Privacy Notice for Upton Lakes & Lodges Ltd
Welcome to our privacy notice.
We respect your privacy and are committed to protecting your personal information, which we call “personal data”. This privacy notice will tell you how we look after your personal data and about your privacy rights. It supplements any other notices and is not intended to override them.
We have tried to be brief and clear. We are happy to provide any additional information or explanation.
WHO WE ARE
|Data Controller(referred to as “we/us/our”)||Upton Lakes and Lodges Ltd|
|Name or title of Data Protection Manager:||Mrs Claire Down|
|Address:||Upton Farm, Cullompton, Devon EX15 1RA|
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would appreciate the chance to deal with your concerns first.
This version was last updated on 19 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed of any changes.
HOW WE COLLECT YOUR PERSONAL DATA
You may give us data orally or by filling in forms or by corresponding with us by post, phone, email or otherwise, for example when you:
• Contact us via our website
• By communications, including email, telephone, post or social media
• enter into a contract with us or contact us about doing so either directly or via our partners Hoseasons;
• contact us about any contract we have with you;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us some feedback.
When using our digital services such as our website, we gather data from you using cookies and other tracking software, such as Google analytics. The purpose of this is to understand how you are using our services, and to provide you with better and enhanced information.
We may also receive personal data about you from third parties and public sources, including other customers when they interact with us and (if applicable):
|Hoseasons||When enquiring about Upton Lakes & Lodges, when making a booking for Upton Lakes & Lodges, once the booking has been finalised for all associated obligations for the performance of the contract with you|
|Upton Barn & Walled Garden Ltd||When planning your stay whilst attending a wedding at Upton Barn & Walled Garden|
HOW WE USE YOUR DATA
We have set out below how and why we plan to use your personal data.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you with our business||Performance of a contract with you|
|To perform any contract with you including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(c) Addressing any breach
(d) Managing your stay with us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for our legitimate interests (to ensure compliance with contract terms)
|To manage our relationship with you which will include:
(b) Notifying you about changes to our business which are relevant to you
(c) Managing your stay with us
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how people use our business)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop and grow our business)|
|Asking you to partake in a review, prize draw, competition or complete a survey||Necessary for our legitimate interests (to study how people use our business, to develop and grow our business)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how people use our business, to develop and grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, relationships and experiences||Necessary for our legitimate interests (to define types of people for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We will get your express opt-in consent before we use your personal data for any other marketing purpose. We will not share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting our DPM.
For information about the cookies we use, and your ability to refuse them please refer to our separate cookie note on our website
CHANGE OF PURPOSE
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.
VISITORS TO OUR WEBSITE
If we want to collect personally identifiable information through our website, we will be up front about this.
When someone visits our website, we may use a third-party service to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.
Our 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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you do not provide personal data to us and this would prevent us from performing the contract we have or are trying to enter into with you, or place us in breach of the law, we may have to cancel our contract. We will notify you if this is the case.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with third parties to help us run our business or carry out our obligations to you:
|Name||Lawful basis for processing including basis of legitimate interest.|
|Service providers for IT and system administration||Performance of a contract with you
Necessary for our legitimate interests (performing the contract, using your data as we have described in this notice).
|Our professional advisers including lawyers, bankers, auditors and insurers.||Necessary for our legitimate interests (complying with our legal obligations).|
|HM Revenue & Customs, regulators and other authorities.||Necessary for our legitimate interests (complying with our legal obligations).|
|Private Lodge Owners who sub-let their lodge sited at Upton Lakes & Lodges through our sub-let management scheme.||Performance of a contract with you
Necessary for our legitimate interests (to resolve any dispute, performing the contract).
We use third party providers such as agents, subcontractors and other organisations to help us provide services to you, these would include:
- Cloud accounting and payroll providers including Xero and Francis Clark
- Email and secure document exchange systems including Microsoft, Google and Dropbox
- Mailchimp, Campaign monitor, research agencies and mailhouses
- Cleaning and maintenance contractors
We may also share your personal data with any third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. All of our third-party service providers are required to take commercially responsible and appropriate security measures to protect your personal data. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of the third party IT providers we use may send your data outside of the European Economic Area (EEA). Where this is the case, we will take reasonable steps to ensure that your data is protected in the same way as if it was being used in the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You can ask us about the retention periods for different aspects of your personal data by contacting our DPM.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We do not knowingly collect data relating to children.
No fee usually required 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. Alternatively, we may 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 you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.