The Clovelly Estate Company: Privacy Policy

Updated: 29th September 2020.

Please click here for our suppliers privacy policy.

This privacy policy will explain how our organisation uses the personal data we collect from you when you use our website or visit our estate. Please note that presently we are also asked to comply with the Governments Track and Trace service and as such will securely store all visit lead party contact details for 21 days.

Topics:

  • Test and Trace
  • What data do we collect?
  • How do we collect your data?
  • How will we use your data?
  • How do we store your data?
  • Marketing
  • What are your data protection rights?
  • What are cookies?
  • How do we use cookies?
  • What types of cookies do we use?
  • How to manage your cookies
  • Privacy policies of other websites
  • Changes to our privacy policy
  • How to contact us
  • How to contact the appropriate authorities

Test and Trace

Recording customer details: how we use your information
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.

By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.

As a customer/visitor of Clovelly Estate Company you will be asked to provide some basic information and contact details. The following information will be collected:

the names of all customers or visitors, or if it is a group of people, the name of one member of the group
a contact phone number for each customer or visitor, or for the lead member of a group of people
date of visit and arrival time and departure time
The venue/establishment as the data controllers for the collection of your personal data, will be responsible for compliance with data protection legislation for the period of time it holds the information. When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time.

The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.

In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.

NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.

For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a 2-day period).

We may require you to pre-book appointments for visits or to complete a form on arrival.

Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing. Information of this type will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit.

However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number). Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.

Your information will always be stored and used in compliance with the relevant data protection legislation.

The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) – a legal obligation to which we as a venue/establishment are subject to. The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.

By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you.

You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).

You have the right to request that we restrict processing of personal data about you that we hold in certain circumstances.

You have the right to object to processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).

If you are unhappy or wish to complain about how your information is used, you should contact a member of staff in the first instance to resolve your issue.

If you are still not satisfied, you can complain to the Information Commissioner’s Office. Their website address is www.ico.org.uk.

The Data Protection Officer for Clovelly Estate Company is George Smith who may be contacted via gs@clovelly.co.uk for matters pertaining to GDPR.

We keep our privacy notice under regular review, and we will make new versions available on our privacy notice page on www.clovelly.co.uk/privacy-policy. This privacy notice was last updated on 1st October 2020.

What data do we collect?

The Clovelly Estate Company collects the following data:

  • Personal Identification Information (Name, email address, phone number, etc.)
  • Guest reservation and booking data within our hotel Property Management Systems
  • CCTV feeds
  • TicketSource event ticketing

How do we collect your data?

You directly provide The Clovelly Estate Company with most of the data we collect. We collect data and process data when you:

  • Register online or place an order for any of our visitor attractions, products or services.
  • Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
  • Use or view our website via your browser’s cookies.
  • Make a booking or reservation with any of our employees.
  • Image capture via CCTV.

The Clovelly Estates Company may also receive your data indirectly from the following sources:

  • We employ footfall monitoring technology to count the number of visitors to our estate.

How will we use your data?

The Clovelly Estates Company collects your data so that we can:

  • Process your order and manage your account.
  • Email you with special offers on other products and services we think you might like.
  • Process your reservation and manage your reservation
  • Improve our guest and visitor experience
  • Monitor visitor numbers

If you agree, The Clovelly Estates Company will share your data with our partner companies so that they may offer you their products and services.

  • Strategic Inbound
  • TicketSource
  •  
  • When The Clovelly Estate Company processes your order, it may send your data to, and use the resulting information from, credit reference agencies to prevent fraudulent purchases and reservations.

How do we store your data?

The Clovelly Estate Company securely stores your data at The Estate Office, Clovelly, EX39 5TA and in the cloud via Microsoft Office 365. Role based access control and Two Factor Authentication is used to secure data. We also store your data in our hotel management and marketing systems which are also secured with Role based access control and Two Factor Authentication.

The Clovelly Estate Company will keep your Personal Identification Information for six years and your Guest reservation and booking data within our hotel Property Management Systems for six years. Once this time period has expired, we will delete your data by automatically removing it from our CRM and PMS systems.

Marketing

The Clovelly Estate Company would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

If you have agreed to receive marketing, you may always opt out later.

You have the right at any time to stop The Clovelly Estate Company from contacting you for marketing purposes or giving your data to other members of the Clovelly Estate Company Group.

If you no longer wish to be contacted for marketing purposes, please email privacy@clovelly.co.uk.

What are your data protection rights?

The Clovelly Estate Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request The Clovelly Estate Company for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that The Clovelly Estate Company correct any information you believe is inaccurate. You also have the right to request The Clovelly Estate Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that The Clovelly Estate Company erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that The Clovelly Estate Company restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to The Clovelly Estate Company’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that The Clovelly Estate Company transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@clovelly.co.uk

Call us at: 01237 431200

Or write to us: Clovelly Estate Office, Clovelly, Devon, EX39 5TA

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology

For further information, visit allaboutcookies.org.

How do we use cookies?

The Clovelly Estates Company uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Understanding how you use our website
  • For marketing purposes
  • To improve the guest and visitor experience

What types of cookies do we use?

There are several different types of cookies, however, our website uses:

  • Functionality – The Clovelly Estate Company uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
  • Advertising – The Clovelly Estate Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. The Clovelly Estate Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
  • Analytics – The Clovelly Estate Company uses Advanced Google Analytics to build data driven buyer personas for marketing purposes with the intent of improving our products and services and guest and visitor experiences.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The Clovelly Estate Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

The Clovelly Estate Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 5th February 2020.

How to contact us

If you have any questions about The Clovelly Estate Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: privacy@clovelly.co.uk

Call us at: 01237 431200

Or write to us at: Clovelly Estate Office, Clovelly, Devon, EX39 5TA

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that The Clovelly Estate Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Email: complaints@ico.org.uk

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow Cheshire, SK9 5AF.