Privacy Policy

Who we are

139 Holdings Ltd is the controller of personal information collected through this website and through enquiries to the club. Club 139 is the name we trade under.

The registered office is C/O Simons Muirhead Burton LLP, 87–91 Newman Street, London W1T 3EY, United Kingdom. Company number 16559534. Privacy questions go to membership@club139.co.uk.

What we collect

This site does not have an account system or a payment form. We collect information in three ways.

• What you send us. The invitation form asks for your name, email, mobile number, the membership type you are interested in, the approximate size and value of your watch collection, how you heard about Club 139, what you are most hoping to get from membership, and any brands or collecting focus you choose to mention. You consent before it is sent. Club 139 stores those answers in a Google Sheet so the membership team can review the enquiry and contact you. Resend is the service that then emails a confirmation to you and emails the enquiry to the membership team.
• Technical logs. Our host keeps short-lived logs of requests to the site, which can include your IP address, browser type, and the page requested. We use these to deliver the site and to deal with abuse.
• The member access preview. The username and password you type on that page stay in the browser while the page is open. We do not create an account from them and we do not store them as a login.

We do not ask for payment card details on this site. We do not buy marketing lists. Membership is for people aged 18 or over, and we do not knowingly collect information about anyone younger.

How we use it

We use personal information to:

• read and reply to an enquiry, and decide whether to invite someone to join;
• email a confirmation to the address on the enquiry, and email the enquiry to the membership team;
• keep a record of that correspondence;
• run, protect, and improve the website;
• meet a legal duty, or establish or defend a legal claim.

The lawful bases under UK data protection law are our legitimate interests in answering serious enquiries and operating a private club website, and steps taken at your request before a membership contract. Where a law requires us to keep or disclose information, we rely on that legal obligation.

We do not use your information for unrelated marketing. If we later write a newsletter, we will ask first.

Who we share it with

We do not sell personal information. We share it only as far as this site requires:

• Vercel, which hosts the website, processes technical logs, and measures page visits and loading speed through Web Analytics and Speed Insights. Those measurements do not include the contents of an enquiry;
• Google, which stores the invitation sheet on our behalf;
• Resend, which sends the confirmation email to the person who enquired and the enquiry alert to the membership team, on our behalf;
• the provider of our membership email inbox, so we can read and reply;
• professional advisers, where a membership or investment enquiry needs them;
• 67 Pall Mall or another experience host, only if you ask us to put you forward for a specific event and we need to share your name to do that;
• a public authority, court, or regulator when the law requires it.

A future membership form or customer register, including any use of Attio, will be described in an update to this notice before it is switched on.

Where it is processed

We are based in the United Kingdom. Our website host, Google, and Resend may process the invitation sheet, the confirmation and alert emails, and technical logs in the United States as well as the United Kingdom. Where personal information leaves the UK, we rely on a lawful transfer safeguard, such as the UK extension to the EU-US Data Privacy Framework or the UK International Data Transfer Agreement, as those providers’ terms provide.

How long we keep it

Enquiry correspondence, including the invitation sheet, is kept while the conversation is active and for up to 24 months after the last message, unless you become a member or we need the record for a legal claim. If you join, the membership agreement sets the longer retention that applies to member records.

Hosting logs are kept only as long as our host’s ordinary security retention, and in any case we do not use them as a membership register. The member access preview is not retained by us.

Your rights

You can ask us for a copy of the personal information we hold about you, to correct it, to delete it, to restrict how we use it, or to object to our use of it where we rely on legitimate interests. Where the law gives you a right to receive information you provided, in a portable form, you can ask for that too.

Write to membership@club139.co.uk. We may need to confirm it is you. We aim to reply within one month.

You can complain to the Information Commissioner’s Office at ico.org.uk. We would like the chance to put things right first.

Cookies

This site does not set analytics or advertising cookies. The detail is in the Cookie Policy.

Security

The site is served over HTTPS. Access to the membership inbox is limited to the people who handle enquiries. No method of transmission is perfectly secure, and you should not email us passport scans, payment card numbers, or other highly sensitive documents unless we have asked for them by a secure route.

Changes

We will update this notice if the way we handle information changes, including when a real membership form or the member platform is added. The date at the top of the page will change with it.

Contact

Privacy questions: membership@club139.co.uk.