Introduction
Ugbrooke House is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR).
We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This privacy notice aims to give you information on how we collect and processes your personal data, including any data you may provide through this website and when you take up our services.
It is important that you read and retain this notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
This Privacy Notice is for information only, it is not a contractual agreement.
Contact Information & Compliance Officer
Our full details are:
Alexander Clifford t/a Ugbrooke Park Ugbrooke Park, Chudleigh, Devon, TQ13 0AD Telephone: 01626 852179
We have appointed a Data Protection Compliance Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact this person. 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.
If you have any questions about this privacy notice, please contact the Compliance officer. They can be contacted on: [email protected].
The kind of information we hold 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: such as first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
- Contact Data: such as billing address, delivery address, email address and telephone numbers;
- Transaction Data: such as details about payments to and from you and other details of products and services you have purchased from us;
- Technical Data: such as internet protocol (IP) address, your login data, 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 website;
- Profile Data: such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data: such as information about how you use our website, products and services; and
- Marketing and Communications Data: such as your preferences in receiving marketing from us and our third parties and your communication preferences.
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 a product or service you have with us but we will notify you if this is the case at the time.
Other data
We may 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.
We do not collect any special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, etc.). We also do we collect any information about your criminal convictions and offences.
How is your personal information collected?
We collect personal information about you through our direct interactions, such as via post, email or otherwise. We also collect your data when we interact regarding our services; subscribe to our service or publications; request marketing to be sent to you and/or give us some feedback.
We may obtain Contact, Financial and Transaction Data from providers of technical, payment and delivery or Identity and Contact Data from data brokers or aggregators.
Lastly, we may obtain Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
How we will use information about you
We will only use your personal information when the law allows us to. Most
commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- 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.
We may also use your personal information in the following situations, which are likely to be rare, such as where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Situations in which we may use your personal information
We need all the categories of information above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
| Purpose/Activity | Lawful basis for processing including basis of legitimate interest |
|---|---|
| To register you as a new client/customer | Performance of a contract with you |
| To process and deliver services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| 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) 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) |
| To administer and protect our Company | (a) Necessary for our legitimate interests (for running our Company, provision of administration and IT services, to prevent fraud and in the context of a Company reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Necessary for our legitimate interests (to develop our products/services and grow our Company) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical 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.
Change of purpose
We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data sharing
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
”Third parties” includes third-party service providers. The following activities are carried out by third-party service providers such as service providers (administration and IT services), professional advisers (such as lawyers, auditors, bankers and insurance companies) and/or HM Revenue & Customs, regulators and other authorities.
Data security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a need to know.
They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Compliance Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Compliance Office.
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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to 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.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Compliance Officer in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Compliance Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to the privacy notice and your duty to inform us of changes
We reserve the right to update this privacy notice at any time. 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.
