INTRODUCTION AND SCOPE OF THIS PRIVACY STATEMENT
Heveningham Concours “we” or “us”, wants to give you the best experience possible. We use the personal information you share with us to make our services and your experience even better. This privacy statement aims to give you a clear view of how we use personal information that you provide, our dedication to protecting it, your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our websites, how we use your personal information and the third parties we will share it with. We use personal information for various purposes, as described in detail below.
WHO COLLECTS YOUR PERSONAL INFORMATION
Heveningham Concours controls the processing of any personal information collected through marketing cookies used on its website and apps. Heveningham Concours has its registered office at Heveningham Hall, Heveningham, Suffolk IP19 0PN.
PERSONAL INFORMATION WE COLLECT FROM YOU
“Personal information” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. Heveningham Concours will collect various types of personal information about you, including the following (as applicable):
USE OF OUR PRODUCTS AND SERVICES
When you use our services we will ask for personal information (at the moment of collection we will explain what information is required in order for us to provide the particular service, and what information you may choose to provide), such as:
▪ your email address, postal address and payment details when setting up your account;
▪ your date of birth, home address, proof of address and proof of ID for our Anti-Money Laundering checks;
▪ your email-address when signing up for one of our contests, free prize giveaways (“Prize Giveaways”) or external newsletters;
▪ a record of our correspondence with you (including any feedback you have provided on any of our products or services), if you have been in contact with our team.
INFORMATION WE COLLECT AUTOMATICALLY
We will also collect personal information about you when you interact with our brand, websites and apps and how you use them, as follows:
▪ Websites: we will collect information about the Heveningham Concours website that you visit and how you use them. A visit to our website results in data being sent from your browser to our servers. We will collect personal information in this way, such as:
· your IP address;
· the date and time of the visit and how long you remained on our website;
· the referral URL (the site from which the visitor has come);
· the pages visited on our website; and
· information about the device and browser (such as, browser type and version, operating system, etc).
▪ Location information: When you use our wi-fi, we will also use various technologies to determine location, such as sensor data from your device that will help us determine where our services are most commonly used throughout the building. You can generally disable sending your location through settings in your device, and we will inform you when we make use of location information.
SOURCES OF INFORMATION
Most of the information we collect about you will be personal information that you have voluntarily provided to us, for example, through our websites.
HOW WE USE YOUR PERSONAL INFORMATION
The personal information we collect when you first log into our wi-fi will be used for identification and authentication purposes.
1. Marketing: when you sign up to receive Heveningham Concours newsletters we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place. We create your profile in accordance with your preferences in order to provide you with the best personalised experience, to send you personalised marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.
▪ What kind of information: the way you interact with our brand across all the different channels described above (e.g. the Heveningham Concours website, social media and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best experience possible. To learn about you and your interests, we analyse your interactions with our brand using various kinds of information, as set out above. In particular, we may combine the information we collect with information we lawfully obtain from third parties. This is necessary for the purposes of our legitimate interests in ensuring that we provide you the most appropriate offers for services and to personalise your experience. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalised marketing messages about products or services, events, Prize Giveaways and promotions. In some instances we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how customers use our products and services, and experience our brand. This is necessary for the purposes of our legitimate interests in analysing our brand and determining how to improve our services.
▪ What kind of channels: we will send direct marketing communications to you via the channel you choose, such as email, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalised marketing communications.
▪ What kind of messages: the messages we will send you will be personalised and tailored to your individual preferences and interests. We use analytics in order to generate such personalised messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our products and services, events, Prize Giveaways or promotions and news. We personalise these messages on the basis of that it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with Pavilion, including by sending you personalised messages.
▪ Re-targeting: our websites and apps use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our offices and our services, advertisements from us on partner websites. We believe that the display of personalised, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyse the information we collect about your interactions with each platform as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behaviour. We will process your data for re-targeting purposes with your explicit consent. Please click here for further information on cookies and instructions on how to disable re-targeting. Note that our sites generally are not configured to respond to web browser do-not-track signals.
▪ Ads: we also work with third party companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect personal information about your visits to our websites or apps and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of cookies for marketing purposes. Please click here [insert hyperlink to cookies policy] for further information on cookies and instructions on how to change your cookie preferences.
