Privacy Policy
Privacy Policy - Version 3.0 August 2020
Introduction and terms
At Pentillie Castle & Estate we are committed to protecting and preserving the personal data and privacy of our customers when visiting us, visiting our website or communicating (electronically or verbally) with us. Please take a moment to familiarise yourself with our Privacy Policy.
This Privacy Policy relates to how we use and collect personal data from you when you use our website, when you purchase a product or service from us, or when you visit us. It also relates to our use of any personal information you provide to us by telephone, in writing (telephone, messenger, SMS or email), or in person, and the conditions under which we may disclose it to others and how we store it.
Please note that this website and our services are not intended for children under the age of 18 and we do not knowingly collect data relating to children.
Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 1998 and 2018 (DPA), and The General Data Protection Regulation 2016 (GDPR) together, and with other subsequent laws “Data Protection Laws”.
This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page.
How to contact us about this policy
For the purpose of the Data Protection Laws, the data controller is Pentillie Castle & Estate. If you have any questions regarding this policy or wish to request more information regarding data protection you should contact the Privacy Officer using the details provided below:
Pentillie Castle & Estate, Paynter’s Cross, Saltash, Cornwall, PL12 6QD.
Telephone: 01579 350044
Email: contact@pentillie.co.uk
How do we collect information from you?
Our team are aware of the importance of handling data safely and securely and understand the procedures we have in place to ensure this happens.
We collect information from you when you make a booking, use our facilities or our services and make an enquiry about our services via our team either in person, over the telephone or email.
We collect information from you when you complete a wedding brochure download form, make an enquiry and sign up to receive our Newsletters via our website and also when booking online via an OTA such as Booking.com. We also collect information about you when we take a payment from you. This information is required to complete the task in question.
We will ask you to confirm that you are happy to receive communications from us and if you would like to be signed up to our newsletter to receive the latest news and offers from Pentillie Castle. Your acquiescence will not be assumed in any case.
In running and operating our website, we may collect and process certain data and information relating to you and your use of this site. We collect information relating to website users by using cookies (see details below).
We have CCTV installed on the premises in public areas for the purposes of the prevention of crime.
If you connect with us via social media i.e. Facebook or Twitter by ‘liking’ or ‘following’ us we may collect information and data such as your name and details you provide to us when entering a social media competition or poll. Our Privacy Policy applies to all social media activity.
What type of information is collected from you?
The data we collect from you may be classed as ‘personal data’ – information about an individual who can be identified by it.
The information we collect about you might include the following:
Identity Data: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and images.
Contact Data includes billing address, delivery 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, including email correspondence.
Technical Data includes internet protocol (IP) address, 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 this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Please note that we may collect and/or process other personal data from time to time.
We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used solely in accordance with this policy.
We do not collect the following special categories of personal data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
We only collect data from you directly or via third parties (see the section Third Parties below).
Your privacy is important to us and we confirm that we will never sell or release your personal data to any third party for their mailing or marketing purposes without your express permission.
If you fail to provide personal data
Where we need to collect personal data by law, (e.g. Track & Trace rules under Covid-19 national response) 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 services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How will we use your data?
We may use your information…
to carry out our obligations arising from any contracts entered into between you and us, and to provide our services e.g. your booking for accommodation or use of Pentillie
to process your gift voucher purchases;
to provide you with information you have requested from us about our products and services;
for processing entries into a competition;
to seek your views or comments on the services we provide, and to research our services;
to notify you about any changes to our business or website, including improvements, and service or product changes;
to send you communications which you have requested and that may be of interest to you. These may include information about stays, events, promotions, offers, job offers, information about the Castle and the surrounding area and replies to requests and bookings enquiries/confirmations;
if you consent, to notify you via our sales and marketing channels (email, telephone or post) of products or special offers that may be of interest to you. You can stop these communications at any time by unsubscribing or contacting us via telephone or in writing (please see ‘How to opt out’ below);
for our internal purposes including internal record keeping, statistical purposes, quality control, website performance and evaluation, improvements to products and services.
We have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out as per below.
Purpose/Activity –
To register you as a new user and customer.
Type of data – Identity Contact.
Lawful basis for processing including basis of legitimate interest – Performance of a contract with you.Purpose/Activity –
To process and deliver your order including: Manage payments, fees and charges; Collect and recover money owed to us.
Type of data – Identity, Contact, Financial, Transaction, Marketing and Communications.
Lawful basis for processing including basis of legitimate interest – Performance of a contract with you, Necessary for our legitimate interests (to recover debts due to us).Purpose/Activity –
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy, Asking you to leave a review or take a survey.
Type of data – Identity, Contact, Profile, Marketing and Communications.
Lawful basis for processing including basis of legitimate interest – Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)Purpose/Activity –
To enable you to partake in a prize draw, competition or complete a survey
Type of data – Identity, Contact, Profile, Usage, Marketing and Communications.
Lawful basis for processing including basis of legitimate interest – Performance of a contract with you,
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).Purpose/Activity –
To administer and protect our business, this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and our mobile application.
Type of data – Identity, Contact, Technical.
Lawful basis for processing including basis of legitimate interest – Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), Necessary to comply with a legal obligation.Purpose/Activity –
To deliver relevant website and mobile application content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data – Identity, Contact, Profile, Usage, Marketing and Communications, Technical.
Lawful basis for processing including basis of legitimate interest – Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).Purpose/Activity –
To use data analytics to improve our website, mobile application, products/services, marketing, customer relationships and experiences.
