This policy (together with any other documents we refer to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who we are
“We” or “us” means Duchy of Cornwall.
If you wish to contact us, please email firstname.lastname@example.org.
By contacting us, using our services or visiting our website, which is owned and controlled by us (“our site”), you are accepting and consenting to the practices described in this policy unless you inform us otherwise.
Information we collect from you
We may collect and process the following data about you:
Information you give us.
You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide if you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, date of birth, financial information; personal description; dietary requirements; medical conditions; allergies; dependants personal information, next of kin details, employment status/history.
Information we collect about you.
With regard to visits to our site we may automatically collect the following information:
· technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
· about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources.
We may receive information about you from third parties such as online travel agents or booking engines. When that data is collected from you, you should be informed by those third parties at that stage that it may be shared internally by us and combined with data collected from multiple sources.
We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We also receive information about you from cookies.
Uses made of the information
We use information held about you in the following ways:
Information you give to us.
We will use this information to:
· notify you about changes to our service;
· ensure that content from our site is presented in the most effective manner for you and for your device.
Where you have indicated to us that you are happy for us to do so, we may also use this information to:
· provide you with information about other services we offer that are similar to those that you have already enquired about or receive from us; and
· provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will contact you by post and electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please leave the relevant box blank situated on the form on which we collect your data.
Information we collect about you.
Examples of how we will use this information includes (but is not limited) to;
· administer our services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· improve our site to ensure that content is presented in the most effective manner for you and for your device;
· allow you to participate in interactive features of our services, when you choose to do so;
· keep our services, site and premises safe and secure;
· measure or understand the effectiveness of our service.
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Disclosure of your information
You agree that we can share your personal information with:
· our suppliers and sub-contractors for the performance of any contract we enter into with them to allow us to provide services to you, and only where they are under a duty to deal with your personal data in accordance with the law; and
· anonymously, with analytics and search engine providers that assist us in the improvement and optimisation of our site or business.
· Supercontrol (based in the UK)
· MailChimp (based in the US)
· Campaign Monitor (based in the (Australia)
We will disclose your personal information to third parties:
· in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
We are a member of Premier Cottages, a professional collective of independent luxury cottage owners. Premier Cottages promotes properties on our behalf as well as other luxury cottages.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us via our contact form.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 2018. If you would like a copy of the information held on you please write to Duchy of Cornwall, Restormel Estate Office, Lostwithiel, PL22 0HN.
If you believe that any information we are holding on you is incorrect or incomplete, please write to us or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
Where we store your personal data
Where data is transferred outside of the European Economic Area by third party suppliers we have ensured that specific safeguards are in place to protect the personal data of individuals and that your rights are preserved. Our suppliers are either members of an EU approved certification mechanism or we have a specific agreement in place which incorporates the EU’s standard contractual clauses on data transfer.
All information you provide to us is stored on our secure servers or on secure servers operated by a third party. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will ask for your permission before collecting your data if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You may revoke that permission at any time by contacting us.
You have the right (subject to certain restrictions) to request any of the following; we ask that you send such requests to our contact details as listed above:
· Access – to access all the personal data we hold about you;
· Erasure – that we erase all personal data we hold about you, if that data is no longer being used for the purposes you have consented to or if you revoke your consent;
· Portability – to copy or transfer the personal data we hold about you to another party.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We will not store your data for any longer than is necessary. If you are a user of our services, then your information will be held for as long as you continue to use our services.
If you cease to use our services, your personal data will be anonymised for statistical purposes shortly after you stop using our services
Contact information and further advice
The Secretary and Keeper of Records of the Duchy of Cornwall is the registered Data Controller.
If you would like to contact us please do so via one of the methods below:
The Data Protection Administrator, Duchy of Cornwall, 10 Buckingham Gate, London. SW1E 6LA
If you have concerns about the use of your personal data, the Information Commissioners Office is an independent body set up to uphold information rights in the UK. They can be contacted through their website: www.ico.org.uk, or their helpline on 0303 123 1113, or in writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
NHS Test and Trace
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.
By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.
As a customer/visitor of the Duchy of Cornwall Holiday Cottages, you will be asked to provide some basic information and contact details. The following information will be collected:
- the names of all customers or visitors
- a contact phone number for each customer or visitor
The venue/establishment as the data controllers for the collection of your personal data, will be responsible for compliance with data protection legislation for the period of time it holds the information. When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time.
The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.
In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.
NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.
For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a 2-day period).
We may require you to pre-book appointments for visits or to complete a form on arrival.
Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing. Information of this type will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit.
However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number). Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.
Your information will always be stored and used in compliance with the relevant data protection legislation.
The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) – a legal obligation to which we as a venue/establishment are subject to. The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of coronavirus.
By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you.
You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).
You have the right to request that we restrict processing of personal data about you that we hold in certain circumstances.
You have the right to object to processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).
If you are unhappy or wish to complain about how your information is used, you should contact a member of staff in the first instance to resolve your issue.
If you are still not satisfied, you can complain to the Information Commissioner’s Office. Their website address is www.ico.org.uk.