We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://manorabberley.co.uk/ (“Our Site”) and will only collect and use any personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Data” – means any contact details or personal information given to via or collected via this website or contact form;
“Cookie” – means a small text file placed on your computer or device by Our Site when you visit certain parts of OurSite and/or when you use certain features of Our Site. Details of the Cookies used by Our My Site are set out in Part 14, below; and
“Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003. These provisions will be incorporated directly into UK Law in 2020, as part of The Great Repeal Act.
2. Information About Us
Our Site is owned and operated by Means Coach House Inns Limited No.2 Ltd Trading As: Coach House Inns, a company registered in England & Wales.
Registered address: Floor 4, Link House, 25 West Street, Poole, BH15 1LD, United Kingdom.
Our nominated Data Protection Officer is: Ed Formstone
Email address: firstname.lastname@example.org
Postal address: Contact is as shown above.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
These regulations and requirements (or similar) will be transposed fully into UK Law during 2020 as a result of the UK withdrawing from the EU.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- b) The right to access the personal data wehold about you. Part 13 will tell you how to do this.
- c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- e) The right to restrict (i.e. prevent) the processing of your personal data.
- f) The right to object to us using your personal data for a particular purpose or purposes.
- g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights as a Consumer User can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves first, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Data Collected – How We Collect the Data
Identity Information including salutation/ title, name and address.
Via our Contact Us form or direct email contact. This may also be entered into our Contacts List or other written method such as a database storage.
Personal contact information including email address.
Via our Contact Us form or direct email contact. This may also be entered into our Contacts or mailing list or other written method such as a database storage.
Business information including business name and contact details.
Via our Contact Us form or direct email contact, Post or telephone contact. This may also be entered into our Contacts or mailing list or other written method such as a database storage.
Payment information including bank details or Payment Processor or Banking identification details.
Via our Payment Processor, invoices and banking records.
Technical information including IP Address, Browser Type and version.
Via our Analytics software and other detection software.
Data from third parties including logins, contact details and transmission of email/ online messages.
Via our analytics software.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do – What Data We Use – Our Lawful Basis
Accessing our website – Personal contact details.
To identify those contacting us, their purpose and responding to their enquiries.
Providing and managing your access to Our Site – Your personal access details when you access and interact with the website.
To better serve your browsing experience and provide our business services information.
Communicating with you – Using any personal details or contact information you have supplied us with via direct contact with the website and our mail contact form, newsletter or Loyalty Scheme sign-up form/s.
This is to answer your enquiries and contact requests, provide further information or contact details, send newsletters or special promotion and discount offers to you and to promote our services to you.
Supplying you with information by email and/ or post that you have opted-in-to (you may opt-out at any time by clicking on any unsubscribe button or informing us directly – Using any personal contact details you have already given to us. We will not arbitrarily add you speculatively to any mailing list. If this should occur in terms of any general canvassing, we will always cease contact with you if you inform us of this desire.
This is to answer existing enquiries, recontact older and previous customers and to send you information that we feel will be of use and benefit to you.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any UK Data Laws, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties (including links to any other companies or organisations) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
In some circumstances, where permitted or required by law, we may be required to process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data – How Long We Keep It
Identity Information including personal contact details, business contact details, phone numbers, email addresses etc.
No fixed period but a maximum of 7 years. Business Law requires UK businesses to retain business records for that period.
Payment information including transactions and financial records.
No fixed period but a maximum of 7 years. Business Law requires UK businesses to retain business records for that period.
9. How and Where Do You Store or Transfer My Personal Data?
Normally we will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
Depending on our choice of Hosting Supplier, we may sometimes be required to store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows.
We may share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
If ever we are required to hold or process your data via a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when handling your personal data to any third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
- We are compliant with the GDPR (General Data Protection Regulations) and other Data Protection Laws. Please refer to our Compliance Statement on this website. A written copy of this can be provided upon request.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions;
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the valid instructions of a government authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong options on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails at the point of providing your details and by informing us directly).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. Whilst it is not essential to use this form, a copy is featured in our website for your convenience.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee of £25 may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for tracking “traffic”, tracking enquirers and to protect our website from unauthorised use by identifying your IP address. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
An example of the type of Cookies we use:
In relation to your device URL browser. This helps to navigate through our Site by remembering your page choices and viewing. They also enable our Site to load faster via your device’s memory upon subsequent visits.
Google tag manager
This is to assess and remember your individual preferences and helps us to tailor a good User Journey through our Site for you. It also assists with any interaction you have with our Site.
Facebook Pixel is a small code placed on Our Site. It collects data that helps track conversions from Facebook ads, optimise adverts, build targeted and remarket to people who have already taken some kind of action on our website.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a Consent Click Box requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the Data Protection Officer):
Email address: email@example.com
Postal Address: As found on our Contacts Page.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.