This Privacy Policy describes how we collect and use personal information about you in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 (when enacted) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation).
Please read the following carefully to understand our practices regarding how we handle information we collect from you or that you provide to us or which we otherwise learn about you from our relationships with you as a user of our lake facilities and/or your use of our website.
This Privacy Policy also explains how we may collect and process information about any other data subjects including:
- Our partners, employees, consultants, workers, work experience students, and job applicants (referred to for convenience in this privacy policy as ‘Employees’);
- Our suppliers and service providers and their agents, employees and representatives; and
- Visitors to our website.
Who we are:
FARLOWS LEISURE LLP (“we”, “our”) is the data controller which means that we are responsible for your personal data. We are a limited liability partnership registered in England and Wales under number OC395786 whose registered office is at Alpha House, 176a High Street, Barnet, Hertfordshire, EN5 5SZ.
If you have any questions about this privacy policy or our privacy practices, our data compliance manager can be contacted by emailing info@farlowslake.co.uk or by calling 01753 630302.
What we do:
Lake Users
We do not operate a membership scheme and the use of our lake facilities is by way of the purchase of a day ticket. If you make a non-cash payment for example a credit card payment then we will collect your personal and financial details in connection with the processing of that payment.
We occasionally conduct prize competitions. If you participate in a prize competition we will collect your personal data in connection with your participation in that competition and we will use it for that purpose and any other purposes described to you at the time of the collection of your personal data in relation to that competition.
We monitor our lake facilities with closed-circuit television cameras (CCTV).
If you visit one of our sites your image and activities on the site will be obtained, retained and processed, as described in this Privacy Policy.
Our CCTV is used to capture, record and monitor images of what takes place at our lake facilities in real time. We operate CCTV for the health and safety of our employees and other persons attending our lake facilities from time to time and for the prevention and detection of crime and antisocial behaviour.
At our discretion, we may disclose personal data in response to valid requests from the police and other statutory law enforcement agencies. We may disclose personal data to third parties, if required to by law. We may also disclose personal data to tenants or licensees so that they can handle recorded incidents where it is appropriate for them to do so. We do not otherwise share any CCTV recordings or images.
We have on-site privacy signs which will notify you that we are monitoring our facilities.
Website Users
We obtain information about you when you use our website, for example:
(i) when you become a registered user or fill in other forms on our website;
(ii) if you purchase a gift voucher from us via our website or other online facility;
(iii) when you subscribe to receive email alerts, or when you subscribe to or participate in any other service;
(iv) if you contact us, we will keep a record of that correspondence (for example, when you report a problem with our website or request technical support);
(v) if you participate in a survey that we use for research purposes.
We may also collect and aggregate information about your computer for system administration and website analytics. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
We obtain information about you when you contact us in relation to an auction, whether an online auction or an auction to be held at our salerooms, or if you are a bidder at one of our auctions or a buyer of any items at an auction, for example:
If you visit our website we may collect additional information through the use of cookies. This is explained in the cookies policy available on our website at www.farlowslake.co.uk
Employees
If you are an Employee then we will collect and process personal information about you as described in your employment contract, our employee policies, and/or any other applicable separate documents provided to you in connection with your position or your application for a position with us.
All Data Subjects
The information we hold about you may include the following:
- your personal details (such as your name, address and other contact details);
- details of any contacts we have had with you in relation to the provision, or the proposed provision, of our services;
- our correspondence and communications with you;
- information about any complaints and enquiries you may have submitted to us;
- information from any research or surveys conducted by us in which you may have participated; and
- information we receive from other sources, such as publicly available information, and information provided by your employer or other relevant organisation.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal information without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Our Lawful Justification for Processing Your Personal Data:
We have set out below the legal bases we rely on to use your personal data. We have also identified what our legitimate interests are where appropriate. Please note that we may process your personal data on 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.
Lake Users
If you make a payment or complete any forms in relation to your use of our lake facilities then we will process your personal data including your identity data, financial data and transaction data on the basis that the processing is necessary for the provisions of our services under the contract which has been entered into with you.
If you use or visit one of our sites we will process your personal data including your identity data collected via CCTV on the basis that the processing is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
We have a legitimate interest as the operator of fishing lake facilities to:
a. Know who is using or otherwise present on our managed private land;
b. Ensure safety and security and help deter/detect criminal activity; and
c. Retain transactional information for accurate record keeping.
All Data Subjects
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.
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. 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.
We do not rely on consent as a legal basis for processing your personal data, although we would get your consent before sending any third party direct marketing communications to you via email or text message.
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.
Retention of your data:
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, the lawful basis upon which we process your personal data, and the applicable legal, regulatory, tax, accounting or other requirements.
Sharing Your Personal Data:
We will share your personal information with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
We share personal data with Napier Parking Limited who provide certain office administrative resources for us.
The cafeteria within our lake facilities is independently operated and we may share personal data with the cafeteria operator in connection with the provision of products or services to data subjects.
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 any third party service provider 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.
We will not transfer your personal data out of the EU.
Your data subject rights are as follows:
1. The right to be informed.
You have the right to be informed about the collection and use of your personal data. That is the purpose of this Privacy Policy.
2. The right of access.
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
3. The right to rectification.
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.
4. The right to erasure.
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. Please note that we may not always be able to comply with your request of erasure for legal reasons which will be notified to you, if applicable, at the time of your request.
5. The right to restrict processing.
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.
6. The right to data portability.
You have the right to 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. Please 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.
7. The right to object.
You have the right to 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.
8. Rights in relation to automated decision making and profiling.
We do not use any personal data for automated individual decision-making (making a decision solely by automated means without any human involvement) or for profiling (automated processing of personal data to evaluate certain things about an individual).
Please note that you have the right to request the above, however, when we receive your requests we may object to your request if we do not agree with it. However, if you do make the request we will tell you if the request has been granted or not.
Exercise of your Data Subject Rights:
If you wish to exercise of any of the above rights we recommend that you provide notice to us via an email request marked for the attention of our data compliance manager because this will allow you to identify and deal with your request promptly. You can do so by emailing info@farlowslake.co.uk or by calling 01753 630302.
[For Subject Access Requests there is a SAR form that may assist you with your request on our website www.farlowslake.co.uk, which can be found on Privacy Policies page.]
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.
We will need to obtain proof of your identity before providing you with information we hold about you. 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.
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.
If you require more information about items raised in this notice we would recommend the ICO website, www.ico.org.uk
Changes to Our Privacy Notice:
From time to time we may amend the way in which we process personal data. This may lead to changes in how we collect and/or use your personal information. We may amend the terms of this Privacy Policy at any time.
Contact Us:
If you have any queries relating to this Privacy Notice or our privacy practices, please contact us by e-mail at: info@farlowslake.co.uk or call 01753 630302.
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.