Privacy Policy

2. About Unlock Longevity

Unlock Longevity is responsible for processing your personal data and is legally composed of:

Unlock Longevity, with headquarters at Mej. N. Schipperstraat 37, 3262 GJ Oud-Beijerland.

Our IT department is based in the Netherlands.

3. What data does Unlock Longevity process?

Unlock Longevity processes the following types of personal data when you share it directly with us or when you use our services:

Identification, contact, and payment data: Unlock Longevity processes the identification and contact details you provide when registering for an account, an event, a promotional action, or subscribing to a service. The data we process in this context include, for example, your name, address, email address, phone number, date of birth, gender, and, if applicable, billing and payment information. During the registration process, it is indicated whether the requested information is mandatory or not. If the requested information is mandatory, you cannot complete the registration if you do not provide it, as we would otherwise be unable to deliver the services (under optimal conditions) to you.

Usage data: When you are logged in, we collect data about your use of our services, such as which TV programs you like to watch, which news articles you find interesting, which events you attend, or which magazines and news media you show interest in. When this involves data stored and retrieved on your device, we always consider your cookie settings. More information can be found in our cookie policy.

Preferences and interests: Based on your usage data (https://privacy.dpgmedia.be/document/cookiebeleid) and your identification details, we can infer your probable preferences and interests. For example, if you frequently read sports articles, you may be grouped into a “Sports Lovers” user group. This information is used to make some of our services as relevant and personalized as possible for you. If you choose to do so in your cookie settings, you may also see personalized advertisements based on this information.

Communication preferences: We also collect information about your preferences regarding our communication with you (via email, push notifications, mail, or phone). You communicate these preferences directly to us during registration or through your account settings, or indirectly via the Do-Not-Call list and Robinson List (see section 8 below).

Other information you share: We process information you provide when you ask a question via email or contact us (e.g., via telephone, our chatbox, or social media). We also process information obtained through market research (surveys/questionnaires) that you voluntarily participate in.

4. What are my data used for?

We process personal data for various purposes, always only processing the data necessary to achieve the intended goal. Personal data is used when necessary:

• In the context of preparing, executing, or terminating our contract with you (e.g., providing information, delivering products and services, invoicing, etc.);
• To comply with legal or regulatory obligations (e.g., tax laws, providing information to authorities for legal investigations, etc.); and/or
• To protect our legitimate interests, always balancing that interest with respecting your privacy (e.g., marketing and advertising for our services).

If processing your personal data is not necessary for any of these three reasons, we will always ask for your permission before doing so.

Specifically, we collect personal data for the following purposes:

• To process your request for our services: If you are not yet a customer and visit our website to gather information or request details about our products and services, we need your contact information at minimum. All information received about you during this pre-contractual phase is used solely to provide the requested information. If you decide to become a customer or use our services, you will need to provide certain personal data to manage our contractual relationship and create an account (see above). If you fill in your data on our website but do not complete the purchase process, we will send you a one-time reminder via email.

• To perform our contract with you and deliver our services: We use your data to provide our services and handle related administration. Provided contact details may be used to inform you about changes or to give you additional information about our services. These data are also used for billing and payment purposes.

• To improve our services and identify general trends: We may use aggregated usage information to identify areas for improvement. This includes feedback from you, data from our contact with you (e.g., written or phone conversations), your inquiries, or recordings of customer service calls. You may also be invited to participate voluntarily in surveys to help us evaluate and improve our services or develop new products.

• To offer personalized content: If you opt-in via your cookie settings, we can tailor our service content to make it more relevant based on your usage and personal data.

• To send you direct marketing about our services via email, SMS, and push notifications: Luxury Exclusive Resorts may use your contact details to communicate news, upcoming promotions, or new products that we think may interest you. We can also use your data to send personalized marketing aligned with your interests, respecting your preferences as set in your profile.

• To display targeted advertisements on Google and Facebook: We may share your email address in pseudonymized form with online marketing companies like Google and Facebook. If you are registered and your ad settings permit, they may show you tailored ads via their platforms.

• To show targeted ads on our own websites and apps: If you opt-in for targeted advertising in your cookie settings, we can use information provided during account creation to make ads more relevant. Names are never used; only your location, gender, hashed email address, and age are linked to your browsing behavior. Advertisers with your email address can share hashed data with us to reach you with their ads on our platforms. For more information, see our cookie policy; you can adjust your cookie settings via the link at the bottom of each website.

• To prevent or detect abuse or fraud: We may use your data to prevent, detect, or investigate illegal activities, such as payment fraud, and to enforce our Terms of Use.

• To comply with laws and regulations: We may use your data to meet legal obligations and conduct audits. Personal information may be disclosed in legal disputes, requests from authorities (e.g., police, courts, emergency services), or in compliance with statutory requirements. We may do so without informing you or obtaining your consent. We are also legally required to retain certain data for fiscal and accounting purposes.

