Welcome to the
Huxham Barns’ privacy notice.
This privacy notice provides information on how we collect and process your personal data when you visit our website, visit/rent a space in Huxham Barns or supply services to us.
In this notice we will refer to our tenant and guarantors. These references shall include any data subjects who are employees or workers of the same (if the tenant or guarantor is a corporate entity).
1. Important information and who we are
James Maunder a sole trader trading as “Huxham Farming” is the controller and responsible for your personal data.
If you have any questions about this privacy notice or our data protection practices, please contact James using the information below.
CONTACT DETAILS
Our full details are:
Full name of legal entity:
James Maunder trading as Huxham Farming
Email address:
james@huxhamfarming.co.uk
Postal address:
Huxham Farming
Huxham Barton
Huxham
Exeter, EX5 4EJ.
Telephone number: 07703 062702
We are registered with the ICO to process personal data. 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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 4th February 2019.
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 policy of every website you visit.
2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, username, password, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank accounts details, business accounts and other financial records.
Transaction Data includes details about payments to and from you.
Technical Data includes internet protocol (IP) address, 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 this website.
Usage Data includes information about how and when you use our website, including the time and date you access our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Security Data including CCTV footage of data subjects.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect 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 in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you.
3. How is your personal data collected?
We use different methods to collect data from and about you including:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Enquiry about Huxham Barns;
Request Huxham Barns marketing materials to be sent to you; or
Manage your tenancy and occupation of Huxham Barns.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Identity and Contact Data from our website contact form via our fully-managed cloud host, Squarespace Inc. based outside the EU (USA);
Technical Data from analytics providers such as Google and Squarespace based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Lloyds Bank plc based inside the EU;
Identity, Contact, Financial, Transaction, Marketing and Communications Data from Letting and Management Agents retained by us to arrange/maintain tenancies based inside the EU.
4. How we use your personal data
We have set out below, in a table format, 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.
Please contact us if you need details about our data processes.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest (see details on each Lawful Basis below)
TENANTS
To register your enquiry
Identity
Contact
Performance of a contract with you
To act as Landlord under a Tenancy Agreement:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Identity
Contact
Financial
Transaction
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 changes to our terms or privacy policy
Identity
Contact
Performance of a contract with you
Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity
Contact
Technical
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 log you into the tenant area of the website.
Identity
Performance of a contract with you
To use data analytics to improve our website, marketing, customer relationships and experiences
Technical
Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Guarantors
To manage our relationship with you as an acting guarantor of a tenant, including administration of debt recovery.
Identity
Contact
Financial
Transaction
Performance of a contract with you (as guarantor under a tenancy agreement).
Marketing
To provide marketing material on Huxham Barns to those that have registered their interest.
Marketing and Communications
Necessary for our legitimate interests (to develop and grow our business)
Security
To prevent crime on Huxham Barns and protect the wellbeing of tenants and visitors of Huxham Barns.
Security Data
Performance of a contract with you
Necessary for our legitimate interests (to deter criminal activity on the car park and help detect crimes which have been committed at Huxham Barns);
Suppliers and Contractors
To engage third party suppliers and contractors for the ongoing maintenance of Huxham Barns and Huxham Farming as a business.
Identity
Contact
Financial
Transaction
Performance of a contract with you
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party, not already listed in this notice, for marketing purposes.
Opting out
You can ask us to stop sending you marketing materials at any time by letting us know at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for another purpose, such as processing you as a tenant.
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.
We use the following cookies:
Duration
Cookie Name
Duration
Purpose
Crumb
Session
Functional/ Required
Prevents cross-site request forgery (CSRF). CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.
RecentRedirect
30 minutes
Functional/ Required
Prevents redirect loops if a site has custom URL redirects. Redirect loops are bad for SEO.
Locked
Session
Functional/ Required
Prevents the password-protected screen from displaying if a visitor enters the correct site-wide password.
