PRIVACY AND COOKIES POLICY
This policy covers the following;
1. Who we are
2. How we collect information about you
3. Information we collect and why we use it
4. Legal basis for using your information
6. Sharing your Information
7. Keeping your information safe
8. How long we hold your information for
9. Your rights
1. WHO WE ARE
Here at Haulfryn, we are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a “data controller” for the purposes of the Data Protection Act 1998 and (from 25 May 2018) the EU General Data Protection Regulation 2016/679 (“Data Protection Law”). This means that we are responsible for, and control the processing of, your personal information.
For further information about our privacy practices, please contact our Data Protection Officer by:
• Writing to Data Controller, Haulfryn, Clarion House, Norreys Drive, Maidenhead, Berkshire, SL6 4FL
• Calling us on 01628 902 600
• Emailing to firstname.lastname@example.org
2. HOW WE COLLECT INFORMATION ABOUT YOU
Everything we do, we do to ensure that our owners and guests have the most positive experience with Haulfryn possible. We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls.
We collect information from you in the following ways:
When you interact with us directly: This could be if you ask us about purchasing a home with us, to gain further information about your contract with us, to enquire about your holiday or specific activities, simply visiting our locations, or apply for a job or otherwise provide us with your personal information. This includes when you phone us, visit our website, or get in touch through the post, or in person.
When you interact with us through partners or suppliers working on our behalf: This could be if you book your holiday through our booking partners but will also include lodge suppliers, and other suppliers of services to our facilities.
When you visit our website: We gather general information which might include which pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. There are more details below – see ‘Cookies’.
We use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
2. HOW WE COLLECT INFORMATION ABOUT YOU
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number and credit/debit card details (if you are making a purchase or have a holiday booking with us), as well as information you provide in any communications between us. You will have given us this information whilst purchasing a home, holidaying with us, living on our parks, or any of the other ways to interact with us.
We will mainly use this information:
• To contact you about news on and about your park and marketing offers
• To process your payments, and verify any financial transactions
• To provide the services or goods that you have requested
• To update you with important administrative messages about your home or holiday, an event, or services or goods you have requested
• To keep a record of your relationship with us
If you do not provide this information, we will not be able to process your home or lodge purchase, facilitate your holiday booking, or provide goods and services you have requested.
We may also use your personal information:
• To invite you to participate in surveys or research.
Sensitive Personal Information
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs. It can also include information collected via CCTV, Biometrics, or ANPR (number plate recognition) systems.
We will only use this information:
• For the purposes of facilitating a specific service that requires such information (for example, for Spa treatments), for ensuring your safety, or to allow you access to facilities
• We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
• Where you have given us your express consent or otherwise clearly indicated to us, for example in signing up to our website offers
4. LEGAL BASIS FOR USING YOUR INFORMATION
In the majority of cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have purchased a lodge / park home, or have booked a holiday with us).
However, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for Haulfryn to process your information to help us help you get the most from your interaction with us.
Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal information if there is no need.
We will only contact you to discuss offers that we believe will be of use to you by phone, email or text message, if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address we may send you information by mail unless you have told us that you would prefer not to hear from us in that way.
You can update your choices or stop us sending you these communications at any time by contacting ‘Marketing@Haulfryn.co.uk’ or clicking the unsubscribe link at the bottom of the relevant communication.
6. SHARING YOUR INFORMATION
The personal information we collect about you will mainly be used by our team at Haulfryn so that they can ensure you get the best experience possible from us.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
Haulfryn may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver required services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it, and never use it for any other purposes. Some examples of where we may share your information are preferred insurance providers, or finance companies, and our partners who help us to manage our social media accounts. If you do not want us to pass your data to third parties please get in touch so that we can discuss.
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.
7. KEEPING YOUR INFORMATION SAFE
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our websites.
Any debit or credit card details which we receive on our website are passed securely to our payment processing partners, according to the Payment Card Industry Security Standards (PCI DSS).
8. HOW LONG WE HOLD YOUR INFORMATION FOR
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations. We have a policy in place in the business that explains the reason for the length of retention of data in each case.
9. YOUR RIGHTS
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Data Controller team at Haulfryn; Clarion House, Norreys Drive, Maidenhead, Berkshire, SL6 4FL, by email at datacontroller@Haulfryn.co.uk and by phone on 01628 902 600. You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, https://ico.org.uk.
• Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing to Data Controller, Haulfryn, Clarion House, Norreys Drive, Maidenhead, Berkshire, SL6 4FL, and provide us with evidence of your identity (such as a copy of passport / photo drivers licence).
• Right to object: You can object to our processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
• Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
• Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
• No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
‘Cookie’ is a name for a small file, usually of letters and numbers, which is downloaded onto your device, like your computer, mobile phone or tablet when you visit a website.
They let websites recognise your device, so that the sites can work more effectively, and also gather information about how you use the site. A cookie, by itself, can’t be used to identify you.
The cookies we use
We use the categorisation set out by the International Chamber of Commerce in their UK Cookie Guide.
We use all four categories of cookies:
• Strictly necessary cookies are essential for you to move around our website and to use its features, like our shopping basket and your account.
• Performance cookies collect anonymous information about how you use our site, like which pages are visited most.
• Functionality cookies collect anonymous information that remember choices you make to improve your experience, like your text size or location. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
• Targeting or advertising cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. As such if you visit the Haulfryn website you may then be more likely to see adverts about Haulfryn’s work on other websites as your browsing suggests that this is an area of interest.
No cookies, please
You can opt out of all our cookies (except the strictly necessary ones). Find out how to control and delete cookies in your browser.
But, if you choose to refuse all cookies, our website may not function for you as we would like it to.
Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes to ensure that we continuously improve our customer service standards.
To find out more about this policy and how we look after your personal information, contact our Data Controller team at datacontroller@Haulfryn.co.uk or on 01628 902 600.