Last Updated: May 2018
In practice, this means that all personal data which we hold about you will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
By visiting www.cosgrovepark.co.uk
Who We Are
Postal address: Whilton Marina Ltd, Whilton Locks, Daventry, NN11 2NH
Telephone: 01327 842577
Privacy Complaints Procedure
You always have the right to make a complaint to the Information Commissioner's Office (“ICO”) if you think your data is being misused. The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk
We always appreciate the chance to try to deal with any data protection concerns before they are referred to the ICO so, if you are happy to do so, please do not hesitate to contact us using the details above so that we can try to help you out in the first instance.
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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out in the “Contact Details” section 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 where this is required or permitted by law.
Informing us of changes to your Data
It is important that the personal data we hold about you is accurate and current. As such you can use your ‘My Account’ page to amend a number of the details which we hold about you.
Third party links
Our Site may contain links to and from 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. Please check the relevant third-party privacy policies before you submit any personal data to them.
Governing law and jurisdiction
The data we collect about you
“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity of the person concerned has been removed (which is called “Anonymised Data”).
We may collect, use, store different kinds of personal data about you. This can be broken down into the following categories:
• Identity Data includes your name, username or similar identifier, marital status, title, date of birth and gender (this will primarily be text based, but could also include audio, photos, videos and other forms of media).
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
•Technical Data includes the internet protocol (IP) address of your device, details of the cookies on your device, 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 our Site.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, reviews, feedback and survey responses.
• Usage Data includes information about how you use our Site, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing communications from us and your communication preferences.
We do not collect any “Special Category Data” about you. Special Category Data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and information about your health, genetic or biometric data. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
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 our products or services). In this case, we may have to cancel a product delivery or service you have with us (but we will notify you if this is the case at the time).
How we collect your personal data
We use different methods to collect data from and about you including:
You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:
• Information that you provide by filling in forms on our Site, viewing holiday homes and caravans at our Park, buying or selling a holiday home or caravan through us, visiting open days at our park. This includes information provided:
at the time of registering for holiday home/caravan updates
registering to view holiday homes/caravans at our park
when buying or selling a holiday home/caravan through us
When visiting our open days
when contacting us to value your caravan
when subscribing to a newsletter;
through a contact form (whether on our Site or by any other means);
when posting material such as ratings and reviews;
when requesting further services; or
when searching for a holiday home/caravan;
• Social Media: Information that you provide to us on our Social Media pages
• Order details: Information that you provide in relation to an order or a product you have purchased. This includes details of any cards which you have successfully used to purchase products from us.
• Competition details: Information that you provide when you enter one of our competitions or participate in one of our promotions;
• Wi-Fi details: Information that you provide when accessing Wi-Fi services in our Park
• Transaction details: Details of transactions which you carry out with us (whether through our Site or otherwise)
Automated Technologies or Interactions
We may also collect and process the following data automatically when you use our Site
• the internet protocol (IP) address of your device, your login information, details of the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of your device's wireless network interface, or the mobile phone number used by your device), mobile network information, your browser type and version, your time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors and bugs, the length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the Site.
We may use IP addresses or personal data to recognize you when you visit or return to our site so we can track anonymised traffic and usage patterns or to help us improve our site.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:
• we need to perform the contract we are about to enter into or have entered into with you;
• 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 need to comply with a legal or regulatory obligation; and/or
• you have specifically consented to us using your personal data in a particular way.
Do we disclose any information to outside parties?
We do not sell or otherwise trade to outside parties. However that does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law.
Disclosure of your personal data
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others. This includes exchanging information with: (a) the police or other investigatory or law enforcement authorities; and (b) companies and organisations involved in fraud protection and credit risk reduction; and/or
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 particular:
• To secure your personal information, access to your data is password protected. It is your responsibility to keep your password confidential and not to share this information with anyone
.• We are registered with the Financial Conduct Authority (FCA) and meet payment card industry data security standards with Level 1 of PCI DSS certification
• Use of secure technologies (e.g. SSL, encryption)
Please note that transmission of information via the internet can never be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our site
We will only retain your personal data 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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We typically retain this information for a further six to twelve months to ensure that no relevant claim has been made within that six year period before we dispose of it.
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.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us using the details set out in the “Contact Details” section (Overview of this policy and who we are). A summary of the rights you have is set out below:
• Opting-out of Marketing: You can ask us or third-parties to stop sending you marketing communications at any time by: (a) by using the “unsubscribe” link at the bottom of any marketing communications which we send to you; or (c) by contacting us at any time using the details set out in the “Contact Details” section (Overview of this policy and who we are).
• Data Subject Access Requests: You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction: You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Erasure: You have the right to request we erase your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Processing Objection: You have the right to object to us processing your personal data 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 as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.•
Processing Restriction: You have the right to request we restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Data Transfer: You have the right to request we transfer your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdrawing consent: You have the right to withdraw your consent to processing where we are relying on that consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
• 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 any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response
Time limit Response 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