Privacy Policy  .

 

1.    Important information and who we are

 

Purpose of this privacy notice

This privacy notice gives you information on how we process personal data we collect from you or that you provide to us.

It is important that you read this privacy notice 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 notice supplements the other notices and is not intended to override them.

 

Controller

Dunloe Estates Limited is the controller responsible for your personal data (collectively referred to as “DEL”, “we”, “us” or “our” in this privacy notice). DEL is a limited liability company registered in England under number 03341498 and our registered office is at 25 High Bannerdown, Bath, BA1 7JZ, England.

 

If you have any questions about this privacy notice, please contact us by email info@sojourn8.com 

We are registered with the Information Commissioner's Office (ICO) as a Tier 1 data controller with registration number ZA749010.

You have the right to make a complaint at any time to the ICO (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 notice and your duty to inform us of changes

This policy may change from time to time. The up to date version will always be available to read on our website and will become effective as soon as it is published. 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.    Information we may collect about you

 

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

  • Identity Data includes your name, title, date of birth, gender, and your job title.

  • Contact Data includes your home and work addresses, email address and telephone numbers.

  • Document Data includes copies of your passport, driving licence, utility bills and bank statements.

  • Financial Data includes your bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

  • Profile Data includes your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us.

 

3.    How is your personal data collected?

 

We may collect data from you in different ways, including:

  • Direct interactions. You may give us your Identity, Contact, Document and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise.

  • Other interactions. You may also provide us with personal data at meetings we have with you, by participating in discussions or social media activities on our website, by giving us your business card or by subscribing to our services or publications.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including advisers acting for another party in a transaction or dispute we are advising you, your professional advisers by conducting searches of publicly available databases or sources including Companies House, the Land Registry, Experian and the electoral register and through social media sites such as LinkedIn, Facebook and Twitter.

 

4.    How we use your personal data

 

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 you have given us your consent,

  • 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, or

  • Where we need to comply with a legal or regulatory obligation under UK or EU law.

 

Purposes for which we will use your personal data

We have set out below a description of all 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:

 

To register you as a new client and verify your identity, including where you are acting as an officer or representative of a company or organisation and we need to register that company or representative as a new client:

  • Performance of a contract with you and to comply with a legal obligation to verify your identity

  • To provide the services you have instructed us on.

  • Performance of a contract with you

 

To manage our relationship with you which will include notifying you about changes to our terms and conditions or our privacy policy and asking you to provide feedback, leave a review or take a survey

  • Performance of a contract with you

  • Necessary to comply with a legal obligation

  • Necessary for our legitimate interests (to ensure you are aware of our current terms and conditions and to keep our records updated

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, research, statistical and survey purposes, system maintenance, support, reporting and hosting of 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 group restructuring exercise)

  • Necessary to comply with a legal obligation

 

To make suggestions and recommendations to you about legal services that may be of interest to you

  • Necessary for our legitimate interests (to develop our services and grow our business)

 

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us (for example, where you have subscribed to our insights, tips and updates) or we have provided services to you or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

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 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.

 

5.    Disclosures of your personal data

 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary

  • 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 notice.

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.

 

6.    International transfers

 

We may transfer your personal data outside the European Economic Area (the "EEA"). For example, this may happen where our servers including those hosting this site are at any time located outside the EEA or where any of our service providers are located outside the EEA. 

 

7.    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.

 

8.    Data retention

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and in accordance with our Terms & Conditions, including for the purposes of satisfying any legal, regulatory, 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.

 

9.    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.

 

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.

 

10.    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 we can. 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).

 

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.

 

THIRD PARTIES

External Third Parties

  • Our bank and auditors.

  • Business partners and suppliers in so far as we consider it reasonably necessary for us to carry out services.

  • Our outsourced IT services providers, providers of IT and system administration and case management services, our email marketing platform provider and our website platform provider.

  • any third party you ask us to share your data with.

 

last updated: April 2020    ...