Privacy Policy

1. Introduction

[TBC: company legal name] ("we", "our", "us") is committed to protecting your privacy. This statement explains how we collect, use and safeguard your personal data in accordance with UK data protection law, including the UK GDPR and the Data Protection Act 2018 as amended.

2. Information we collect

Contact details (name, email address, phone number). The information you provide in our fact-find questionnaire, including your property preferences, budget, citizenship and residency status, and lifestyle requirements. Technical data such as your browser type and the pages you visit. Where we need to prevent automated abuse of our forms we process your IP address briefly and do not store it.

3. How and why we use your data

We use your data to respond to your enquiry and arrange a consultation; to identify properties and services that may suit your requirements; to comply with our legal obligations; and, where you have agreed, to send you occasional updates. Our lawful bases are your consent, and our legitimate interest in responding to enquiries about our services.

4. Sharing your data, security and international transfers

We do not sell your data. We share it with our partner Briggs & Co Retirement Consultancy in the Philippines, and with trusted partner developers, agents and legal professionals, only where necessary to progress your enquiry. We also use trusted service providers for hosting and email. We apply appropriate technical and organisational measures to protect your data against accidental loss, unauthorised access, alteration or disclosure.

[TBC: legal to confirm the transfer mechanism and wording] — draft: The Philippines is outside the UK. Where we transfer your data there we rely on [TBC: the International Data Transfer Agreement (IDTA) OR the UK Addendum to the EU Standard Contractual Clauses], supported by a transfer risk assessment. You may request details of the safeguards we use.

5. Data retention

We keep your personal data only as long as necessary for the purposes we collected it for, including any legal or reporting requirements. Fact-find records are retained for [TBC: retention period] after our last contact with you, after which they are deleted.

6. Your legal rights

Under the UK GDPR you have the right to request access to your personal data; to request correction or erasure; to object to or restrict processing; to data portability; and to withdraw your consent at any time.

7. Contact us

To exercise your rights or ask questions, contact us at info@contrastlifestyle.co.uk. If you are unhappy with how we handle your data, you have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.

8. Philippine Data Privacy Act

In compliance with Republic Act 10173 (the Data Privacy Act of 2012), personal information handled by our Philippine partner is kept strictly confidential and used solely for the purpose of matching you with relevant property listings and progressing your enquiry.