), as well as to comply with Our regulators.

There is some personal information which We collect from You in pursuit of Our own legitimate interests, such as providing You with Our services, all the while providing the most efficient and effective service possible.

It is important to note that if You refuse to provide Your personal data to Us, or object to the processing of Your personal data (which You can do at any time – read further down below), We may not be able to provide Our services to You at all, including the App, as that would mean that We may be in breach of Our legal obligations.


7. What Rights Do You Have Regarding Your
Personal Data?

In this situation, We are the data controller and You are the data subject. Being data subject, You have a set of rights given to You by the GDPR, which include the following:

  • To request access to Your personal data
  • To request correction of Your personal data
  • To request erasure of Your personal data
  • To object to processing of Your personal data
  • To request restriction of processing Your personal data
  • To request transfer of Your personal data
  • To withdraw consent

You also have the right to lodge a complaint with the Information Commissioner’s Office, which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.

If you wish to exercise any of these rights, please contact us at [email protected]

To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.


8. For How Long Do We Store Your Personal Data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

To obtain further information about how long we retain your personal data, please contact us at privacy.


9. Cookies

We use Cookies and similar tracking technologies to track the activity on our service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our service.


10. Marketing Permissions

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Email: You can change your mind at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at [email protected]

We use MailChimp as our marketing automation platform. MailChimp has its own privacy notice, which can be viewed here.


11. Third Party Links

Our Service may contain links to third party sites whose information practices may be different than ours. Please consult all third-party sites' privacy notices, as we have no control over information that is submitted to, or collected by, third parties.


12. Disclosures of Your Personal Data

Business Transactions. If we are involved in a merger, acquisition or asset sale, your personal data may be transformed. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Law enforcement. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements. We may disclose your personal data in the good faith belief that such action is necessary to:

  • Comply with legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with our service
  • Protect against legal liability.

13. Security of Your Personal Data

The security of your personal data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.


14. Changes to This Notice or Your Data

We may amend or modify this privacy notice from time to time. We will post any revised notice on this site and on our app, and if the changes are significant, we will notify you by email.

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.

Contact Us:

If you have any questions about this Privacy Policy, you can contact us using the email: [email protected]

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