1. Who we are and who controls your data
ELITE 360 LTD ("Elite 360", "we", "us" or "our") is the controller of personal information covered by this Privacy Policy unless we tell you otherwise. Our company number is 15047746 and our registered office is 168 City Road, Cardiff, Wales, CF24 3JE.
Privacy contact: info@elite360.uk
2. What this Policy covers
This Policy explains how we handle personal information when you visit our website, contact us, submit a membership application, create or use a member account, request concierge services, attend or enquire about experiences, receive marketing, or otherwise interact with Elite 360.
It should be read together with any just-in-time privacy notice we show when collecting information for a particular purpose, such as identity verification or a booking that requires sensitive information.
3. Personal information we may collect
3.1 Identity and contact information
• Name, title, date of birth, nationality and gender where relevant to the application or requested service.
• Email address, telephone number, postal address, city, region and postcode.
• Account identifiers, login information and communication preferences.
3.2 Membership and professional profile information
• Membership level, application status, membership history and service preferences.
• Occupation, company name, company website and professional profile information such as LinkedIn.
• Social media details, such as Instagram, where you choose to provide them.
• Information supplied during membership review, onboarding, relationship management or customer service.
3.3 Identity and travel document information
Where genuinely necessary for verification, travel, ticketing, accommodation or another requested service, we may collect passport number, passport expiry date, nationality, date of birth or other identification information. We do not ask for or retain more identity information than is reasonably necessary for the stated purpose.
3.4 Concierge, guest and booking information
• Requests, itineraries, reservation details, dates, destinations, preferences, guest names and booking history.
• Information about emergency contacts or other people you ask us to include in a booking or service.
• Accessibility, dietary, health or other sensitive requirements where relevant to a requested service.
3.5 Payment and transaction information
We may process billing address, transaction history, payment status, invoices, refunds and related financial records. Full payment-card details are normally processed by our payment provider rather than stored directly by Elite 360, unless we expressly tell you otherwise.
3.6 Website and technical information
• IP address, device type, browser, operating system, approximate location derived from technical data, log data and security events.
• Pages viewed, links used, interactions with forms or member areas and similar usage information.
• Cookie, tracking and consent information, subject to the choices available through our consent tools.
3.7 Communications
We keep records of relevant emails, messages, live chat conversations, telephone notes, requests, complaints and service communications where needed to manage the relationship, provide services, protect our legitimate interests or comply with legal obligations.
4. If you provide information about another person
If you give us personal information about a guest, family member, emergency contact, colleague or other person, you should only provide information you are entitled to share and, where appropriate, make them aware that Elite 360 will use their information for the relevant request. We may provide them with privacy information directly where required by law.
5. How we collect information
• Directly from you through forms, applications, member accounts, email, telephone, live chat or other communications.
• From people acting on your behalf, such as an assistant, family member or authorised representative.
• From third-party suppliers involved in your booking or request.
• From publicly available professional or corporate sources where reasonably relevant to membership review, relationship management, fraud prevention or verification.
• Automatically through our website and permitted cookies or similar technologies.
6. Why we use your information and our lawful bases
Purpose Typical information Typical lawful basis
Respond to enquiries and membership applications Identity, contact, professional profile, application information Steps at your request before a contract; legitimate interests in operating a selective membership service
Create and administer membership Identity, contact, account, membership and payment information Performance of a contract; legitimate interests in account administration
Deliver concierge requests and arrange bookings Contact, preferences, guest, booking, identity/travel details Performance of a contract; steps at your request
Take and reconcile payments Billing, transaction and payment status information Performance of a contract; legal obligations; legitimate interests in preventing fraud and managing debts
Security, fraud prevention and verification Identity, account, device, login and transaction information Legitimate interests; legal obligations where applicable
Customer service and complaints Account, booking and communication records Performance of a contract; legitimate interests in service quality and dispute management
Improve our website and services Usage, feedback and service interaction data Legitimate interests, where those interests are not overridden by your rights; consent where required for non-essential storage/access technologies
Send marketing and invitations Name, contact information, interests and engagement Consent where required by PECR; otherwise legitimate interests where legally permitted and appropriate
Meet legal, tax, accounting and regulatory duties Transactions, invoices, identity and communication records Legal obligation; legitimate interests in establishing or defending legal claims
7. Sensitive or special category information
A bespoke concierge request may sometimes involve information that is treated as special category personal data, for example health or accessibility information and, in some circumstances, dietary information that reveals religious or health information. We will only collect this where it is reasonably necessary for the request. Where the law requires an additional condition for processing, we will rely on explicit consent or another condition permitted by law and will limit access to people who need the information for the service.
You may withdraw consent where consent is the lawful basis. Withdrawal does not make earlier lawful processing unlawful, but it may mean that we cannot continue a service that genuinely requires the information.
8. Marketing communications
We may send service communications that are necessary to manage your application, account, membership or requests. These are not marketing communications.
We will send electronic direct marketing only where permitted by applicable privacy and electronic communications law. Where consent is required, we will ask for it. You can opt out of marketing at any time by using the unsubscribe method in the communication or contacting us. Opting out of marketing will not stop necessary service messages.
