Date: 21/04/2021 – made simpler to understand.
1 – Introduction
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to Orchard Holiday Park and Fishery. For more information about us, see Section 12.
2 – Credit
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3 – The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, business name, job position, email address and telephone number. The source of the contact data is you and/or your employer.
3.3 We may process your website user account data (“account data“). The account data may include your account identifier, name, caravan make/model, car registration number, membership number(s) and postal address. The primary source of the account data is you and/or your employer.
3.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, membership number(s), your payment method and the transaction details. The source of the transaction data is you.
3.5 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
3.6 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our website security provider.
3.7 We use CCTV cameras on the premises in risk areas (“CCTV data“). The CCTV data may capture video footage and / or still photos of you or family members/visitors and car registrations when on our premises. The CCTV data is processed for the purposes of securing our premises and to detect criminal activity.
4 – Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.3 Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing except where you are a business or long term client) by email, SMS, post, fax and/or telephone, providing support services and complaints handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
4.4 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.5 Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by post for marketing related purposes for our own services/goods. We do not share your personal data with any other third party for marketing and you can opt-out. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors, prospective clients and service users.
4.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.7 Security (including CCTV) – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity including the use of CCTV cameras on key risk areas of the premises. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and our business premises, and the protection of others.
4.8 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.9 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.10 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5 – Providing your personal data to others
5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal data held in paper based records and some held locally in digital format.
5.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for providing cloud services or hosting, providing services on our behalf, accountants and book keeping and technical support.
5.4 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.5 In the event we sell or merge, part or all of our business and assets, we may transfer personal data to the new owners.
6 – International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law.
6.2 We may transfer your personal data from the European Economic Area (EEA) and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3 The facilities for our website, emails, phone system provider are situated in United Kingdom or EU. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries.
6.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7 – Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 12 months following the date of the most recent contact between you and us, and for a maximum period of 7 years following the end of the year the relevant transaction occurred;
(b) account data will be retained for a period up to 7 years following the end of year the relevant transaction occurred;
(c) transaction data will be retained for a period up to 7 years following the end of year the relevant transaction occurred;
(d) communication data will be retained for a minimum period of 6 months following the date of the communication in question, and for a maximum period of 7 years following that date;
(e) usage data will be retained for as long as necessary following the date of collection; and
(f) cctv data will be retained for a minimum of 10 days and a maximum of 31 days, unless we require the cctv data for criminal proceedings or other legal matters in which case it will be retained for as long as necessary.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8 – Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Please note that we may ask for valid identification when using your rights.
9 – About cookies
10 – Security
10.1 We use an SSL (secure socket layer) certificate on our website (you can see this by the “green padlock” in your browser). This encrypts the link between the website server and the end user. Our emails and enquiry form are sent using SSL connection over STMP. However emails cannot be 100% secure, this is due to the way the internet works. We cannot accept responsibility as its out of our control. We have put in place suitable technical and physical measures for any systems we use where personal data is present.
11 – Amendments
11.1 We may update this policy from time to time by publishing a new version on our website.
11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
12 – Our details
12.1 This website is owned and operated by Steve Jones (Proprietor).
12.2 Our correspondence address:
Orchard Holiday Park and Fishery, New House Farm, St Michaels, Tenbury Wells, Worcestershire, WR!5 8TW
12.3 You can contact us:
Phone number: 01568 750618
Email address: firstname.lastname@example.org
Data controller registration no.: ZA286619