Privacy Policy

Updated as of May 2, 2023
Effective Date: May 2, 2023


Castle Creek Properties, Inc. (“Rosenthal Estates”, “Rosenthal – The Malibu Estate”, “us”, “we” or “our”) created this privacy policy (“Privacy Policy”) to advise you about Rosenthal Estates’ information practices, such as the types of information we collect and how we may use that information, and to inform you about your privacy rights. We urge you to read this Privacy Policy carefully. Please also review our Terms of Use, which govern your use of the Site (as defined below) and your interactions with us offline.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

California residents and data subjects in the European Union (“EU”) should be sure to read the important information provided here (California residents) and here (EU residents) in addition to the other provisions in this Privacy Policy.
















This Privacy Policy applies to all information collected or submitted to Rosenthal Estates offline or via our website at or other online services that are owned or controlled by Rosenthal Estates and that post a link to this Privacy Policy (collectively, the “Site”). Note, however, this Privacy Policy does not apply to your use of unaffiliated websites that link to our Site. Once you enter another website (whether through an advertisement, service, or content link), be aware that we are not responsible for the privacy practices of such other websites.


This Privacy Policy aims to give you information on how Rosenthal Estates collects and uses your information through your use of the Site, including any information you may provide through the Site when you view our content, create an account, sign up to be a wine club member, or contact customer service.


The Site is not intended for children and we do not knowingly collect information relating to children. If Rosenthal Estates discovers that it has inadvertently collected personal information from anyone younger than the age of 13, it will delete that information. Furthermore, we do not knowingly “sell” the personal information of children under 16 years old who are California residents without their affirmative authorization.

In addition, the website and any features or online services associated with Rosenthal – The Malibu Estate, are not intended for persons under twenty-one (21) years old. We do not knowingly collect personal information from anyone younger than the age of 21 in connection with such Site, features, or online services.


We reserve the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Site. Any such change, update or modification will be effective immediately upon posting on the Site.

It is important that the information we hold about you is accurate and current. Please keep us informed if your information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.


The Site may include links to other parties’ websites, plug-ins and applications and certain content on the Site may be hosted and served by other parties that Rosenthal Estates does not control. Clicking on those links or enabling those connections may allow other parties to collect or disclose information about you. We do not control these other party’s websites and are not responsible for their privacy statements. When you leave the Site, we encourage you to read the privacy policy of every website you visit.

In addition, Rosenthal Estates content may be included on web pages and websites that are not associated with Rosenthal Estates and over which we have no control. These other parties may collect data through the use of their own cookies, web beacons or other technology, independently collect information or solicit information, and may have the ability to track your use of their websites and services. Rosenthal Estates is not responsible for the privacy practices or the content of any other party.


We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you when you visit our Site or interact with us offline. The following are the categories of information we collect and have collected, including in last 12 months:

  •  Contact Information includes name, billing address, email address, shipping and delivery address, and telephone numbers.
  •  Demographic Information includes zip code, gender, age and/or income.
  •  Financial Information includes bank account and payment card details.
  •  Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology or other unique identifier which is a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet (“Device Identifier”) for any computer, mobile phone, tablet or other device (“Device”) used to access the Site.
  •  Profile Information includes your username and password, date of birth, details about the products you purchase and order, the events you are interested in and attend, wine preferences, feedback, and survey responses.
  •  Usage Data includes information about how you use our website, products and services, including all of the areas within our Site that you visit or use, and the time of day you visited the Site, among other information.
  •  Marketing and Communications Information includes your preferences in receiving marketing from us and other companies and your communication preferences.
  •  Location Information includes non-precise information about your location using a variety of technologies, such as IP address, and connected or nearby Wi-Fi networks.
  •  Job Applicant Data includes your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
  •  Content includes content within any messages you send to us (such as feedback and questions to customer support).

We also collect, use and disclose aggregated information for any purpose. If we combine or connect aggregated information with your information, we treat the combined information in accordance with this Privacy Policy.


We use different methods to collect information from and about you when you access our Site, interact with us online, or interact with us offline, including through:

Direct interactions. You may give us your Demographic, Contact, Financial, Profile, or Marketing and Communications Information by filling in forms, by corresponding with us by mail, phone, or email, by accessing our Site, or by otherwise interacting with us offline. This includes information you provide when you:

  •  purchase our products or services;
  •  create or use an account on our Site;
  •  subscribe to our newsletters or publications;
  •  request marketing to be sent to you;
  •  attend an event at our Malibu location;
  •  give us feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical, Usage, and Location Information about your equipment, browsing actions and patterns. We collect this information by using cookies, web beacons, embedded scripts and other similar technologies.

