Hurlston Hall is a company registered in England and Wales.
Maintaining the security of your data is a priority and we are committed to respecting your privacy rights. We will handle your data fairly and legally at all times. We are also committed to being transparent about what data we collect about you and how we use it.
This policy which applies to whatever interaction you have with us and provides you with information about:
- How we use your data
- What personal data we collect
- How we ensure that your privacy is maintained
- Your legal rights relating to your personal data
2. HOW WE USE YOUR DATA
2.1 We and also our trusted partners acting on our behalf use your personal data:
- To provide goods and services to you
- To make a tailored website available to you
- To manager any accounts that you may hold with us
- To verify your identity
- For crime and fraud prevention, detection and related purposes
- With your agreement to contact you electronically about any promotional offers/products and services we think may interest you
- For market research purposes, to help understand your needs
- To enable interactions between us and you
- Where we have a legal right or duty to use or disclose your information (e.g. in a legal dispute)
2.2 Promotional communications
We may use your data for electronic marketing purposes (with your consent) and may send postal mail to update you with our latest offers.
We only aim to update you on products and services which are of interest and relevance to you as an individual.
You have the right to opt out of receiving promotional communications at any time by contacting us via the contact details set out in this policy.
2.3 Sharing data with third parties
In order to make certain services available to you we may need to share your personal data with some of our service partners, these include IT and Marketing.
We only allow our service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security which means that they can only use your data to provide services to us and you and for no other purpose.
Other third parties
Aside from service providers we will not disclose your personal data to any third parties, except as set out below and we will never sell or rent our customer data to other organisations for marketing purposes.
We may share data with:
-credit reference agencies where necessary for card payments
-government bodies, regulators, law enforcement agencies, courts/tribunals and insurers where required to do so:
- -to comply with our legal obligations
- -to exercise our legal rights
- -for the prevention, detection, investigation of crime or prosecution of offenders
- -for the protection of our employees and customers
How long do we keep data?
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years.
3. WHAT PERSONAL DATA WE COLLECT
We may collect the following information about you:
- Your name, age/date of birth and gender
- Your contact details – postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and email addresses
- Purchases and orders made by you
- Your on line browsing activities on the website
- When you make a purchase or place an order, your payment card details
- Your communication and marketing preferences
- Your location
- Your interests, preferences and feedback
- Your correspondence and communications with us
Our website(s) are not intended for children and we do not knowingly collect data relating to children. This list is not exhaustive, and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our websites or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
4. HOW WE PROTECT YOUR DATA
4.1 Our controls
We are committed to keeping your personal data safe and secure.
Our security measures include: -
- - encryption of data;
- - regular cyber security assessments of all service providers who may handle your personal data;
- - regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
- - testing of systems;
- - security controls which protect our IT infrastructure from external attack and unauthorised access; and
- - internal policies setting out our data security approach and training for employees.
5. WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
We will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from us asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety: -
- - keep your account passwords private. Remember, anybody who knows your password may access your account.
- - when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password. You can do this accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.
- - avoid using the same password for multiple online accounts.
6. YOUR RIGHTS
You have the following rights:
- - the right to ask what personal data that we hold about you at any time;
- - the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
- (as set out above) the right to opt out of any marketing communications that we may send you.
If you wish to exercise any of the above rights, please contact us using the contact details set out below.
Legal basis for Hurlston Hall processing customer personal data
Hurlston Hall collects and uses customers’ personal data because is it necessary for:
- - the pursuit of our legitimate interests (as set out below);
- - complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email or text message.
Members have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing members data, is that it is necessary for the legitimate interests of Hurlston Hall, including: -
- - selling and supplying goods and services to our customers;
- - protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- - promoting, marketing and advertising our products and services;
- - sending promotional communications which are relevant and tailored to individual customers;
- - understanding our customers’ behaviour, activities, preferences, and needs;
- - improving existing products and services and developing new products and services;
- - complying with our legal and regulatory obligations;
- - preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
- - handling customer contacts, queries, complaints or disputes;
- - protecting us, our employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Hurlston Hall;
- - effectively handling any legal claims or regulatory enforcement actions taken against Hurlston Hall; and
- - fulfilling our duties to our customers.
7. CONTACT INFORMATION
If you have any questions about how we use your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:
You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.