For the purposes of data protection laws, Heckfield Management Limited is a company registered in England and Wales with number 06208603, whose registered address is at 2nd Floor, 55 Ludgate Hill, London, EC4M 7JW. Heckfield Management Limited is the controller and is responsible for the Website.

We have a data protection officer who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below:

Full name of legal entity: Heckfield Management Limited

Email address: [email protected]

Postal address: Heckfield Management Limited, Heckfield Place, Heckfield, Hook RG27 0LD

Heckfield Management Limited is registered with the UK Information Commissioner’s Office (Z2226973).

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information (e.g., name or address) changes during your relationship with us so that we can update our records.

“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 collect personal data about you when you make a reservation or booking, subscribe to our marketing newsletter and updates, place an order for a product or service, use our online services, stay with or visit us, fill in a form or communicate with us (whether via email, telephone, post or in person) or interact with us in any other way, including but not limited to social media interactions, attending events, entering competitions, signing up for special offers and/or completing surveys.

As required by local laws, we may also be required to collect additional information, such as passport number, when you check in to stay with us.

During or prior to your visit/stay, we may gather personal information, such as your preferences or any special requirements in order to provide you with a tailored and superior service during current and future visits/stays. This information is stored on our systems.

For security purposes, we operate closed circuit television systems “CCTV” in and around our premises. These may capture your image if you visit our premises.

Our key card system will also record when you enter and leave your room.

We may receive information about you from other sources, such as public databases, travel agents, airlines, credit card companies and other third parties.

We may collect, use, store and transfer different kinds of personal data about you which may include your name, email address, date of birth, birthday, telephone numbers, billing address, delivery address, bank account and payment card details, booking history, preferences related to your visit/stay and certain information when you visit the Website including IP address, preferences, the type of browser you use, your login data, time zone setting and location, browser plug-in types and versions, operating system and platform and any other technology on the devices you use to access the Website, your interests, preferences, feedback and survey responses, your preferences in receiving marketing from us and our third parties and your communication preferences.

When you visit or stay with us, we may collect certain types of Special Categories of personal data also known as “sensitive personal data” which might include health and medical information. We will only collect such information where you give it to us and where it is directly relevant to your visit/stay with us or your use of our facilities, such as the spa and treatment area or if you wish to visit the working farm. If you have any allergies or intolerances, we will note those for your wellbeing

We will only use your personal data when the law allows us to and for the purposes set out in this Policy. These are:

• When you give your consent
• When necessary for the performance of a contract we have entered into or are entering into with you
• When necessary to comply with a legal or regulatory obligation
• For our legitimate interests or those of a third party, provided that your interests and fundamental rights and freedoms do not override those interests.

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 process your booking or provide you with goods or services). We will notify you if this is the case at the time.

We may also use your personal data to meet our legal obligations, to deal with any complaints and for the enforcement of our terms and conditions.

We may use your personal data for our legitimate business interests which include security purposes, improvements to our Website, improvements to our solutions and services and for general marketing purposes. We will not do so though where our interests are outweighed by your interests, rights and freedoms.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we may use your personal data:

• to process your booking and register you on our systems as a guest;
• to manage payments, fees and charges and collect and recover any monies owed to us;
• to manage our relationship with you which will include notifying you about changes to our terms or privacy policy and/or asking you to leave a review or take a survey;
• to enable you to take part in a prize draw, competition or complete a survey;
• to send you newsletters, to keep you updated on events, new facilities or services or other goods or services that may be of interest to you, to let you know about special offers and to invite you to our events. For more information on how we may market to you please see the section of this policy called ‘Marketing Communications’;
• to administer and protect our business and our Website (including troubleshooting,
• data analysis, testing, system maintenance, support, reporting and hosting of data);
• to deliver relevant website content and advertisements to you and measure or understand the effectiveness of that advertising;
• to use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.

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 you would like to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data protection officer using the details set out above.

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.

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Where processing is based on your consent, we shall only process your personal data until such time as you withdraw your consent unless we have another lawful basis on which we can continue to process your personal data.

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 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.

We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Policy.

We take reasonable steps to ensure that any third parties hosting our Website and our other services have adequate security measures in place to protect personal data.

Some of our systems are managed from outside of the United Kingdom (UK) which means that your personal data may be transferred outside the UK. We will only transfer your personal data outside the UK where the organisation receiving the personal data has provided adequate safeguards in accordance with UK data protection laws.

For further information about the specific mechanisms in place for transfers outside the UK, please contact us.

We will not sell your personal data and generally do not give your personal data to third parties but there are some exceptions. We may share your personal data in the following ways (as appropriate):

• in order to provide any services requested by you which may involve us sharing your personal data with our partners or third parties with whom we do business;
• with any actual or prospective seller or buyer of our business and/or any assets. Information held by us about our customers and any users will be one of the transferred assets;
• with our group companies, which means our subsidiaries and holding companies and any subsidiary or holding company of the same;
• in order to comply with any legal obligation or as otherwise permitted by law;
• for debt collection purposes;
• for security purposes or to protect our rights or those of a third party;
• in the conduct or defence of legal claims or in order to enforce our terms and conditions; and
• for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, we may share any personal data that we collect with the Police, other public or private sector agencies, governmental or representative bodies in accordance with the relevant legislation. This will include public authorities, insurance companies, finance companies and/or other agencies.

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have signed up to receive them or otherwise requested information from us. We will not send marketing communications to you where you have opted out of receiving these.

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, we may still contact you in relation to your booking or your visit/stay when we have a lawful basis to do so.

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 and access the same.

They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Under data protection law you have the following rights in respect of your personal data:

• to request information regarding the personal data that we hold about you and the source(s) of that information. You can request a copy of any personal data we hold about you. This service is usually free of charge, although we have the right to charge a ‘reasonable fee’ in some circumstances;
• to request that we rectify any inaccuracies in relation to the personal data we hold;
• in some circumstances, to request the erasure of your personal data or object to the processing of your data;
• to object to any direct marketing;
• in some circumstances, to request that your personal data be transferred to you or a new provider if the data is processed automatically;
• to withdraw consent to us processing your personal data. This will not affect the processing already carried out with your consent; and
• to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you wish to exercise any of the rights set out above, please contact our data protection officer using the details set out in this Policy.

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 a person who does not have the right to receive it.

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.

Our 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.