Introduction

Welcome to the Somerleyton Group’s Privacy Policy. This Privacy Policy explains how personal data is collected and used by all Somerleyton Estate businesses, including Crossley Farms Limited, Fritton Lake Limited, Somerleyton Marina Limited, Herringfleet Limited, Hotchip Limited, Somerleyton Hall & Gardens, Somerguns, Blocka Farms, the Trustees of the 1971 Settlement and other businesses or commercial entities that are operated by or in connection with the Somerleyton Estate from time to time (together referred to in this Privacy Policy as “Somerleyton Group”, “we”, “us”, “our”).

The Somerleyton Group respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

1. Important information and who we are
2. Data protection principles
3. The data we collect about you
4. Disclosures of your personal data
5. International transfers
6. Data security
7. Data retention
8. Your legal rights
9. Glossary

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how the Somerleyton Group collects and processes your personal data, including any data you provide when you visit Somerleyton Hall, book a wedding or private party with us, attend an event at Somerleyton Hall, purchase or make an enquiry about a retreat at Fritton Lake, book a holiday at Fritton Lake, subscribe to day membership of Fritton Lake, sign-up for an activity with us, moor your vessel with us at the marina, bring your vessel in for repair at the marina, book a table at the The Fritton Arms, make an enquiry about any of our businesses (including Somerleyton Hall, Fritton Lake and the Fritton Arms), rent an estate property and any data that you may provide through this website when you sign-up to receive our newsletter, leave a review or feedback, contact us for more information about our services or manage your marketing preferences. Please see theGlossary section for an explanation of the meaning of “personal data” and “personal information”

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

Under data protection legislation, we are the controller and responsible for your personal data.
We have appointed a data compliance manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 8 below), please contact the data compliance manager using the details set out below.

Contact details

Name: Alison Edwards, Estate Secretary
Email address: clubsecretary@frittonlake.co.uk
Postal address: The Estate Office, Manor Barn, St. Olaves Road, Lovingland, Suffolk NR32 5QS
Telephone number: 01502 734901

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 25th May 2018.

We keep this Privacy Policy under regular review and may amend it from time to time. Please check back regularly to view the latest version. Hard copies of this Privacy Policy are available from us on request.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. Data protection principles

The Somerleyton Group adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:

• Processed lawfully, fairly and in a transparent manner.
• Collected only for specified, explicit and legitimate purposes.
• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
• Accurate and where necessary kept up to date.
• Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.
• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
• Not transferred to another country without appropriate safeguards being in place.
• Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.
• We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

3. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you:

• visit Somerleyton Hall;
• book a wedding or private party with us;
• attend an event at Somerleyton Hall;
• purchase or make an enquiry about a retreat at Fritton Lake;
• book a holiday at Fritton Lake;
• subscribe to day membership at Fritton Lake;
• sign-up for an activity with us;
• moor your vessel with us at the marina;
• bring your vessel in for repair at the marina;
• book a table at The Fritton Arms;
• make an enquiry about any of our businesses (including Somerleyton Hall, Fritton Lake and the Fritton Arms);
• rent an estate property;
• sign-up for our newsletter on this website;
• leave a review or feedback;
• contact us for more information about our services; and
• manage your marketing preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect 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 in accordance with this Privacy Policy.

Only on very rare occasions will we collect and process any Sensitive Personal Data (as defined in the Glossary) about you. For example, we may need to collect information about your health in connection with your participation in certain activities on our premises for health and safety reasons. In these circumstances, we will ensure to collect and process any such Sensitive Personal Data in compliance with data protection laws.

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 (for example, to provide the services you have requested), 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. In these circumstances, we may have to terminate our contract with you, but we will notify you if this is the case at the time.

The below table provides a summary of how we collect and process your personal data:

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 in the table above.

Marketing

We will only contact you by e-mail or text message for marketing purposes if you have given us your opt-in consent to do so. Please note that we will continue contacting you in connection with any contract that we have with you, including any services that you have purchased or upcoming bookings. We will also continue contacting you to provide you with our newsletter if you have signed-up to receive it.

We will not share your information for marketing purposes with any company or other entity outside the Somerleyton Group, unless we have your opt-in consent to do so.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time or by clicking the “unsubscribe” button in the relevant e-mail.

We do not and will not sell any of your personal data to any third party.

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.

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, in compliance with the above rules, where this is required or permitted by law.

Automated decision-making and profiling

We do not carry out any automated decision-making or profiling.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

• Other entities within the Somerleyton Group for general administrative and operational purposes, or marketing purposes if you have given us your opt-in consent.
• Service providers who provide IT, software, marketing, advertising and system administration services.
• Our booking agents, for the purposes of administering your booking with us.
• Third party agencies, such as credit reference agencies and fraud prevention agencies, for fraud prevention and detection purposes.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, accountants, insurers and other third parties based who provide legal, banking, consultancy, accounting, insurance and other related services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We do not transfer your personal data outside the European Economic Area (EEA)

6. Data security

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 addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

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.

Details of retention periods for different aspects of your personal data are available on request by contacting us.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

9. Glossary

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

LAWFUL BASIS

“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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.

Request erasure of 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of 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.

Request the transfer of 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.

Withdraw consent at any time where we are relying on 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.