Privacy Policy

“We” or “us” means:

The Gitcombe Estate
Gitcombe House and Country Cottages
Cornworthy
Devon
TQ9 7HH

For the purpose of the Data Protection Laws, we are the data controller unless we inform you otherwise. If you want to request more information about our privacy notice or information regarding data protection you should contact us by email [email protected]. The person responsible for our data protection compliance is Peter O’Brien.

When processing personal data, we are legally obliged to use that data in line with all applicable laws concerning the protection of such information; including but not limited to the Data Protection Act 2018 and the General Data Protection Regulation, as adopted by the UK (UK GDPR), described in this notice as the “Data Protection Laws”.

Please note that:

• our website is not intended for children under the age of 18 but we may collect personal data belonging to children who are guests of the Property (as described below); and
• our 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.

This privacy notice also forms part of our terms of business and is not intended to override them.

We may collect and process the following data about you:

Information you give us

You may give us information about you (or another guest or visitor when you act on their behalf) by filling in forms on our website or by corresponding with us by phone, e-mail, through our social media channels or otherwise. This includes information you provide if you register to use our website, book the Property, subscribe to our services, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our website. The information you give us may include:

• Identity Data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images.
• Contact Data includes billing address, email addresses and telephone numbers.
• Transaction Data includes details about services you have purchased from us or your visits to our premises.
• Other Guest Data: dietary requirements; accessibility requirements, medical conditions; allergies; dependants’ personal information, emergency contact information, information about how you use our Property (including its facilities), our website and services;
• Financial Data includes bank account and payment card details.
• Financial Data includes bank account and payment card details.
• 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. If we ask you to provide any other personal information not described above, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal information.

We do not collect criminal conviction data.

Information we collect about you

We may automatically collect the following information:

• CCTV Data includes data (including but not limited to images, video and sound) gathered by Closed Circuit Television, Automatic Number Plate Recognition and other surveillance technologies which may be installed at the Property;
• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, cookies (please see our cookie policy), your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources

We may receive information about you from third parties such as online travel agents or booking engines. When that data is collected from you, you should be informed by those third parties at that stage that it may be shared internally by us and combined with data collected from multiple sources.

We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Accuracy of information

It is important that the personal data we hold is accurate and current. We cannot be held responsible for any inaccurate or incomplete data on our system arising out of your default in this regard. Please keep us informed if your personal data changes during your relationship with us.

We use information held about you in the following ways:

Information you give to us

We will use your personal data and, where indicated by (*) special category data, to:

• book the Property and register any guests/visitors;
• provide our services (*);
• to ensure our Property is accessible and provide special assistance where necessary(*);
• to record and report an incident or accident occurring at the Property(*);
• manage payments, fees and charges;
• collect and recover money owed to us;
• notify you about changes to our service;
• ensure that content from our website is presented in the most effective manner for you and for your device.
• provide you with information about other services we offer that are similar to those that you have already enquired about or receive from us (where we have a legitimate interest to do so). You may opt-out of these communications at any time using the ‘unsubscribe’ button on each communication; and
• provide you with other marketing materials (by us or third-parties) where you have consented to receive the same. You may withdraw your consent to these communications at any time.

Information we collect about you.

Examples of how we will use this information includes (but is not limited) to;

• administer our services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• improve our website to ensure that content is presented in the most effective manner for you and for your device;
• allow you to participate in interactive features of our services, when you choose to do so;
• keep our services, website, staff, guests and premises safe and secure(*);
• enforce our rights under any contract between us(*);
• measure or understand the effectiveness of our service.

Information we receive from other sources.

We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Lawful bases

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 – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations .
• Legitimate Interest – means in the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 you personal data for our legitimate interests. 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 services 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); and
  – any special category data.
• Legal obligation – We may process your data where we it is necessary for us to do so to comply with the law.

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.

Please see below the list which sets out the categories of recipients of personal data.

• IT Support Services

• Email Provider

• Website Provider

• Secure document disposal service

• Banks

• Online payment providers

• Accountants
• Insurers
• Solicitors

• Software Providers

• Feedback aggregators and collectors

• Couriers

• Marketing Services (Mailchimp, outside the UK/EEA)

We will disclose your personal information:

• to protect your vital interests or those of any other person;
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• to any competent law enforcement body, regulator, government agency, court or other third party if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to exercise, establish or defend our legal rights; or to protect the rights, property, or our safety, the safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We are a member of Premier Cottages, a professional collective of independent luxury cottage owners. Premier Cottages promotes properties on our behalf as well as other luxury cottages. Where you have indicated your consent, we would like to give them your information so that they can contact you about other quality properties that you might like. You may unsubscribe from this service at any time.

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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your data is stored by us in the UK. However, several of our third-party processors are based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. We will either:

• transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• ensure that standard contractual clauses as amended for use by the UK (SCCs) or, International Data Transfers Agreements (IDTAs) as required by law from time to time are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

You have the right (subject to certain restrictions) to request any of the following. We ask that you send such requests to our contact details as listed above:

To be informed – We must make this privacy notice (sometimes referred to as a privacy notice) available to you and be transparent over how we process your data.

Access – You are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of their personal data by making a formal request under the data protection laws. Such requests should be made using the contact details provided in this notice. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will:

• confirm that your data is being processed;
• verify the lawfulness and the purpose of the processing;
• confirm the categories of personal data being processed;
• confirm the type of recipient to whom the personal data have been or will be disclosed; and
• let you have a copy of the data in format we deem suitable or as reasonably required by you.

Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this notice, clearly specifying which data is incorrect or out of date.

Erasure – This is also known as the right to be forgotten. Under Data Protection Laws you have the right to require us to erase your personal data under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this notice.

Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.

Portability – You have the right to obtain the personal data that you have provided to us in a commonly used machine-readable format and reuse it with a different provider.

Object – You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.

Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.

Withdraw consent – Where you have given us consent to process your personal data, you can withdraw that consent at any time either by contacting us using the details set out in this notice, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can.

Please note that:

• in certain circumstances Data Protection Laws may relieve us of some of our obligations to you under the rights summarised above; and
• you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the data protection laws and as summarised above.

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.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients.

In some circumstances you can ask us to delete your data (see below for further information).

We may anonymise your personal data (so that it can no longer be associated with you) for business purposes, in which case we may use this information indefinitely without further notice to you. Aggregated anonymised 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 data to create ‘analytics’ on how our website is used. 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 notice.

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. This version was last updated during February 2023.

If you would like to update any of the information we hold or if you have any questions regarding this Privacy Note, please let us know in by emailing: [email protected]

The Gitcombe Estate, Gitcombe House and Country Cottages, Cornworthy, Devon,TQ9 7HH