Spains Hall Estate Privacy Policy 

Introduction

Spains Hall Partnership respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice


This privacy notice aims to give you information on how Spains Hall Partnership collects and processes your personal data through your use of this website, including any data you may provide through this website and linked sites (such as our booking and payment sites) when you sign up to our marketing list, purchase a product, or set up an account.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.


Controller


Sir TE Ruggles-Brise, Lady RE Ruggles-Brise, AE Ruggles-Brise trading as Spains Hall Partnership is the controller and is responsible for this website.

If you have any questions about this privacy notice, please contact the Data Privacy Manager, using the details set out below.


Contact details


Our full details are:

Full name of legal entity: 

Sir TE Ruggles-Brise, Lady RE Ruggles-Brise, AE Ruggles-Brise, AC Ruggles-Brise trading as Spains Hall Partnership

Name or title of person who manages queries relating to privacy notice: 

Data Privacy Manager

Email address: 

enquiries@spainshallestate.co.uk

Postal address: 

Spains Hall Estate, Finchingfield, Braintree, Essex, CM7 4NL, UK

Telephone number: 

+44 (0)1371 811596

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

By email: Please complete the form at https://ico.org.uk/global/contact-us/email/

By phone: +44 (0)303 123 1113

By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF


We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.


Changes to the privacy notice and your duty to inform us of changes


This version was last updated on 5th August 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


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.


The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

 

  • Identity Data includes first name, last name, username or similar identifier, title, car registration number (if you are bringing a vehicle onto the Estate as part of a booking).
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Transaction Data includes details about payments from you and other details of products and you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data (if you choose to create an account on our booking site). 3rd party sites (such as our booking, shopping and payment processor sites may also collect some or all of the following: browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this or associated websites.
  • Profile Data includes your username and password (if you choose to create an account on our booking or shop sites), purchases or orders made by you (if you place an order)
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we (or more likely website analytics services provided by our service providers) 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 notice.

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.


If you fail 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 provide you with goods or services). In this case, we may have to cancel an order you have with us, but we will notify you if this is the case at the time.


How is your personal data collected?

We use different methods to collect data from and about you including through:

 

  • Direct interactions You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • order our products or services;
  • create an account on our website;
  • request marketing to be sent to you; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we (and those websites) may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, http request headers, server logs, analytics software and other similar technologies. 
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

 

Technical Data from the following parties:

a. analytics and search information providers such as Google based outside the EU;

b. advertising networks such as Facebook, Twitter, YouTube and Instagram based outside the EU; and

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and Paypal based inside the EU,

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.


How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation.
You have the right to object to being sent marketing at any time by contacting us.

5 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Essential Uses

 

 

1. To register your account

(a) Identity 
(b) Contact

Performance of a contract with you

2. To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity 
(b) Contact 
(c) Financial 
(d) Transaction 
(e) Marketing and Communications

(a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to recover debts due to us)

3. To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity 
(b) Contact 
(c) Profile 
(d) Marketing and Communications

(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 customers use our products/services)

4. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(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

Non-essential

 

 

5. To manage our relationship with you which will include:
(a) Asking you to leave a review or take a survey

(a) Identity 
(b) Contact 
(c) Profile 
(d) Marketing and Communications

(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 customers use our products/services)

6. To enable you to partake in a prize draw, competition or complete a survey

(a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications

(a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

7. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 
(b) Contact 
(c) Profile 
(d) Usage 
(e) Marketing and Communications 
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

8. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences and to ensure that content from our website is presented in the most effective manner for you and for your computer

(a) Technical 
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

9. To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity 
(b) Contact 
(c) Technical 
(d) Usage
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:


Promotional offers from us

Very occasionally we may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.


Third-party marketing

We do not provide your Personal Information to any third party companies but you may submit your Personal Information to a company not controlled by Spains Hall Partnership in the course of making an enquiry to us or placing a booking.


Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase or other transactions.


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. 


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 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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in above.
o 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. 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.

Data Security

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.

Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
We have put in place procedures to deal with any suspected personal data breach and will notify you and/or the ICO of a breach where we are legally required to do so.

Data Retention

How long will you use my 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out in Section 12, please contact us.

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.

What we may need from you

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.

Time limit to respond

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.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

External Third Parties

o Service providers acting as processors based within the EEA who provide IT and system administration services.

o Service providers acting as processors based outside the EEA including but not limited to:

Constant Contact and MailChimp -  email marketing service; and

Xero , Receipt Bank and Futrili who provide us with an accounting package and hold our transaction data.

Stripe who perform credit card transactions

Checkfront and Duda who provide an online booking portal and online shop.

o Professional advisers acting as processors or as data controllers including lawyers, bankers, auditors, insurers and credit checkers based within the EEA who provide consultancy, banking, legal, insurance, accounting and fraud prevention services.

o HM Revenue & Customs, regulators and other authorities acting as processors or data controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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.

Spains Hall Partnership 5th August 2022