Cookies Policy

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 our Cookies Policy below. 

WHAT ARE YOUR RIGHTS?

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, namely: 

• to access your 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.; 
• to have your data rectified if it is inaccurate or incomplete - 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; 
• in certain circumstances, to have your data deleted or removed – 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. Please 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; 
• in certain circumstances, to restrict the processing of your data – this enables you to ask us to suspend the processing of your personal data in the following scenarios: 
  • if you want us to establish the data's accuracy; 
  • where our use of the data is unlawful but you don’t want us to erase it; 
  • 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; 
  • you have objected to our use of your data (see below) but we need to verify whether we have overriding legitimate grounds to use it; 
• a right of data portability, namely to obtain and reuse your data for your own purposes across different services. 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 information which you initially provided consent for us to use or where we used the information to perform a contract with you; 
• to object to the processing of your 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; 
• not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you;  
• the right to withdraw your 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 and 
• to claim compensation for damages caused by a breach of the Data Protection Laws. 

If you wish to exercise any of these rights, please contact [email protected], or Highland Park representative with whom you normally deal. 

WHO DO WE SHARE YOUR PERSONAL DATA WITH? 

To effectively fulfil our obligations to you, and to provide you with marketing and certain experiences, special invitations and benefits, we use a number of trusted and reliable third parties to carry out functions which involve the processing of your personal data. These include:. 

• vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management vendors marketing service providers, and other cloud-based solutions providers that are used by Highland Park in the conduct of its business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing; 
• vendors that process your personal data in order to assist us to better understand our consumers and how we can improve our consumer engagement, such as HubSpot and Salted Stone; 
• marketing service providers that administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run; and 
• translation service providers that administer services on our behalf, such as translating communications received and sent in different languages; 
• other agencies and fulfilment partners to administer events, competitions. experiences, brand programmes and other special invitations and benefits. 
• where you have given your specified consent, we will share your personal details with our airport retailer operations
• our professional advisors (e.g. lawyers, accountants and bankers); 
• other entities in Highland Park group of companies; and 
• Highland Park's third party distributors, joint venture partners, or airport retailers. 

We may provide information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our Terms and Conditions; (ii) comply with any legal claims raised against Highland Park; (iii) protect the rights, property or safety of Highland Park; or (iv) protect the rights, property or safety of the public. 

If Highland Park becomes involved in a merger, acquisition, bankruptcy, or other transaction involving the sale of some or all of our business or assets, user information, including personal data collected from you through your use of our website, could be included in the transferred business or assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on our website.  

WHERE WE STORE YOUR PERSONAL DATA

We may transfer your personal data outside the United Kingdom and/or EEA. This is primarily to allow us to: 

• receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located in non-UK/EEA jurisdictions, such as the US, South Africa and Australia; and 
• provide special invitations, products, services, experiences and other benefits to you, from other Highland Park group companies, or selected third party distributors, joint venture partners, or airport boutique operators.  

Where your personal data is transferred outside of the UK and/or EEA, we will ensure your personal data is afforded an adequate level of data protections (as required by data protection laws), including: 

• by transferring the data to a country that the UK authorities or European Commission have deemed as providing an adequate level of data protection (an "adequacy decision"); 
• by implementing an appropriate international transfer mechanism under data protection law, such as standard contractual clauses approved for this purpose by the UK authorities or European Commission; 
• by relying on a "transfer derogation" under data protection law (e.g. where the transfer is based on your explicit consent, or is necessary to perform a contract with you); or 
• where we are otherwise permitted to make the transfer under data protection law. 

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA. 

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will not retain your personal data for longer than necessary for the purposes set out in this Privacy Policy, including for the purposes of maintaining our relationship with you as well as 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 of our relationship with you.  

Different retention periods will apply to different types of data. To determine the appropriate retention period for personal data, we consider any ongoing relationship we have with you, the likelihood you may want to make a further purchase from us in the future, 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.  

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to). 

In certain circumstances, you can ask us to delete or remove your data (see the section entitled "What rights do you have?" above for further information on your rights). 

We may also use your personal data collected by recording phone calls for the following purposes: 

1. Account management; 
2. Prevention, detection, investigation and prosecution of fraud; 
3. Complaint handling and resolution; 
4. Measuring the quality of the call; 
5. Internal training on call handling.

We have a legitimate interest in retaining calls in order to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded. You will have the option to contact us through alternative means. All calls will be retained for a period of one year. 

HOW DO WE PROTECT YOUR PERSONAL DATA? 

Highland Park is committed to keeping your personal data safe and secure. To prevent unauthorised access, maintain data accuracy and ensure the correct usage of personal data, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal data we collect online. 

QUESTIONS

If you have any questions or concerns about the way in which your Personal Data is processed, please contact [email protected]. 

COMPLAINTS

You have the right to complain about data protection matters to the Information Commissioner’s Office (ICO).    

The ICO is the UK's independent body set up to uphold information rights. You can find out more about the ICO on its website (https://ico.org.uk/). The ICO can be contacted by calling 0303 123 1113.  

You can also lodge a complaint with a data protection regulator in the EEA member state in which you are based.  

We would however appreciate the chance to discuss and work with you to address your concerns before you approach the ICO or another regulator, so please contact us in the first instance.  

CHANGES

Highland Park may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given below and Highland Park encourages you to review this Privacy Policy periodically so you remain informed of how we uses your personal data. 

APPENDIX:

NOTE FOR US CONSUMERS

If you are based in the US, you may know that, while there is not a federal data privacy law framework, some states have passed data privacy laws.  

• California - CCPA (California Consumer Privacy Act) & CPRA California Privacy Rights Act 
• Colorado – CPA (The Colorado Privacy Act) 
• Nevada – Consumer Opt-Out Privacy Law (SB 220) 
• Virginia - Virginia Consumer Data Protection Act (VCDPA) 

In these states, covered organisations are required to provide transparent information to consumers/data subjects about how their personal data is managed, protected and how consumers can exercise rights in relation to their data.  

These requirements are covered in this Privacy Notice but, if you have any additional questions relating to your data, please contact us at;

[email protected] 

The most established of the US state privacy laws is the CCPA/CPRA and additional information is provided for Californian consumers in the table at the end of this appendix. 

ADDITIONAL INFORMATION 

• We do not sell personal data 
• You will not be discriminated against should you choose to exercise consumer rights related to your personal data, applicable in your state 
• This Privacy Notice is reviewed annually 

CALIFORNIA PRIVACY LAW - TABLE 

This table provides additional information to residents of California and supplements the information provided in the Privacy Policy. 

To learn more about the categories of personal data we collect, how we collect it, why it is collected, with whom we share the information, and how long we retain it, please see the chart below.

Last Updated: 24 February 2022

COOKIES POLICY

WHAT IS A COOKIE?

A cookie is a small file of letters and numbers that we store on your browser of the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. A cookie will usually contain the name of the domain it originated from, the “lifespan” of the cookie and a unique identifier (usually a randomly generated number).

WHAT TYPE OF COOKIES DO WE USE?

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below: