PUBLIC PRIVACY NOTICE
The owners and management of The Half Moon Elloughton are committed to safeguarding the privacy of our customers, website visitors and other individuals with whom we deal. This policy sets out information about how we use, store and transfer personal data relating to those individuals.
The Half Moon Elloughton has a responsibility to ensure that your personal data is protected, which we take very seriously, and we’re committed to keeping your information safe and secure.
Information we collect about you:
a) Usage data: to ensure that our website is useful to all visitors and continues to improve, we may process data about your use of the site. This may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. This data, obtained through Google Analytics, is anonymised and contains no information pertaining to any identifiable individual; as such, it is not personal data per se, but we have referred to it here for your information.
b) Correspondence data: we may process information contained in or relating to any communication that you send to us, whether through the site, by email, through social media, or otherwise. This may include the communication content and metadata associated with the communication, as well as any contact details you provide to us, such as your name, email address, phone number, job title, address or social media username. We process correspondence data for the purposes of communicating with you and record-keeping.
c) Enquiry data: we may process information contained in any enquiry you submit to us indicating your interest in our services or business, such as the contents of your enquiry and any contact details you provide to us, such as your name, email address, phone number, job title or address. We process such data for the purposes of addressing your enquiry.
d) Transaction data: we may process information relating to transactions, such as bank account details, contact details, or transaction data in relation to payments made by us to you or by you to us. This may include your contact details, or any bank account or sort code information provided for the purposes of making payment, as well as transaction details (such as POs or invoices). The transaction data may be processed for the purpose of supplying or receiving and administering the relevant services and keeping proper records of those transactions, and for making and receiving payments.
e) Personal data we obtain from others: your personal data may be provided to us by someone other than you—for example, by your employer, by an organisation with whom you and we are both dealing, or by someone who wishes to refer you to us or vice versa. Normally this data will be correspondence data or enquiry data as described above and will be processed by us for the purposes described above.
We process personal data on lawful bases only. In particular, we process personal data on the following lawful bases identified in Article 6 of the General Data Protection Regulation:
a) for the performance of a contract with you, or to take steps at your request prior to entering into a contract with you (Article 6(1)(b) GDPR). This may be our basis for processing correspondence data, enquiry data and transaction data;
b) for our legitimate interests (Article 6(1)(f) GDPR). This may be our basis for processing:
i) correspondence data (as we have an interest in properly administering our business and communications);
ii) enquiry data (as we have an interest in developing our business with interested parties);
iii) transaction data (as we have an interest in making and receiving payments promptly and in recovering debts);
In addition to the specific purposes for which we may process your personal data set out above, we may process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject (Article 6(c) GDPR), or in order to protect your vital interests or the vital interests of another individual (Article 6(d) GDPR).
Your rights
The rights you have under data protection law are summarised below. Some of these are complex, and not all of the details have been included here. Further guidance can be obtained from your data protection authority—e.g. in the UK, the Information Commissioner’s Office (www.ico.org.uk)
Your principal rights under data protection law are the right to:
a) access;
b) rectification;
c) erasure;
d) restrict processing;
e) object to processing;
f) data portability;
g) complain to a supervisory authority.
Access: You have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
Rectification: You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
Erasure: In some circumstances you have the right to the erasure of your personal data. These might include if:
a) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; or
b) the processing is for direct marketing purposes.
However, there are certain general exclusions of the right to erasure, for example where processing is necessary for compliance with a legal obligation or in connection with legal claims.
Restriction: In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted on this basis, we may continue to store your personal data and will observe the restrictions on processing except in the case of processing permitted by applicable law (for example, in connection with legal claims or for reasons of public interest).
Objection: You have the right to object to our processing of your personal data on the basis of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless the processing is for legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
Portability: To the extent that the legal basis for our processing of your personal data is consent, or the performance of a contract with you, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
Complaints: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
You may exercise any of your rights in relation to your personal data by written notice to us.
Providing your personal data to others
We will not disclose your data to any third party other than disclosing your personal data where it is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.
If any part of our business or operations is sold or transferred to, or integrated with, another organisation, your personal data may be disclosed to that organisation.
Data security
We have 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 who have a business need to know. They will process your personal data only on our instructions and they are subject to a duty of confidentiality.
Retaining and deleting personal data
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain and delete your personal data as follows:
a) usage data (which is anonymised, and not personal data) may be retained by us indefinitely;
b) enquiry and correspondence data which does not relate to a business relationship with us will be retained for the period of the enquiry or chain of correspondence and then deleted after 12 months;
c) transaction data, and enquiry and correspondence data which relate to a business relationship with us will be retained for six years after delivery of the relevant service or transaction or the end of the relationship.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. For example, certain project and transaction data will be retained for longer than six years in order to comply with HMRC or other tax reporting obligations.
Amendments
We may update this Notice from time to time by publishing a new version on the site and therefore recommend that you check occasionally to ensure you are happy with any changes to this Notice.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. A ‘persistent’ cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a ‘session’ cookie will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
Third parties and security
Our website may, on occasions, contain links to third-party website and refer to third-party service provider and other entities. If you follow a link to any third-party website or deal with any third party entity referred to on the site, then you should note that these third parties may have their own privacy and cookie policies, and that we are not responsible for their use of any personal data which you may provide to them. You should ensure that you have read and understood any relevant policies.
Transmission of data
Although we do our best to ensure the security of personal data provided to us (and to use only reputable service providers), any transmission of data to us via the Internet is by its nature insecure and we cannot guarantee the security of any personal data you provide to us, during transmission. Once we have received your information we use strict procedures and security features to prevent unauthorised access.
Data Controller
For the purposes of the Data Protection Act 1998 and the General Data Protection Regulations 2018 the data controller is David Shipp, Trading as The Half Moon Elloughton, 61 Main Street, Elloughton, HU15 1HU.
Any queries relating to this document or requests to exercise your rights in respect of personal data should be made in writing using the details above.