  •  Cookies – Cookies are data files sent to and stored on the Device you use to view a website. Cookies can be used for many purposes, including to monitor use of our Site, to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly and to store your username and password so you do not have to re-enter it each time you visit the Site. If you choose to disable cookies on your Device, some features of the Site or our content may not function properly.
  •  Web Beacons – Web Beacons are small graphic images or other web programming code (also known as “1×1 GIFs” or “clear GIFs”) that may be included on the Site and in our e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
  •  Embedded Scripts – Embedded scripts are programming code designed to collect information about your interactions with the Site, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a service provider, is active only while you are connected to the Site.

Other sources. We may receive information about you from other sources. For example, if you are on another website and you opt-in to receive information from us, the other website will forward your contact and other information to us so that we may contact you as requested. We also supplement the information we collect with outside records from other sources in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information. The following are the categories of sources we collect and have collected information from, including in the last 12 months:

  •  analytics advertising and marketing providers;
  •  business partners such as delivery services;
  •  social networks; and
  •  publicly availably sources.


Certain functionality on the Site integrates technology, links, websites, platforms and services owned or operated by other parties. If you post information on a social networking platform that references the Site (e.g., by mentioning Rosenthal Estates or using a hashtag associated with our Site in a tweet or status update), your post may be published on our Site. In addition, both Rosenthal Estates and the other party may have access to certain information about you and your use of the Site and the other site or service. The information we collect is subject to this Privacy Policy. The information collected and stored by the other party remains subject to their privacy practices.


Rosenthal Estates works with certain other parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Site, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. For example, if you clicked on one of our advertisements that led you to the Site, our vendor(s) or other parties may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These other parties may set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. Cookies and web beacons, including those set by network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics. We may disclose Device Identifier and Usage Data about visitors to advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of other parties to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA“) Self-Regulatory Program for Online Behavioral Advertising.

For additional information regarding targeted advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:

Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Site and elsewhere online. Some other parties may collect information about your online activities over time and across different websites.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, unless and until the law is interpreted to require us to do so, the Site currently does not alter its practices when a “Do Not Track” signal from a visitor’s browser is received. To find out more about “Do Not Track,” you may wish to visit However, please note that if you are a California resident, you may exercise your right to opt-out of sales or sharing through preference signals. Please see the “Additional Disclosures for California Residents” section below for more information.


We use the information we collect for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include:

  •  to provide you with our Site, products and services and respond to your customer service requests;
  •  to send you information about Rosenthal Estates or our wines, products or services, events or promotional material from some of our advertisers or business partners,
  •  to process a transaction you initiate and deliver products to you;
  •  to provide you with information, products or services that you have requested or agreed to receive;
  •  to process your registration with the Site, including verifying your Contact Information is active and valid;
  •  to customize and tailor your experience on the Site, for example, by displaying content that we think you might be interested in;
  •  to bill you for products you order;
  •  to send you offers or information on behalf of our business partners or affiliates;
  •  to improve the Site, our products and services;
  •  for compliance fraud prevention and safety, including enforcing our terms of service and this Privacy Policy, protecting our rights privacy, safety, or property and/or that of you or others, and protecting against, investigating or deterring fraudulent, harmful, unauthorized, unethical or illegal activity;
  •  comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  •  to develop and send you direct marketing, including advertisements and communications about our and other entities’ products, offers, Promotions, rewards, events and services;
  •  to provide you with information about our loyalty program;
  •  contact you with regard to your use of the Site and, in our discretion, changes to the Site policies or functionality; and
  •  for other commercial or business purposes at your direction or with your consent or notice.


We may disclose non-personally identifiable information, such as aggregated information, in our discretion and without restriction.
We may disclose the information we have collected about you, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy. We also disclose and have disclosed information, including in the last 12 months, to the following parties:


Rosenthal Estates or the Rosenthal – The Malibu Estate discloses information to its parent, affiliates and related entities (including, without limitation, Raleigh Enterprises, Hollywood Rentals, Raleigh Creative, File Keepers, the Cavatina at Sunset Marquis Hotel, Raleigh Studios, and Sunset Marquis) for a variety of purposes, including for business, operational, commercial and marketing purposes. Rosenthal Estates may, and reserves the right to, disclose your information to any other company that is not presently, but becomes, a Rosenthal Estates parent, subsidiary, or affiliate.


Service Providers

We disclose information to service providers in connection with their performance of services to, or on behalf of, the Site. For example, we use a service provider to accept orders for wine. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us. However, these service providers may store or use your information outside of the EU or United States.

Partners or At Your Request or Direction

You may be presented with an opportunity to receive information and/or marketing offers from one or more of our partners or that we disclose your information to another party. If you agree at that time to have your information disclosed, your information will be disclosed to that party (or parties) and will be subject to the privacy policy and practices of that party. We are not responsible for the privacy policies and practices of other parties, and, if you later decide that you no longer want to receive communications from another party or otherwise do business with another party, you will need to contact that party directly. You also may request, sometimes through your use of another party’s interactive feature or application, that we disclose information about you to that party and we will typically do so under those circumstances. We also disclose information to partners for joint marketing and co-branded emails and advertising.

Administrative & Legal Reasons

We may transfer and disclose information, to other parties to:

  •  comply with a valid legal inquiry or process such as a search warrant, subpoena, statute or court order, or if in our opinion such disclosure is required by law;
  •  protect the safety, interests, rights, property or security of Rosenthal Estates, you, or any person or party;
  •  respond to a breach or attempted breach of the security of our Site;
  •  defend or assert our legal rights pursuant to the Site’s Terms of Use, any policies applicable to the Site, or any other agreement you may have with Rosenthal Estates; or
  •  at the request of governmental authorities conducting an investigation.

We may also use information to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies in our discretion. Rosenthal Estates may also disclose and transfer your information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database, or of our products or services; (ii) if Rosenthal Estates (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to another party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Rosenthal Estates’ ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.


We disclose information to vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics Providers & Ad Servers; Online Tracking” section above.

Sweepstakes, Contests & Promotions

We may offer sweepstakes, contests, and other promotions (any, a “Promotion“) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your information may be disclosed to other parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.


Rosenthal Estates may also disclose and transfer your information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database, or of our products or services; (ii) if Rosenthal Estates (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to another party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Rosenthal Estates’ ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.

We do not allow our service providers to retain, use, or disclose your information for their own purposes and only permit them to use your information for specified purposes and in accordance with our instructions.



You may review, update, correct or delete the information in your profile by logging into your website account. You may contact us at if you have questions about making such changes to your account.

You are responsible for maintaining the accuracy of the information you submit to us, such as your Contact Information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


You can ask us to stop sending you marketing emails at any time by following the opt-out links on any marketing emails sent to you. Alternatively you may contact us at

Where you opt out of receiving these marketing emails, this will not apply to information provided to us as a result of the purchase of a product or service or other transactions.


You may opt-out of receiving text messages (e.g., SMS or MMS messages) that we may offer by replying “STOP” to one of our messages or by contacting us at Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions.


Rosenthal Estates takes commercially reasonable security measures to help protect your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your information to those employees, agents, and contractors who have a business need to know. However, please note that transmission over the Internet or wireless networks cannot be guaranteed to be 100% secure; and therefore we cannot ensure or warrant the security of any information we collect. You use our Site and provide us with your information at your own risk.

We have put in place procedures to deal with any suspected information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


The Site is operated in the United States, and Rosenthal Estates and our service providers, partners and vendors operate in the United States and other jurisdictions. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States and other countries. By using the Site, or providing us with any information, you consent to this transfer, processing and storage of your information in countries where the privacy laws may not be as comprehensive as those in the country where you reside or are located.


If you have any questions or concerns regarding our privacy policy or practices, please feel free to contact us via email at

We can also be contacted by mail at:
Attention: Privacy Policy
5300 Melrose Avenue – 4th Fl. West Office Bldg.
Hollywood, CA 90038

If you have a disability and would like to access this Privacy Policy in an alternative format, please email us at


These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act, as replaced by the California Privacy Rights Act, (collectively, the “CPRA”) provides additional rights to know, correct, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise such rights.

A. Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CPRA:

  •  Identifiers, including name, address, email address, account name, IP address – and an ID number assigned to your account.
  •  Customer records, phone number, billing and delivery address, and credit or debit card information.
  •  Demographic information, such as your age or gender. This category includes pieces of personal information that also qualify as a protected classification characteristics under other pre-existing California or federal laws.
  •  Commercial information, including purchases and engagement with the Services.
  •  Internet activity, including history of visiting and interacting with our Service, browser type, browser language and other information collected automatically.
  •  Non-precise geolocation data, including location enabled services such as WiFi and IP address.
  •  Employment and education data, including information you provide when you apply for a job with us.
  •  Inferences, including information about your interests, preferences and favorites.

For more information on what we collect, including the sources we receive information from, review The “Information We Collect About You” section. We collect and use these categories of personal information for the business purposes described in the “How We Use Your Information” section, including to provide and manage our Site.

Rosenthal Estates does not generally sell information as the term “sell” is traditionally understood. However, some of our disclosures of personal information described herein may be considered a “sale” or “share” as those terms are defined under the CPRA. A “sale” is broadly defined under the CPRA to include a disclosure in exchange for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising.. Rosenthal Estates collects, sells or discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. In addition, we use and partner with different types of entities to assist with our daily operations and manage our Site. Please review the “Disclosures of Your Information” section for more detail about the parties we have disclosed information to. For details about your rights regarding sales and sharing, please see the “Right to Opt-Out” section below.

We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.

To the extent any of the personal information we collect is sensitive personal information, we collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA. We do not sell or share sensitive personal information, as those terms are defined by the CPRA.


We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.


If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

In addition, you have the right to correct or delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our online form available here, call our toll free number at 1 (844) 689-9558. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know, correct, or delete. Please note, these rights may be subject to certain exceptions.


To the extent Rosenthal Estates sells or shares your personal information as the terms “sell” or “share” are defined under the CPRA, you have the right to opt-out of the sale and/or sharing of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell or Share My Personal Information, or by turning on a recognized opt-out preference signal, such as the Global Privacy Control, in your browser or extension..

When you submit an opt-out except as provided below, your opt-out will only apply to sales and sharing from the specific browser from which you sent the signal because the connection between your browser identifier and other personal information we have about you is not known to us.


You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods above. Except for opt-out requests, will require written proof of the agent’s permission to do so and may verify your identity directly.


You have the right not to receive discriminatory treatment by us for the exercise of any your rights.


Pursuant to California Civil Code Section 1798.83, customers who are residents of the State of California have the right to request from companies conducting business in California certain information regarding Rosenthal Estates’ disclosure within the immediately preceding calendar year of that California resident’s categories of personal information to third parties (and in some cases, affiliates) for their direct marketing purposes and the categories of third parties to whom such personal information was disclosed.

If you are a California resident and you have questions about our practices with respect to disclosing information to third parties and affiliates for their direct marketing purposes, please send your request to the following email address:, or write to us at the following mailing address: Rosenthal Estates, 5300 Melrose Avenue – 4th Fl. West Office Bldg., Hollywood, CA 90038. You must put the statement “California Shine the Light Request” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information. We may also require additional information from you to allow us to verify your identity, and we are only required to respond to requests once during any calendar year.



References to “information” or “data” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.


We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  •  Where we need to perform obligations relating to a contract to which you are a party or to take steps at your request before entering into such a contract.
  •  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include those related to conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  •  Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided above.


This Privacy Policy is issued on behalf of Rosenthal Estates as a controller with respect to personal data collected as you interact with our Site, emails, and advertisements.


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.

In some circumstances, you can ask us to delete your data: see “EU Data Subject Rights” section below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Under certain circumstances, data subjects in the EU may have rights under data protection laws in relation to your personal data as outlined below:

  •  Request access to your personal 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.
  •  Request correction of the personal data that we hold about you. 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.
  •  Request erasure of your personal data. 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
  •  Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it affects 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 that override your rights and freedoms.
  •  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  •  Request the transfer of your personal data to you or to a third party. 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  •  Withdraw 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.

If you wish to exercise any of the rights set out above, please complete this form.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints to Supervisory Authority

EU data subjects may have the right to make a complaint at any time to the supervisory authority for data protection issues. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority so please first contact us directly to allow us to do so.