The Thinking Luxury LTD | Trading as Carlo Rappa

 

1. LUXURY DISCRETION & PRIVACY

At The Thinking Luxury LTD, we understand that privacy is the cornerstone of a luxury lifestyle. This policy details how we manage your personal information with the absolute discretion and security required for high-net-worth travel and lifestyle management.

We comply strictly with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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2. DATA WE COLLECT FOR CONCIERGE SERVICES

To facilitate exclusive experiences and secure high-value assets, we must collect specific, sensitive data:

• Identity & Travel Data: Full names, passport copies, visa details, and dates of birth for all passengers in your party.

• Lifestyle Preferences: Dietary requirements, pillow menus, favorite brands, and specific medical or accessibility needs to ensure a bespoke experience.

• Financial Data: Secure processing of payment card details for asset charters and luxury bookings.

• Contact Data: Personal mobile numbers and secondary contact details for real-time coordination (e.g., via WhatsApp or encrypted messaging).

• Asset Details: Vehicle registration for estate entry or manifest details for private aviation and maritime charters.

 

3. THE LEGAL BASIS FOR PROCESSING

We process your data under the following legal grounds:

• Contractual Necessity: To secure the jet, villa, or yacht you have requested.

• Legal Obligation: To comply with international border control, "Know Your Customer" (KYC), and anti-money laundering (AML) protocols.

• Vital Interests: In rare cases, to protect your physical safety during travel (e.g., sharing medical alerts with a flight crew).

 

4. SHARING DATA WITH GLOBAL SUPPLIERS

As a Booking Agent, we must share your data with selected third-party Suppliers to fulfil your requests. This includes:

• Aviation & Maritime Operators: Sharing manifests with jet and yacht crews for safety and border compliance.

• Hospitality Partners: Providing guest details to Villa Managers and Hotel Concierges.

• Specialist Partners: Sharing requirements with Art Consultants, Real Estate Brokers, or Event Organsers.

• Note: We only share the minimum data required to execute the booking. We do not sell your personal preferences to marketing third parties.

 

5. INTERNATIONAL DATA TRANSFERS

Luxury travel frequently involves destinations outside the United Kingdom. Your data will be transferred to Suppliers in your destination country. While some countries may not have "adequacy" ratings identical to UK GDPR, we take all reasonable steps to ensure our global partners respect the confidentiality of our clients.

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6. DATA SECURITY & THE "PRIVATE OFFICE" STANDARD

Your data is stored within a secure, encrypted environment. Access is restricted to Carlo Rappa and essential personnel. We utilise enterprise-grade security to ensure that your travel movements and personal habits remain confidential.

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7. RETENTION & SURVIVAL

We retain your travel records only as long as necessary for tax and legal reporting. However, we may maintain a "Preference Profile" for you to ensure that your future bookings are seamless and tailored to your tastes, unless you request otherwise.

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8. YOUR RIGHTS

Under UK GDPR, you have the right to access, correct, or delete your data. You may also request that we restrict the processing of your lifestyle preferences. To exercise these rights, please email carlo@carlorappa.com.

 

Last update Dec 2024