• To conduct studies, tests, and statistics: We may use anonymized, aggregated data internally or externally to report on service usage. These analyses cannot be linked to individual persons and help us evaluate and adapt our services and processes based on new developments.

5. Does Unlock Longevity engage in automated individual decision-making?

No. European data protection law (GDPR/AVG) sets strict conditions for decisions based solely on automated processing, including profiling, that have legal or significant effects on individuals. Examples include automatic rejection of online credit applications or processing job applications without human intervention. Unlock Longevity does not engage in such decisions.

6. To whom can my personal data be disclosed?

We do not sell your personal data to third parties, nor do we allow third parties to use your data for their own purposes without your consent. Your data are only shared with the following parties:

• Suppliers, subcontractors, and service providers: We use third-party companies to perform services on our behalf, such as marketing, communication, infrastructure, IT services, payment processing, fraud prevention, customer service, debt collection, data analysis, and feedback management. These providers may access personal data as needed but are contractually obliged to handle it confidentially and securely.

• Commercial partners: If you participate in a contest or promotion, your data may be shared with the partner responsible for that activity, as specified in the contest disclaimer. We do not sell personal data to third parties.

• Authorities: We may share personal data, including communications, to comply with legal obligations or legal procedures, detect or prevent fraud and security issues, or protect our rights and property.

• Social media platforms: Our websites and apps allow registration and login via Facebook or Google, and sharing content on social media. When you use these features, certain data are shared with the platforms, subject to their privacy policies. Your contact details may also be shared with these companies to display personalized ads for our services on their platforms.

• Business transfers: Unlock Longevity reserves the right to transfer data, including personal data, in case of reorganizations, restructuring, mergers, sales, or other asset transfers, provided the recipient agrees to process your data according to our privacy policy.

When these parties process data outside the European Economic Area (EEA), we ensure your data remains protected as required under European law, either through standard contractual clauses or if the country is recognized by the European Commission as providing adequate data protection.

7. How long are my personal data retained?

We do not keep your data longer than necessary for the purpose they were collected, considering legal retention obligations.

In practice, all data types listed above are retained as long as you are a customer or have an account with us. If you cease to be an active customer or stop using your account, we retain your personal data for an additional 2 years in case you return or become a customer again. During this period, your data may also be used for direct marketing, e.g., to send renewal offers unless you previously opted out.

After this 2-year period, your account is closed, and linked data are deleted. Only if you had a paid customer relationship with us will we archive your identification, contact, and payment data for up to 10 years after your last payment, to support legal claims.

8. What are my rights and how can I exercise them?

Data protection rights are fundamental in the European Union. You should always retain control over your personal data. Here are your rights and how to exercise them with Unlock Longevity:

• Right of access: You can request confirmation from us whether we process your data, access your personal data, understand how and why they are processed, and obtain a copy.

• Right to rectification: You can request correction of incorrect data. You can update your identification, contact, or payment details yourself via your account.

• Right to erasure: You can request deletion of your data. This is not absolute and may not always apply. You can exercise this right via this link.

• Right to restriction: In certain cases, you can request to limit the processing of your data by emailing info@unlocklongevity.eu with the subject “privacy.”

• Right to data portability: You can request the data you provided based on your consent or necessary for a contract, in a machine-readable format, by emailing info@unlocklongevity.eu.

• Right to object: You can object to the processing of your data based on our legitimate interests, including profiling, by emailing info@unlocklongevity.eu.

• Right to object to direct marketing: This right is absolute—you can always opt out. You can do this during data sharing, through your account settings, or via the unsubscribe link in messages. For other channels, send an email to info@unlocklongevity.eu.

• Right to withdraw consent: If you previously consented to data processing, you can withdraw this consent at any time via your account settings or the relevant communication.

• Right to lodge a complaint: You can file a complaint with the Dutch Data Protection Authority at:

Authority for Personal Data (Autoriteit Persoonsgegevens)
Hoge Nieuwstraat 8
2514 EL The Hague

For more information, visit their website: www.autoriteitpersoonsgegevens.nl.

9. Changes to this Privacy Policy

We may update this Privacy Policy occasionally, for example, due to changes in our services. When we do, we will update the “last updated” date at the top of the document and specify what has changed. For significant changes affecting how we handle your data, we will inform you before they come into effect via a notice on our website.

10. Do you have any questions?

If you have questions about this Privacy Policy, you can contact our Data Protection Officer via:

• Email: info@unlocklongevity.eu
• Postal mail: Unlock Longevity, attent: Data Protection Officer, Mej. N. Schipperstraat 37, 3262 GJ Oud-Beijerland