Type of data – Technical, Usage.
Lawful basis for processing including basis of legitimate interest – Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).Purpose/Activity –
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of Data – Identity, Contact, Technical, Usage, Profile, Marketing and Communications.
Lawful basis for processing including basis of legitimate interest – Necessary for our legitimate interests (to develop our products/services and grow our business)
Lawful basis for processing data
We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
Contractual obligation – Where processing is necessary to comply with our obligations arising out of a contract, for example, where you have bought products from us we will use the personal data you provide to fulfil our contractual obligations e.g. taking payment /shipping/processing of any licenses.
Legitimate Interest – Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest products or obtaining your feedback on our service.
Consent – We will seek to obtain your consent to process your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above).
Who has access to your information and Third Parties?
We follow procedures in the storage and disclosure of information that you have given to us, to prevent unauthorised access, misuse, alteration or loss of information under our control. Our security measures may mean that we will require proof of identity before we are able to disclose information to you.
We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct. 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.
Please see below the list which sets out the categories of recipients of personal data.
Service providers who may receive your personal data
IT Support Services
Email Provider
Secure document disposal service
Banks
Online payment providers
Accountants
Solicitors
Feedback aggregators and collectors
In addition third parties may provide us with personal data and they should only do so where the law allows them to.
We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes. We only share your information with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis. We may process your personal data without your knowledge or consent where this is required or permitted by law.
Third Party Service Providers working on our behalf: We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process payments i.e. PayPal, Microsoft Cloud for remote email access (Microsoft Cloud Agreement) and Mail Chimp to send you marketing communications). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we ensure their own Privacy Policies are in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Third Party Product Providers we work in association with: We work with carefully selected Online Travel Agents (OTAs e.g. Booking.com). When you enquire about or book with these third parties, the relevant third-party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. They too will be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. These third-party product providers will share required information about you with us (e.g. room type purchased and dates of stay) which we will use in accordance with this Privacy Policy.
When you are using our secure online booking system, your purchase is processed by a third-party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions.
When you give us personal information, we take steps to ensure that it’s treated securely. Once we receive your information, we make our best effort to ensure its security on our systems. We have secure password protected databases.
Whilst we take appropriate measures, both technical and organisational, to safeguard your personal data you provide us, we cannot guarantee that transmissions over the internet are totally secure, therefore the transfer of personal data via the internet is entirely at your own risk.
Retention of information
We will hold your personal information on our systems for as long as is necessary to fulfil the purpose for which it was obtained, or as long as is set out in any relevant contract you hold with us.
Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.
Where your data is held
Your data is stored by us and our processors in the UK, EEA or in a country where an adequacy decision has been made by the European Data Protection Board (EDPB) (e.g. EU-US Privacy Shield). For example, we use Mail Chimp (based in USA) as a platform for email marketing. Please find their Privacy Policy here https://mailchimp.com/legal/privacy/. These countries may not have similar data protection laws to the UK. By submitting your personal data, you are agreeing to this transfer, storing or processing.
Applying to work for us
If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
How do I opt out?
You have a choice about whether or not you wish to receive information from us. We will not make contact with you unless you have opted in. If then, you no longer want to receive direct marketing communications from us about the Castle and offers, then you can change your preferences or completely unsubscribe in one of two ways:
Click the ‘unsubscribe’ or ‘change preferences’ link at the bottom of marketing emails sent to you
Email contact@pentillie.co.uk or telephone 01579 350044 and we will process your request within 7 days
We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted.
Your Rights
Your ‘right to be forgotten’ and access. Under the Data Protection Laws you are legally entitled to access, modify, correct, revoke your consent and delete any data we hold relating to you and that you have the legal right to forbid this data being prevented to any third parties. You have the right to ask for a copy of the information Pentillie Castle holds about you at any time. Please use the contact details below if you would like to receive a copy. If you agree, we will try to deal with your request informally, for example, by providing the information you require via email.
The accuracy of your information is also important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please email us at: contact@pentillie.co.uk or write to us at: Pentillie Castle & Estate, Paynters Cross, Saltash, Cornwall, PL12 6QD. Alternatively, you can telephone 01579 350044.
Use of ‘cookies’
Like many other websites, the Pentillie website uses cookies. A Cookie is a small file of letters and numbers sent by an organisation which asks permission from your browser to be placed on your hard drive to allow that website to recognise when you visit. We only use this information for statistical analysis purposes. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use Google Analytics to research user activities on our website in order to enhance its performance and usability. In the course of conducting this research Google places a First Party session 'cookie' on your browser and collects aggregate information to enable us to see what people view on the website and for how long. The use of cookies enables us to improve our website, deliver effective marketing and offer a more personalised service. You can choose to accept or decline cookies.
It is possible to switch off cookies by adjusting your browser preferences or using a dedicated browser extension.
To find out more about how to manage cookies through your chosen browser go to www.allaboutcookies.org/manage-cookies/
External links to other websites
This privacy Policy applies solely to information and data collected by us. Our website may contain links to other websites run by other organisations over which we have no control, so we encourage you to read the privacy statements on the other websites you visit. We are not responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you were referred to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
Those aged 17 or under
We are concerned to protect the privacy of children aged 17 or under. If you are aged 17 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
Changes
This Privacy Policy is reviewed regularly. We may change this Policy from time to time so please check this page occasionally to ensure that you are happy with any changes. By using our website, you agree to be bound by this Policy. We may display this notice to you from time to time to remind you of its contents.
Complaints
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.
