We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA), and The Swiss Federal Act on Data Protection 1992 (FDPA).
It would be helpful to start by explaining some key terms used in this policy:
|Any information relating to an identified or identifiable individual|
Special category personal data
|Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify an individual)
Data concerning health, sex life or sexual orientation
|Data subject||The individual who the personal data relates to|
Personal data we collect about you
We may collect and use the following personal data about you:
- Your name and contact information, including email address and telephone number
- Your gender
- Your billing information, transaction and payment card information
- Your personal or professional interests or preferences
- Information about how you use our website, IT, communication and other systems
We collect and use this personal data to provide products and/or services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing these products and/or services to you.
How your personal data is collected
We collect most of this personal data directly from you, in person, by telephone, text or email and/or via our website when you enquire about or make a booking, or get in touch with us. However, we may also collect information:
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason to do so. These reasons are:
- Where you have given consent;
- To comply with our legal and regulatory obligations;
- For the performance of a contract with you or to take steps at your request before entering into a contract; or
- For our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate
interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
|What we use your personal data for||Our reasons|
|Providing products and/or services to you||To perform our contract with you or to take steps at your request before entering into a contract|
|Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, which are to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, which are to be as efficient as we can so we can deliver the best service to you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, which to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business, including in relation to our financial performance, customer base, product or service range or other efficiency measures.||For our legitimate interests or those of a third party, which are to be as efficient as we can so we can deliver the best service to you at the best price|
|Preventing unauthorised access and modifications to systems||
For our legitimate interests or those of a third party, which are to prevent and detect criminal activity that could be damaging for you and/or us
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||To perform our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, which are to make sure that we can keep in touch with our customers about existing orders and new products|
Marketing our services and those of selected third parties to: existing and former customers; third parties to:
|For our legitimate interests or those of a third party, which are to promote our business to existing and former customers|
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, and will only process such personal data where:
- We have your explicit consent;
- The processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
- Or the processing is necessary to establish, exercise or defend legal claims.
We may use your personal data to send you updates by email about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- Contacting us at firstname.lastname@example.org
- Using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences in the future, for example if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it or share it with other organisations outside the Thornicroft Lodge group of companies for marketing purposes.
Who We Share Your Personal Data With
We routinely share personal data with:
- Companies operating under the Thornicroft Lodge brand;
- Third parties we use to help deliver our products and/or services to you, e.g.
- Other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
- Third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- Disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations; or
- Share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring; usually information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where Your Personal Data Is Held
Personal data may be held at our offices and those of our group companies, third party service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will keep your personal data while you use our website or we are providing products and/or services to you. Thereafter, we will keep your personal data for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly;
- To keep records required by law.
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA:
- With our offices or other companies within our group located outside the UK/EEA;
- With our service providers located outside the UK/EEA;
- If you are based outside the UK/EEA; or
- Where there is another international dimension to the services we are providing to you.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- The UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- There are appropriate safeguards in place such as approved standard contractual clauses or certification schemes, together with enforceable rights and effective legal remedies for data subjects; or
- A specific exception applies under data protection law.
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country where an exception applies under relevant data protection law, including where:
- You have explicitly consented to the proposed transfer after having been informed of the possible risks;
- The transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- The transfer is necessary for a contract in your interests, between us and another person; or
- The transfer is necessary to establish, exercise or defend legal claims.
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
You have the following rights, which you can exercise free of charge:
- Be provided with a copy of your personal data.
- Require us to correct any mistakes in your personal data.
- Require us to delete your personal data in certain situations.
- Require us to restrict the processing of your personal data in certain situations.
- Receive the personal data you provided to us in a structured, commonly used and machine readable format and/or transmit that data to a third party in certain situations.
- Object to our processing of your personal data, at any time for direct marketing, and in certain situations when we process your data for our legitimate interests.
- Not to be subject to a decision solely based on automated processing that would significantly affect you.
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please:
- Email, call or write to us (see below: ‘How to contact us’); and
- Provide enough information to identify yourself, for example your full name, address and booking reference and any additional identity information we may reasonably request from you;
- Let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner in the UK or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint.