Castle Howard, Historic House North Yorkshire
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Privacy Statement

Castle Howard Estate Limited (“Castle Howard”, “we”, “us”, “our”) respects your privacy and is committed to protecting and maintaining the security of any personal information we hold about you.

The purpose of this statement is to explain to you what personal information we collect and how we may use it. It is important that you read this statement so that you are fully aware of how and why we are using your data and what your legal rights are. Please keep us informed if your personal data changes during your relationship with us.

For your ease of use this statement is provided in a layered format so to expand and read the relevant section please click on the headings below.


Contact Details

Castle Howard is the controller and is responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this statement. If you have any questions about this statement, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Mr M. Gaynor

mgaynor@castlehoward.co.uk

Castle Howard Estate Ltd, Castle Howard, York, YO60 7DA

Telephone number:01653648444

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.


Third-party links

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.


What personal data do we collect?

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).

We may collect, use, store and transfer the following types of personal data about you:

  • Identity Data: includes photographs, first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • 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.
  • 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 our website.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

For holiday homes, to comply with regulations, we will need proof of identity or proof of residency. This is Special Category Personal Data which we will request directly from you.

Otherwise we do not generally collect any Special Categories of Personal Data about you (this includes 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.

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 goods or 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 do we collect your Personal Data?

We use different methods to collect data from and about you including through direct interactions (for example when placing an order, becoming a Friend of Castle Howard), through automated interactions (for example when using our website or signing up to our e-mail newsletter) and from third parties (for example a tenant referencing agent) or publicly available sources.


How we use the personal data that you provide us with?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have your consent to send you marketing communications and third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data

We have set out below, a description of the ways we plan to 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.

Please 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 below.

Purpose/Activity

Types of personal data

Lawful basis for processing including basis of legitimate interest

To manage your account and register you as a customer.

Identity Data, Contact Data, Billing Data, Interaction Data and Marketing and Communications Data.

Performance of a contract with you.

Necessary for our legitimate interests to keep our records updated.

To process and deliver your order including:

(a)   Manage payments, fees and charges.

(b)   Collect and recover money owed to us.

Identity Data, Contact Data, Billing Data and Interaction Data.

Performance of a contract with you.

Necessary for our legitimate interests to recover debts due to us.

To manage our relationship with you which will include:

(a)   Notifying you about our changes to the terms of our privacy policy.

(b)   Asking you to take a survey or provide feedback.

Identity Data, Contact Data, Feedback Data and Marketing and Communications Data.

Performance of a contract with you.

Necessary to comply with a legal obligation (data protection law).

Necessary for our legitimate interests to keep our records updated and to study how you use our products/services.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

Identity Data, Contact Data and Technical Data

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 restructuring exercise).

Necessary to comply with a legal obligation.

To deliver relevant website content to you and to measure or understand the effectiveness of our website

Identity Data, Contact Data, Marketing and Communications Data and Technical Data

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)

To email you about products or services that we think may be of interest to you.

Identity Data, Contact Data, Interaction Data, Feedback Data and Marketing and Communications Data

Necessary for our legitimate interests to promote our business

To register you on our The Friends Scheme

Your photograph to print on your membership card, your Identity Data, Contact Data. Financial Data and Transactional Data

Performance of a contract with you.

Necessary for our legitimate interests to keep our records updated.

Purchasing online tickets

Your Identity Data, Contact Data and Financial Data.

Performance of a contract with you.

Necessary for our legitimate interests to keep our records updated.

To obtain your tickets for pre-booked events

Your Identity Data, Contact Data. Financial Data.

Performance of a contract with you.

Necessary for our legitimate interests to keep our records updated.

When on our Estate to use holiday homes, motorhomes, caravans and camping

Your Identity Data, Contact Data. Financial Data and Transactional Data. For holiday homes, in order to comply with our Site Licence and Planning Permission from Ryedale District Council, we will also collect evidence of permanent residency

Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests to keep our records updated.

When you are a tenant of our Estate

Your Identity Data, Contact Data. Financial Data and Transactional Data. You may also be required to complete a third party tenant referencing form for a tenant referencing agent who is authorised and regulated by the Financial Conduct Authority (FCA).

Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests to keep our records updated.


Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may contact you (by email or post) with information about our products, services, promotions, any future events and to send regular newsletters after every transaction. Every communication from Castle Howard will also give you the option to review these choices online or by post.

You can also let us know if you would like us to contact you by visiting our Marketing Options Form.

You can unsubscribe at any time to our e-newsletter, either follow the link in the e-newsletter or unsubscribe here.

We will always treat your personal information with the greatest of care.  We will never sell or transfer them to other companies or organisations for marketing purposes without your permission.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy page.


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 contact details set out 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, in compliance with the above rules, where this is required or permitted by law.
Who do we disclose your personal data to?

We may have to share your personal data with the parties set out below for the purposes set out in the table in above:

  • External Third Parties as set out in the Glossary;
  • Specified Third Parties such as Ryedale District Council, tenant referencing agencies and a third party booking and management company (registered in the United Kingdom);

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.


Where do we transfer your personal data to?

We do not transfer your personal data outside of the European Economic Area.


How long do we keep your 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.

For short stay motorhomes, caravans and camping this information will be destroyed 14 days after departure.
How do we look after your personal data?

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.
Your data rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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 deletion of personal data we hold about you in certain circumstances: 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 the way we use 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.

Restrict the way in which we use your personal data in certain circumstance:. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

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

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 to respond

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 keep you updated.
Glossary

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/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 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 using the contact details set out above.

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.

EXTERNAL THIRD PARTIES

  • Service providers acting as a processor based in the United Kingdom who provide IT, website and system administration services.
  • Professional advisers acting as processors based in the United Kingdom including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

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