9. Cookies and similar technologies
Our website may use cookies, pixels, local storage, scripts and similar technologies. Technologies that are strictly necessary for security, authentication, member-area functionality or a service you request may be used without consent where the law permits. Non-essential analytics, advertising or similar technologies will only be used in accordance with the consent choices we make available to you.
You should be able to reject or manage non-essential technologies without losing access to core website functions. Our cookie banner and cookie settings should provide current details of the technologies in use, their purposes and duration. A separate Cookie Policy should be published if the live site uses non-essential analytics, advertising or third-party tracking technologies.
10. Who we may share information with
We share personal information only where reasonably necessary and subject to appropriate safeguards. Recipients may include:
• Website hosting, member-account and technology providers, including Wix where it provides the relevant website functionality.
• Payment processors, accounting providers and fraud-prevention services.
• Hotels, airlines, transport providers, venues, restaurants, event organisers, ticketing partners, experience providers and other suppliers needed to fulfil your request.
• Customer relationship management, communications, email, live chat and support providers.
• Identity or verification providers where verification is reasonably required.
• Professional advisers such as lawyers, accountants, insurers and auditors.
• Law enforcement, courts, regulators, tax authorities or other bodies where disclosure is required or permitted by law.
• A buyer, investor or successor organisation in connection with a genuine corporate transaction, subject to appropriate confidentiality and data protection safeguards.
When we share booking information with an independent supplier, that supplier may become a separate controller of the information it needs to provide its own service. Its privacy notice will then apply to that processing.
11. International transfers
Elite 360 is a UK business, but concierge requests and technology providers may involve organisations outside the United Kingdom. Where personal information is transferred to a country that is not covered by an applicable UK adequacy decision, we will use an appropriate safeguard where required, such as approved contractual protections, or rely on another lawful transfer mechanism.
For travel and international bookings, information may also need to be sent to suppliers in the destination country because the transfer is necessary to perform or arrange the service you requested.
12. How long we keep information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, security and dispute-resolution needs. We maintain retention rules appropriate to the type of information and the relationship.
• Active member and account records are generally kept for the duration of the relationship and then for an appropriate period where needed for legal, tax, contractual or dispute purposes.
• Transaction, invoice and accounting records may need to be retained for statutory accounting and tax periods.
• Unsuccessful or incomplete membership application information should not be retained indefinitely and should be deleted or anonymised after a defined review period unless there is a lawful reason to keep it.
• Passport numbers, copies or other high-risk identity information should be retained only for the period genuinely required for verification or the relevant booking, unless law or a documented operational need requires longer retention.
• Marketing suppression information may be retained so that we can respect a request not to receive marketing.
13. Security
We use technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. Measures may include access controls, authentication, secure hosting, encryption where appropriate, staff access restrictions, supplier due diligence, backups and monitoring.
No internet service can be guaranteed completely secure. If we become aware of a personal data breach, we will assess and handle it in accordance with applicable data protection law, including notification to affected people or the Information Commissioner where required.
14. Your data protection rights
Depending on the circumstances, UK data protection law may give you rights to:
• Ask for access to personal information we hold about you.
• Ask us to correct inaccurate or incomplete information.
• Ask us to delete information in certain circumstances.
• Ask us to restrict processing in certain circumstances.
• Object to processing based on legitimate interests, including an absolute right to object to direct marketing.
• Receive certain information you provided to us in a portable format where the right to data portability applies.
• Withdraw consent at any time where we rely on consent.
• Ask for safeguards in relation to certain solely automated decisions, where applicable.
To exercise a right, contact [INSERT PRIVACY EMAIL]. We may need to verify your identity before acting on a request. We will not charge a fee in most cases, although the law permits a fee or refusal in limited circumstances.
15. Automated decision-making
We may use systems to assist with administration, security, fraud detection, prioritisation or membership workflow. We do not intend to make decisions that produce legal or similarly significant effects about you solely by automated means unless we have a lawful basis and provide the information and safeguards required by law.
16. Children
Membership applications are intended for adults aged 18 or over. We do not knowingly invite children to create independent member accounts. A member may ask us to process limited information about a child where necessary for a family travel, accommodation, event or other legitimate booking. In that situation, we will only use the information for the relevant service and will expect instructions from an appropriate parent, guardian or authorised adult.
17. Complaints and the Information Commissioner
If you have a privacy concern, please contact us first at info@elite360.uk so that we can investigate it. You also have the right to complain to the UK Information Commissioner's Office (ICO).
ICO information and complaint routes: ico.org.uk
18. Changes to this Policy
We may update this Privacy Policy to reflect changes in our services, technology, suppliers, legal obligations or data practices. The current version will be published on the website with the date of the latest update. If a change materially affects how we use existing personal information, we will provide any additional notice required by law.
19. Contact us
ELITE 360 LTD
Company number 15047746
168 City Road, Sivapalan & Co
Cardiff, Wales, CF24 3JE
Email: info@elite360.uk