1. Conducting analytics: we will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our customers and ensuring that our products meet the needs of our customers. The specific ways in which we carry out this analysis include:
▪ data science/analytics, whereby we combine information (such as personal information and/or sensitive personal information we have obtained through the use of a Pavilion app or from your browsing history) we hold on a large scale in order to:
· learn more about our customers and their preferences;
· to identify patterns and trends amongst our customers;
· enhance user experience on our websites;
· provide information, content and offerings tailored to our customers’ needs;
· for general research and statistical purposes; and
· for aggregated reporting purposes within the Group;
▪ develop new products and services;
▪ monitor performance of our products and services and/or improve our technology;
▪ to be able to send you personalised marketing messages;
▪ to display online ads to you.
3. Analysing our business: we will use your personal information (including by anonymising and aggregating it with other customers’ personal information) for sales, supply chain and financial analysis purposes, to determine how Heveningham Concours is performing and where improvements can be made and where necessary to report back to our parent or affiliate group companies. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.
1. We will ask for your consent if we wish to use your personal information for purposes other than those listed in this privacy statement and as required to do so under applicable law. We will not use your personal information for other purposes before we have received such consent.
HOW WE SHARE YOUR PERSONAL INFORMATION
We treat your personal information with care and confidentiality and do not share it with third parties other than in the following ways:
With Social Networks
Our website and apps will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook or Twitter (for example by registering an account), your activity on our website or via our apps will also be made available to that social network. This is necessary for the performance of your contract with a Group entity which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or apps or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings. If you would like to prevent this type of data transfer, please log out of your social network account before you enter one of our websites or apps, or change the app’s privacy settings, where possible. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal information, what rights you have and how you can maintain suitable privacy settings for your needs.
With Legal and Law Enforcement
Heveningham Concours will disclose personal information where required by law or legal process, for the administration of justice, for the purposes of debt collection, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Pavilion’s property and legal rights, to protect the personal safety of our website or (mobile) app users or by order of a valid injunction from a court or law enforcement agency.
With Your Consent
We will share your personal information with other third parties (different from those described above, for example, affiliated companies providing external services or products) in other limited circumstances. In these instances we will, where required by applicable law, obtain your consent to share your personal information in this way.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We are committed to protecting your personal information and implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
RETAINING YOUR PERSONAL INFORMATION
We will keep your personal information for two years from your last interaction with us, such as the date your account was deleted, your last purchase, the last time you used one of our apps or in some other way contacted or interacted, unless a longer or shorter retention period is required by law, is necessary in the course of legal proceedings or is otherwise needed for a particular purpose under applicable law.
The following are examples to illustrate how Pavilion keeps your personal information for as long as necessary for a particular purpose:
▪ we may keep your personal information collected during a purchase for as long as required by tax laws (longer than 2 years in some European countries);
▪ we may keep your personal information for a shorter period if you ask us to delete your personal information. In such a case, Pavilion will aim to delete your personal information within a maximum period of 28 days from the date of the request;
▪ information collected in connection with promotions will be kept for no longer than one month following the end of the promotion.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
Unless stated otherwise, we store and process your personal information in the European Union. There will, however, be occasions when we need to transfer your personal information outside of the European Economic Area (“EEA”) to a country is not regarded under European Law as providing the same level of data protection as the country in which you normally use our products and/or services.
INFORMATION ABOUT CHILDREN
As a general rule, we do not intentionally collect personal information about children under the age of 16. If we become aware that we have inadvertently collected personal information about children under the age of 16, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it.
Where we know a child is above the age of 16, but considered a minor under applicable law, we will obtain parental/guardian consent prior to using that child’s personal information.
LINKS TO OTHER WEBSITES AND SERVICES
Our websites may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks).
We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Fair play and transparency are important to us. We are open about the personal information we collect and have implemented mechanisms to enable you to exercise any rights you might have with respect to your personal information.
Where we have obtained your consent in relation to any matter in relation to your personal information (e.g. your consent to receiving direct marketing messages or your consent to the placement of cookies on your device), you can withdraw this consent at any time by contact us using the contact details set out below or changing your cookie settings.
ACCESS TO, DELETION, AND CORRECTION OF PERSONAL INFORMATION
You can send us a request for access to this information at no cost using the contact details set out at the end of this privacy statement.
After receiving your request and sufficient information to verify your identity we will provide you with a copy of the personal information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such personal information is being used, its recipients and the origin of the information.
You may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information. You may also write to us at any time to object to our use of your personal information, restrict our use of your personal information, or request that we provide your personal information in a usable electronic format and transmit to a third party (right to data portability). We will comply with these requests in relation to your personal information in line with applicable law.
OPTING OUT AND UNSUBSCRIBING FROM MARKETING MESSAGES
All our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. You may also opt out for particular channels (for example email or SMS) as indicated in the message received in such channel or through your Pavilion account settings.
