1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About Us
Our Site is owned and operated by Wyvern Enterprises Ltd, a limited company registered in England under company number 07726279. Registered address: Kilver Court, Kilver Street, Shepton Mallet, Somerset, BA4 5NF. Main trading address: Kilver Court, Kilver Street, Shepton Mallet, Somerset, BA4 5NF.
VAT number: 132062852.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which We will always work to uphold:
b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We have. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
- your name, age/date of birth and gender;
- your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- purchases and orders made by you; - your on-line browsing activities on Our Site and your IP Address, web browser type and version, operating system;
- your password(s);
- when you make a purchase or place an order with us, your payment card details;
- your communication and marketing preferences;
- your interests, preferences, feedback and survey responses; - your location;
- your correspondence and communications with us; and
- other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page or post).
Our Site is not intended for children and We do not knowingly collect data relating to children.
This list is not exhaustive and, in specific instances, We may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you sign up to our mailing list on Our Site, or send an email to our company, or when you ‘like’ or ‘follow’ Kilver Court on social media platforms. Other personal data is collected indirectly, for example your browsing activity, further details provided in Part 14. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
We also receive personal data from trusted third parties who provide services to our customers under the Sharpham Park Partnership.
7. How Do You Use My Personal Data?
Under the GDPR, We must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- communicating with you. This may include sending emails to you via our mailing list, or responding to emails or calls from you.
- to verify your identity;
- to provide goods and services to you;
- personalising and tailoring our products and services to you;
- to provide and manage your access to Our Site;
- personalising and tailoring your experience of Our Site;
- to manage any registered account(s) that you hold with us;
- for crime and fraud prevention, detection and related purposes;
- with your agreement, to contact you electronically about promotional offers and products and services which We think may interest you (you may unsubscribe or opt-out at any time by clicking on the ‘Unsubscribe’ link within emails or making contact with firstname.lastname@example.org );
- for market research purposes to better understand your needs; and
- where We have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
If you subscribe to the mailing list or become a member of the Friends of Kilver Court We may collect data directly from you, as well as analysing your browsing and purchasing activity, both on-line and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allows us to ensure that We contact you with information on products and offers that we believe are relevant to you. To do so, We use software and other technology (automated processing).
With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, or post with information, news, and offers on our products or services. We work with the intention of fully protecting your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.
8. How Long Will You Keep My Personal Data?
We will not retain your data for longer than is necessary for the purposes set out in this Policy. We aim to keep your personal data for use in respect of marketing communications for as long as you continue to interact with us (for example, if you visit our website or read or click on an email We send you, or attend an event We host). If We do not have any interaction with you for three years, We will endeavour to contact you to see if you still want to receive marketing communications. If We do not hear from you (or if you tell us, at any time, that you no longer want to receive communications) then We will delete your personal data from our records. There may be some personal data We only need to collect in order to provide you with a particular service. We will delete such personal data as soon as the relevant service has been completed. We may still retain your preferences about the way the service was delivered so that We can improve your experience next time. Where you unsubscribe from our marketing communications, in order to demonstrate that you have been unsubscribed We will add your email address to our exclusion list and will not contact you again. We will also delete any additional information that We hold about you.
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR. We store your information in a secure marketing database hosted by a third party which We use to also generate our email marketing campaigns. We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information, however, please note that no system is ever completely secure.
10. Do You Share My Personal Data?
In order to make certain services available to you, We may need to share your personal data with some of our service partners. These include IT and marketing service providers to provide customer insight through the analysis of data and to collect personal data on our behalf. We store your information in a secure marketing database hosted by a third party which We use to also generate our email marketing campaigns.
If any of your personal data is required by a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may also share your data during the course of the transfer or sale of our business or its assets to one or more third parties. In this situation we will ensure that your data is only provided to a third party on the undertaking that it will be used in accordance with the original consent provided to us when you provided us with your data i.e., for the purposes of marketing Kilver Court.
We only allow our service providers to handle your personal data when We have confirmed that they apply appropriate data protection and security controls.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, We aim to give you controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and, at the point of providing your details).
12. Can I Withhold Information?
13. How Can I Access My Personal Data?
If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use upon request. You do not have to use this form, but it is the easiest way to tell us everything We need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 working days and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.
14.1 Strictly Necessary Cookies
These cookies are necessary to operate Our Site. They do not store any personally identifiable information. You can set your browser to block or alert you about these cookies, but Our Site will not work properly without these cookies.
14.2 Performance Cookies
These cookies collect information in an anonymous manner about how visitors use Our Site and how Our Site performs. These cookies allow us to recognise and count the number of visitors and help us understand which pages are the most popular and where visitors spend most of their time.
14.3 Functional Cookies
These cookies enable Our Site to provide enhanced functionality and personalisation, such as remembering choices you make or information you provide, what region you are in, your login information, or the pages you have viewed. They may be set by us or by third-party providers whose services We have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
14.4 Targeting Cookies
These cookies allow us to deliver advertisements that are relevant to you and your interests. They may be used by us and our advertisers to build a profile of your interests and show you relevant advertisements on other sites. These cookies may track whether you clicked on an advertisement in order to limit the number of times you see a particular advertisement and help us understand the efficacy of our advertising campaigns. They do not directly store personal information, but uniquely identify your browser and device. If you do not allow these cookies, you will experience less targeted advertising.
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to obtain a subject access request form or to make a subject access request, please use the following details (for the attention of the Facilities Manager): Email address: email@example.com. Telephone number: 01749 340 439. Postal Address: Kilver Court, Kilver Street, Shepton Mallet, Somerset BA4 5NF.