SiteUserSecureAuthToken
3 years
Functional/ Required
Authenticates a visitor who logs into a customer account
squarespace-popup-overlay
Persistent
Functional/ Required
Prevents the Promotional Pop-Up from displaying if a visitor dismisses it
squarespace-announcement-bar
Persistent
Functional/ Required
Prevents the Announcement Bar from displaying if a visitor dismisses it
Test
Session
Functional/ Required
Investigates if the browser supports cookies and prevents errors.
ss_cid
2 years
Analytics/Performance
Identifies unique visitors and tracks a visitor’s sessions on a site
ss_cvr
2 years
Analytics/Performance
Identifies unique visitors and tracks a visitor’s sessions on a site
ss_cvisit
30 minutes
Analytics/Performance
Identifies unique visitors and tracks a visitor’s sessions on a site
ss_cvt
30 minutes
Analytics/Performance
Identifies unique visitors and tracks a visitor’s sessions on a site
ss_cpvisit
2 years
Analytics/Performance
Identifies unique visitors and tracks a visitor’s sessions on a site
ss_cookieAllowed
30 days
Analytics/Performance
Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies
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 share your personal data with third parties such as:
Letting or Management Agents acting as processors or joint controllers, currently Stratton Creber Commercial, 20 Southernhay West, Exeter, EX1 1PR.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Studio Zumfelde or any other marketing agency as determined by us, acting as processor based in the United Kingdom who provide marketing and advertising services.
We may also share the following Data for the following reasons:
Tenant Identity and Contact Data of an existing or former tenant:
to suppliers, contractors and utility companies to perform our ongoing contractual obligations (such as repair and maintenance);
to utility companies to set them up as a recipient of services or inform them of a tenant vacating Huxham Barns; or
to a relevant local authority for the correct administration of rates and any other tax and legal need.
Identity Data, Contact Data and Transaction Data of a tenant and that has vacated Huxham Barns leaving rent arrears to the tenant’s guarantor (if applicable), tracing agent or debt collector to help us recover money owed.
Identity Data, Contact Data and Transaction Data of a Guarantor if their associated tenant has vacated Huxham Barns leaving rent arrears to the tenant’s guarantor (if applicable), tracing agent or debt collector to help us recover money owed.
All personal data held by us to whom we may choose to sell, transfer or merge parts of our business or our assets in the future. 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 policy.
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. CCTV
We operate an external CCTV system at Huxham Barns in all external communal areas.
We password protect and securely store Security Data for 30 days. We deem this period of storage necessary to meet the purpose of recording them, as outlined in the table above.
This retention period can be extended by way of sufficient risk assessment determining that a longer retention is necessary.
You have the right to see CCTV images of you and, if reasonable, ask for a copy of them. If requested, we must provide this within 30 calendar days. This is called a Subject Access Request. You will need to provide details to help us to establish your identity as the person in the pictures, and to help us find the images on their system.
We will not disclose images of identifiable people to the media - or put them on the internet - for entertainment. Images released to the media to help identify a person are usually disclosed by the police.
We do not share Security Data directly with tenants, however we will share Security Data with law enforcement agencies in matters of crime investigation pursuant to our legal obligations. Tenants are advised to log all criminal concerns with the Police who will subsequently be granted access to CCTV footage.
Where a CCTV request comes from the Police as part of a police investigation, we are not obligated to inform tenants of the disclosure if doing so would prejudice the police investigation.
7. International transfers
We may transfer your personal data outside the European Economic Area (EEA) through our use of the cloud storage system, Google Drive and our website cloud host, Squarespace Inc.
Google Drive and Squarespace maintain servers around the world and your information may be processed on servers located outside of the country where you live. Google Drive and Squarespace comply with certain legal frameworks relating to the transfer of data, such as the EU-US and Swiss-US Privacy Shield Frameworks.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. 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.
9. Data retention
How long will you use my personal data for?
By law we must keep basic information about our tenants and their guarantors (including Contact, Identity, Financial and Transaction Data) for six years after the tenant vacates Huxham Barns for legal and tax purposes. We may also retain deeds for up to 12 years legal reasons.
If you request marketing materials from us, we will keep your information for up to 6 months from the date you register your interest with us.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
If you wish to exercise any of the rights set out above, please contact us.
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 could 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 could 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.
11. 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.
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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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.