Privacy Policy
1. Introduction
This privacy notice provides you with details of how we collect and process your personal data through your use of our site, www.ResidenceBarbados.com.
By providing us with your data, you warrant to us that you are over 13 years of age.
Michael Ashton is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details
Our full details are:
Full name of legal entity: Michael Ashton trading as Residence Barbados
Email address: mike.ashton@residencebarbados.com
Postal address: 26-27 Newton Terrace, Christ Church, Barbados, WI Telephone number: +1 246 230 4982
Details of our UK Representative: Emily Collins, EVC Marketing, United Kingdom Email: emilyc@evcmarketing.com
Details of our EU Representative: Emily Collins, EVC Marketing, United Kingdom
Email: emilyc@evcmarketing.com
It is very important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time by emailing us at mike.ashton@residencebarbados.com.
2. What Data Do We Collect About You, For What Purpose And On What Ground We Process It
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data (Recognised Legitimate Interests) This includes any communication you send us, whether through the contact form on our website, email, text, social media messaging, social media posting, or any other communication. We process this data for the purposes of communicating with you, for record-keeping, and for the establishment, pursuit, or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data (Recognised Legitimate Interests) This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, and purchase details. We do not collect or store your card details. All card payments are processed directly by our third-party payment provider, who handles and stores this information under their own security standards. We process the data we do hold to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data (Recognised Legitimate Interests) This includes data about how you use our website and any online services, as well as any data you post for publication on our website or through other online services. We process this data to operate our website, provide relevant content to you, ensure the security of our website, maintain backups of our website and/or databases, and enable the publication and administration of our website, other online services, and our business. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business.
Technical Data (Recognised Legitimate Interests) This includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to properly administer our website and business, grow our business, and decide our marketing strategy.
Marketing Data (Recognised Legitimate Interests) This includes data about your preferences for receiving marketing communications from us and our third parties, as well as your communication preferences. We process this data to enable you to participate in our promotions, such as competitions, prize draws, and free giveaways; to deliver relevant website content and advertisements to you; and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is either consent, contract or our legitimate interests, which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests, which is to grow our business. We may also use such data to send you other marketing communications. Our lawful ground for this processing is either consent or legitimate interests (namely, to grow our business or for direct marketing).
We may also use Communications Data, Customer Data, User Data, Technical Data and Marketing Data for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which, in this case, are to establish, pursue, or defend legal claims.
We process this data to grow our business and provide a complete customer service. Our lawful ground of processing is Recognised Legitimate Interests.
Required Processing Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do, we will notify you at the time.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Purposes of Processing We will only use your personal data for the purpose it was collected for, or a reasonably compatible purpose if necessary. For more information on this, please email us at mike.ashton@residencebarbados.com. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.
Sensitive Data and Criminal Conviction Data We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data.
We do not collect any information about criminal convictions and offences.
Automated Decision-Making We do not carry out any automated decision-making or automated profiling of any kind. Every decision that affects you, whether about eligibility for our services or anything else, is made by a person.
3. How We Collect Your Personal Data
We may collect data about you when you provide it directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our Cookie Policy for more details about this.
We may receive data from third parties such as analytics providers such as Google, based outside of Barbados, advertising networks such as Facebook, based outside of Barbados, search information providers such as Google, based outside of Barbados, and providers of technical, payment and delivery services.
We may also receive data from publicly available sources, such as company registries and public records.
4. Marketing Communications
Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely, to grow our business).
Under the Privacy and Electronic Communications Regulations (PECR), where they apply to you, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
We will never share your personal details with any third party for their own marketing purposes.
You can ask third parties or us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing us at mike.ashton@residencebarbados.com at any time.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.
5. Disclosures Of Your Personal Data
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services and marketing services.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- Fraud prevention and anti-money laundering agencies.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Michael Ashton trading as Residence Barbados is based in Barbados. Many of our customers are based in the UK, the EU, the US and Canada. This means that when you use our website or services, your personal data is transferred from your country to Barbados, and may also be transferred on from Barbados to service providers we use in other countries, such as analytics and advertising providers based in the US.
This processing is subject to the Barbados Data Protection Act, 2019-29, which places its own conditions on transferring personal data outside of Barbados. Where we transfer your data to a service provider outside of Barbados, we rely on one or more of the following:
- Your consent to the specific transfer.
- The transfer being necessary to perform our contract with you, for example to deliver goods or services you have ordered.
- Contractual protections with our service providers that require them to protect your data to a standard equivalent to the Barbados Data Protection Act.
If you are based in the UK or the EU, you should be aware that Barbados does not currently hold a UK or EU adequacy decision. This means UK and EU data protection law does not treat a transfer of your data to Barbados as automatically safe. Where required, we put alternative safeguards in place, such as contractual clauses with our service providers, or we rely on the fact that the transfer is necessary to fulfil a contract you have asked us to perform.
If you have any questions about how your data is protected once it reaches Barbados, please contact us using the details in Section 1, or contact our UK or EU Representative.
7. Data Security
We have implemented security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to employees and partners who have a business need to know it. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to address any suspected personal data breach and will notify you and any applicable regulator if we are legally required to do so.
8. Data Retention
We will retain your personal data only for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.
When deciding how long to keep the data, we consider its volume, nature, and sensitivity; the potential risk of harm from unauthorised use or disclosure; the processing purposes; whether these can be achieved by other means; and legal requirements.
For tax purposes, the law requires us to retain basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 6 years after they cease to be customers.
We also retain Marketing Data for 6 years from the date of your last interaction with us, after which it is deleted or anonymised unless you ask us to remove it sooner.
In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/
If you wish to exercise any of the rights set out above, please email us at mike.ashton@residencebarbados.com.
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, or refuse to comply with your request in these circumstances.
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 for further information in relation to your request to speed up our response.
When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances. This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it and the potential benefit to you of receiving it.
We try to respond to all legitimate requests within one month of receiving the request, or, where applicable, of receiving the identity verification information or clarification we have asked for. The response period is paused while we wait for that information.
Occasionally, it may take us longer than one month if your request is particularly complex or you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed and explain why.
10. How To Complain
If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you.
You can submit a data protection complaint to us by emailing us at mike.ashton@residencebarbados.com.
We will acknowledge your complaint within 30 days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion.
If you are within the UK and are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO).
If you are in the EU and are not satisfied with our response, you have the right to complain to the data protection authority of the country where you are based.
11. Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
12. 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 Cookie Policy.
This document was created using a template from Small Business Legal Academy. It was updated on 16 July, 2026.