If you would like to opt out of receiving marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you could contact our:
Data Protection team
by E-mail at : Data.Protection@Ocubis.co.uk
Note that if you choose to opt out of receiving marketing messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalised or non-personalised marketing messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.
Please note that some of our mobile apps might also send you messages, including (if you have given your permission to do so) push messages, for instance about new services. In this case, the particular mobile app will provide just in time notices before we send you push notifications. You can disable these messages through the settings in your phone or the app, or choose to uninstall the app to stop receiving the messages.
CHANGES TO THIS POLICY
Heveningham Concours has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our online privacy statement in order to ensure that it is free of errors and clearly visible on websites, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. We may update this privacy statement from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites and/or mobile apps along with an updated version of the privacy statement.
If you have any questions about our use of your personal information, how to exercise your rights or about our privacy statement you are welcome to contact us:
by E-mail at : Data.Protection@Ocubis.co.uk
if you prefer to contact us by regular mail, please send your request to the following address:
C/o Ocubis Ltd
Data Protection Team
15 Regent Street
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority using their website.
LAST UPDATED: January 2019.
LAST UPDATED: May 2018
WHAT YOU SHOULD KNOW ABOUT COOKIES
FIRST OF ALL… WHAT ARE COOKIES?
Cookies are small text files that are stored on your computer or mobile device when you visit a website. For this section, we conveniently use “cookies” as an umbrella term for techniques such as cookies, Flash cookies and web beacons. They don’t take much space and they will be removed automatically when expired. Some cookies expire at the end of your internet session, while others will be saved for a limited amount of time.
SECONDLY… WHAT ARE THE DIFFERENT COOKIE TYPES WE USE?
There are different types of cookies with different uses. Some are there just to allow you to browse the website and see certain features. Some give us an idea on your browsing experience, i.e. when you have trouble finding what you are looking for, so we can improve and make your future visit as pleasant as possible.
Cookies set by Heveningham Concours are called “first party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer or mobile both when it visits the website in question and also when it visits certain other websites. We use first party and third party cookies for several reasons.
The most important cookies are the required cookies. They are essential and help you to navigate on the website and to use basic features, such as media plugins. Then there are functionality cookies that enable you to make an enquiry through our live-chat or online enquiry form. The performance and analytics cookies we use to improve our website. We also like to show you relevant promotions. To manage this we collect browsing data, which may be linked to a unique identifier to allow us to understand how you interact with Pavilion across different platforms as described in our privacy statement (click [here] for our privacy statement). Interaction cookies are used for you to interact with social media or to submit reviews. Targeting cookies, advertising cookies and social media cookies capture your preferences in order to show you relevant ads outside adidas sites. In addition, social media cookies may be used to track your activity over social media platforms.
1. REQUIRED COOKIES
are essential and help you navigate, move around on the website and see certain features. These cookies are required to enable core site functionality. These cookies are stored for the duration of your browsing session.
2. FUNCTIONALITY AND ANALYTICS COOKIES
are there so we can give you an even smoother customer experience (e.g. these cookies help you to continue conversations with us after closing your session). These cookies allow us to analyse site usage so we can measure and improve performance. These cookies may be placed by us or a third party on our behalf (see our cookie opt-out tool) and are stored for the duration of your browsing session.
3. ADVERTISING AND SOCIAL MEDIA COOKIES
▪ will remember your preferences or assist marketing efforts in other ways. These cookies enable us to share data, such as what you like, with our advertisers, so the advertisement you see can be more relevant to your preferences (sometimes referred to as “targeting cookies”).
▪ help us to understand behaviour of visitors. This enables us to keep improving our website, so usage becomes easier and more pleasant, and to improve the marketing messages we send to our contacts (sometimes referred to as “performance cookies”).
▪ are used for you to express your opinion. These cookies will enable you to like or recommend us on social media and to chat with our service agents.
WHAT IF YOU DON’T LIKE COOKIES?
You can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings. Find out how this works for your browser here:
Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html
Note that you may visit http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to learn about the options that some of the third parties we work with offer for opting out of certain ad targeting activities. You will need to visit those websites from each browser and device that you would like to be covered by your opt-out. Because the opt-out tools may depend on cookies, you may need to visit these sites again to reinstate your preferences if you delete your cookies.
HOW OFTEN WILL YOU UPDATE THIS COOKIE STATEMENT?
The date at the top of this Cookie Statement indicates when it was last updated.
FINALLY…WHERE CAN I GET FURTHER INFORMATION?