1. Personal data we collect
We collect only the personal data that is reasonably needed for the purposes described in this policy. Depending on how you interact with us, this may include:

- Identity and contact details: your name, date of birth, postal address, country, email address and telephone number.

- Booking and administration details: your booking request, eligibility confirmations, chosen payment option, payment status, invoices, correspondence, room or participation requirements and feedback.

- Emergency-contact details: the name, relationship and contact details of the person you nominate. If you give us another person’s details, you must tell them and show them this Privacy Policy before submitting their details.

- Health and accessibility information: dietary requirements, allergies, intolerances, medical, pregnancy, mobility or accessibility information that you choose to provide. This can be special-category personal data under the GDPR.

- Travel information: arrival, departure or flight details that you later provide where these are needed to coordinate retreat transfers or your participation.

- Media information: your photo and video preference and, where you consent, photographs or recordings in which you are identifiable.

- Website and technical data: information submitted through website forms and limited technical data such as IP address, browser, device information and cookie data.

Where a bank or third-party payment provider handles a payment, it processes your bank or card details under its own privacy notice. We normally receive the payment status, amount, date and transaction reference rather than full card details.
Our retreats are for adults aged 18 or older. We do not knowingly accept bookings from children.

 
2. Why we use personal data and our legal bases
-Enquiries and booking requests
  What this covers: Responding to you, assessing and administering a booking request, and sending booking information.
  Legal basis: Steps before entering into a contract and performance of a contract.

- Delivering the retreat
  What this covers: Accommodation, meals, transfers, activities, communications, participant support and handling changes or complaints.
  Legal basis: Performance of our contract with you.

- Payments and records
  What this covers: Confirming payments, invoicing, bookkeeping, tax and statutory records.
  Legal basis: Performance of our contract and compliance with legal obligations.

- Emergency contact and participant safety
  What this covers: Holding and, where reasonably necessary, using the nominated contact’s details in connection with a participant’s safety or a serious incident.
  Legal basis: Our legitimate interest in participant safety; vital interests where applicable in an emergency.

- Health, dietary and accessibility support
  What this covers: Planning reasonable arrangements and sharing only necessary information with relevant retreat suppliers, including in Ghana. In a genuine emergency, using information to protect you or another person.
  Legal basis: Your explicit consent for health-related data; vital interests where applicable in an emergency.

- Safety, security and legal matters
  What this covers: Fraud prevention, incident management, insurance, enforcing our terms, and establishing or defending legal claims.
  Legal basis: Legal obligations and our legitimate interests in operating safely and protecting our rights.

- Photos, video and marketing
  What this covers: Using identifiable retreat media, sending newsletters, and using optional analytics or marketing cookies.
  Legal basis: Your consent, which you may withdraw.
 

Some information is necessary for us to process and perform your booking. If you do not provide it, we may be unable to accept or deliver your booking. Health information, identifiable-media consent and marketing consent are optional, although missing health or accessibility information may limit the arrangements we can safely make.
Where we rely on consent, you may withdraw it at any time by emailing info@chaptersretreats.com. Withdrawal does not affect processing that was lawful before it was withdrawn and does not affect consent given for a different purpose.

 

3. Who we share personal data with
We do not sell personal data. We share only the information reasonably necessary with:

- our authorised retreat team and co-hosts;

- website, form, email, cloud-storage and payment-service providers;

- our accountant, insurer, insolvency-protection provider and professional advisers where relevant;

- trusted accommodation, catering, transport, activity and emergency or medical providers involved in delivering the retreat; and

- public authorities, regulators, courts or law-enforcement bodies where disclosure is required or permitted by law or necessary to protect someone’s safety.

We share health, dietary and accessibility information only with people who need it to make the relevant arrangements, only to the extent necessary and, where it is health-related data, on the basis described above.

 

4. International transfers
CHAPTERS is based in the Netherlands, while the retreat takes place in Ghana. Ghana is outside the European Economic Area and is not currently covered by a European Commission adequacy decision. Its data-protection rules may therefore not provide the same level of protection as the GDPR.
For the Ghana retreat, limited transfers to Ghana-based accommodation, catering, transport, activity or emergency providers may be objectively necessary to perform your booking or make arrangements you request. For these occasional transfers, we rely where applicable on the contract-necessity exception in Article 49(1)(b) GDPR, limit the data to what the provider needs and use additional safeguards where reasonably possible.
Some of our website, form, email, cloud-storage or payment providers may also process data outside the EEA. Where required, we use an adequacy decision, European Commission standard contractual clauses or another valid GDPR transfer mechanism. You may contact us for information about a particular transfer and the safeguards used.

 

5. How long we keep personal data
We keep personal data only for as long as reasonably necessary for the relevant purpose, including legal, accounting, insurance and dispute-resolution requirements. Our usual retention periods are:
- enquiries that do not result in a booking: up to 12 months after our last contact;
- ordinary booking records and correspondence: up to two years after the retreat, unless a complaint, incident or legal claim requires longer;
- invoices and core accounting records: seven years, in line with Dutch tax-record obligations;
- health, dietary, accessibility and emergency-contact details: normally deleted or anonymised within three months after the retreat, unless an incident, legal obligation or claim requires longer;
- marketing contact details: until you unsubscribe or we determine that they are no longer current; and

- identifiable photographs and video: while we continue to use them for the purpose covered by your consent, subject to periodic review and any withdrawal of consent.

If you withdraw media consent, we will stop new use and take reasonable steps to remove material from channels we control. Copies already shared by others, cached by search engines or included in printed material may not always be fully retrievable.

 

6. Your data-protection rights
Subject to the conditions in the GDPR, you may ask us to:

- give you access to your personal data;

- correct inaccurate or incomplete data;

- delete data or restrict how it is used;

- provide certain data in a portable format;

- stop processing based on your particular situation where we rely on legitimate interests; or

- record the withdrawal of consent at any time.

To exercise a right, email info@chaptersretreats.com. We may ask for information needed to verify your identity. We normally respond within one month, although the GDPR permits an extension for particularly complex or numerous requests.
You may complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens, at autoriteitpersoonsgegevens.nl. You may also contact the data-protection authority in the EEA country where you live or work, or where you believe an infringement occurred.
We do not make decisions about you based solely on automated processing that produces legal or similarly significant effects.

 

7. Cookies and website services
Our website uses necessary cookies and similar technologies to operate forms, security features and core website functions. Analytics or marketing cookies are used only after you give consent where the law requires it. You can refuse them and later change or withdraw your choice through the cookie settings. Third-party services may process data under their own privacy notices.

 

8. Security
We use reasonable technical and organisational measures designed to protect personal data, including limiting access to people who need it for their role and using reputable service providers. No internet transmission or storage system is completely secure, so we cannot guarantee absolute security.

 

9. Changes and contact
We may update this Privacy Policy when our services, suppliers or legal obligations change. The current version will be published on our website with its last-updated date. Where a change materially affects how we use data already collected, we will take appropriate steps to inform you.
Questions, requests or complaints about this policy may be sent to:
CeeKay Events, trading as Chapters Retreats
Molenweide 87, 2614 LJ Delft, the Netherlands
Email: info@chaptersretreats.com
Telephone: +31 6 25 26 63 75