Privacy policy.
We at Honeybridge Estate, take the privacy and security of your personal data very seriously.
The policy applies to any personal data we collect from you, including when you book a visit to the estate or contact us for any other reason. It also applies to your use of our website www.honeybridgeestate.co.uk (the “Site”).
Please read this policy carefully before giving us any of your personal data.
Who We Are
We are The Honeybridge Estate – an unincorporated entity.
We are the controller of your personal data and are responsible for what happens to any data you send to us. We are subject to certain legal obligations about how we store it, who we send it to and what we can lawfully do with it. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below:
Tel: 01403 597 097
Email: mail@honeybridgeestate.co.uk
The Data We Collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where any identifying markers have been removed.
We may collect the following kinds of personal data from you:
Generally, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. The only exceptions to the above are:
If an accident occurs on the estate, we may record information relating to that accident, which may include special category data about you; and
If you have dietary requirements which stem from your religious beliefs or a medical condition, we will collect and retain this information if you disclose it to us.
Failure to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to make a booking, you will need to provide us with your name, age, contact details and other information).
Aggregated Data
Honeybridge Estate may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about which of the three buildings on the estate are most popular and when, or the areas of the country where visitors mostly come from. We may also
aggregate data about how our Site is used (e.g. the percentage of users who access it via an IOS device, as against those who use Android or Windows.) We will use this data to inform our marketing and development strategies.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
How We Collect Your Data
A lot of the data we collect about you will be provided by you directly to us when you make a booking or contact us for any other reason. We will collect technical data from your browser when you visit our Site, and we will receive data about you from agents where you make a booking through them.
How We Use Your Personal Data
Generally, we do not rely on consent as a legal basis for processing your personal data. We will only use your personal data when the law allows us to. Most commonly, we will use it in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you (e.g. to accept your booking and take payment for it);
To protect your vital interests (e.g. in the event of an accident);
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
Where we need to comply with a legal obligation.
Where we rely on our own legitimate interests to process your data, those interests are:
To administer and protect our business;
To increase footfall to the estate by showing you the most relevant content; and
To use data analytics as a way of improving the user experience on our Site.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Marketing
We would welcome the opportunity to keep you up to date with everything happening on the Honeybridge Estate. You can opt into receiving regular updates by email from our Site. When you receive a communication, we may collect information about how you respond to or interact with that communication, and this may affect how we communicate with you in future.
You can decide not to receive communications or change how we contact you at any time. If you wish to do so, either click on the relevant link at the end of every email you receive from us, or contact us directly using the details set out above.
Photography
We may take photographs of the estate during your visit. If we do this, our photographers will be clearly identifiable, and we will not use photographs of any adult who has expressly told us that they do not wish their photographs to be used. Photographs may be accompanied by a first name.
In the case of anyone under the age of 16, we will obtain express written consent from their parent or legal guardian before we use any photograph of them for promotional purposes.
If you take photographs during your stay on the Honeybridge Estate, upload them to a social media platform and tag us in the relevant image, we will assume that you are happy for these photographs to be shared on our social media business page. If any photographs you tag us in include images of children under the age of 16, we will not use them without written consent from their parent or legal guardian in writing. If you do not tag us, or your privacy settings do not permit image sharing, we will not republish the post.
Disclosures of Your Data
We will never sell your personal data.
However, we may share it with subcontractors or suppliers who provide services to our business. Our subcontractors will typically fall within the following categories:
Service providers requested by guests: We offer all manner of activities on the estate, from tennis lessons to massages. Where a guest requests any of these services, we may pass their personal data to the individual or company providing that service. If personal data includes any special category data, we will obtain express permission from guests before passing it on.
Professional Advisers (e.g. accountants, marketing specialists and lawyers);
IT services providers;
Associated companies (e.g. other companies connected with the estate); and
Marketing and social media companies.
Where we share your data with suppliers or subcontractors, they will be subject to a contract which imposes strict obligations of confidentiality and compliance with UK data protection laws on them.
All of our external third-party suppliers and subcontractors are either based within the UK, or are subject to suitable legal restrictions about where they may store your personal data.
We may also disclose your personal data to 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 policy.
Data Security and Retention
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Your Legal Rights
Under certain circumstances, you have rights under data protection law in relation to your personal data. You have the right to:
Request access to the personal data we hold about you;
Request corrections to any of the personal data we hold, if it is inaccurate;
Ask us to erase your personal data;
Object to the way in which we process your personal data; or
Request transfer of your personal data in a commonly-used file format.
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 could refuse to comply with your request in these circumstances. If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could 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. Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
Your Right to Complain
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues. Details of how to do this can be found on their website, which you can access by clicking here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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