We are committed to keeping your Personal Data safe and confidential both online and offline. Please take time to read through this Privacy Statement to ensure you are aware of how Habitat First Group obtains and uses your information and how we keep it safe.
This Privacy Statement will apply to:
- All land and property owners, visiting guests and members of the public within the grounds of a Habitat First Group owned Estate
- Those using our Apps & Habitat First Group Websites
- Those using our booking system operated by Habitat Escapes
- Those we provide services to over the phone, by email or in person
We have separate policies and privacy notices in place in respect of job applicants, former employees, workers, volunteers, apprentices and consultants. A copy of these can be obtained from here.
This Privacy Statement explains what Personal Data we collect and how we will process this information (i) to provide our services to you, (ii) to comply with our legal obligations, (iii) for the purposes of our legitimate business interests (namely to analyse the use of our Website and/or our apps and services to continually improve our business and your customer experience) or (iv) where we have your consent.
1. Data Controller
We will only use information from which you can be identified, such as your name, images, contact details and financial information (“Personal Data“) which is provided to us, or otherwise obtained by us, as set out in this Privacy Statement. We will ensure that your Personal Data is handled in accordance with “Data Protection Legislation” (meaning any law applicable relating to the processing of Personal Data and/or privacy including the UK Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003,
In this Privacy Statement, “Habitat First group“, “we“, “us” and “our“, refer to Habitat First group, registered in the United Kingdom with registered 47 Marylebone Lane, London, England, W1U 2NT. Our company registration number is 08035016. For the purposes of the Data Protection Legislation, we are deemed to be the “data controller” in respect of any Personal Data that you provide to us in connection with the operation of our business or which we otherwise obtain about you.
2. How we collect personal data
We collect personal data from you when you engage with us in various ways, as described below:
- visiting our estates
- registering with us
- sending us emails
- online data capture forms
- contacting us via telephone
- making an enquiry through the website and/or our apps or on one of our sites
- through social media or our online chat system
- purchasing a plot of land
- owning property within our estates
3. What personal data we collect
Depending on your reason for engaging with us, we will collect the following personal data:
- your name and contact details (e.g. your address, email address and telephone number)
- information regarding your personal or professional interests
- details of your experiences with our breaks (you may choose to provide us with contact information, where you are from, which location you visited, when and photos of your stay)
- your contact preferences
- the names of other members of your party (where applicable)
- financial information to make a payment for a booking
- video recordings, still pictures, your activities, your face, car registration details and any other visual information about you which is recorded on CCTV
We collect this information in several ways such as:
- CCTV onsite at the entrances / exits, restaurant and children’s indoor play area.
- completing a booking form
- through online data capture forms
- providing us feedback forms
- when subscribing to use property Wi-Fi
- through registration forms
Where you are booking a holiday for other individuals, it is the primary ‘booker’s’ responsibility to notify their accompanying guests they have provided their personal information to us and to direct them to this Privacy Statement.
Special category data
You may voluntarily provide us with some special category data for us to provide you with a better standard of service. For example, when booking a service or holiday with us you may provide us with information about your dietary or medical requirements and any restricted mobility or access requirements, which may reveal details about your mental or physical health or condition.
The provision of this information is entirely voluntary, and we have justification to use it under health and safety legislation. We only process this information to the extent strictly necessary and we will only use this information for the purposes for which you provided it to us. Where you are booking a holiday for other individuals and provide their Special Category Data, please make sure that you have their permission for Personal Data and please direct them to this Privacy Statement for further information as to how we will process this data
Personal Data that we receive from CCTV
We may collect video recordings and still pictures which feature you if you are in the field of vision of any of our CCTV system. This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system.
As the data controller, we will collect personal information on our CCTV system and use it for the following purposes: For the prevention and detection of crime, for evidence in any civil or criminal legal proceedings, to assist in investigations, for safety and security, dealing with any queries, complaints or enquiries.
All the above are legitimate reasons for us to use and store personal information relating to you which is captured on our CCTV system and legitimate interests is our legal basis for processing your personal information. We may anonymise any of the personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face) and it therefore ceases to be your personal information.
We share your personal information with the following parties: Organisations that provide us with legal, property and insurance advice, authorised personnel, such as the police and service providers to Habitat First Group where they would responsibly need access to the data. We do not disclose personal information to anyone else except as set out above unless we have your consent, or we are legally obliged to do so.
Personal Data that we collected via your device
Where you make use of our Website and/or our apps, login to our WIFI or otherwise engage with us we will also collect technical information about you and certain limited information about your device, your visits to our Website and/or our apps and when you contact an advisor through the online chat system. This Personal Data may include:
Device data: We will collect information about the type of device, operating system and platform you use (such as a computer or mobile device) to access our Website and/or our apps, your choice of browser and plug-in types and versions.
Location data: Your use of our Website and/or our apps may generate geographical data, such as the location or time zone setting of a device or IP address, which we may collect. We may also use technology that allows us to customise emails that we send you. We may do this by tailoring the email content according to your general location area which is determined from the IP address that your computer or device sends when you load our emails.
Log data about your visit: Your use of our Website and/or our apps automatically generates information about your unique visit which we will collect. This can include your login information, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), products and events 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), data about your internet service provider, the number and timing of clicks to and from the content on our Website and/or our apps and methods used to browse away from the page. Typically, we will not be able to identify you from this information, although we may do if you have logged in to our Website.
Personal Data that we receive from other sources
We may receive information from third parties who collect Personal Data from you and pass it on to us. For example, where a holiday is booked by an individual on your behalf, they may give us your Personal Data so that we can process the booking. Where this is the case the third party is responsible for ensuring that you are aware of this policy and that you are happy with the way in which your Personal Data will be used.
We will obtain some limited children’s data (when a child is a guest at one of our locations). If you are a child staying with us, we may acquire details of your name, age and gender, your contact information, dietary and medical requirements and images obtained through our CCTV camera onsite. We will only use this information in order to ensure that your stay with us is safe and comfortable and to help you to enjoy age-appropriate activities at our locations.
7. How do we use Personal Data?
We use your Personal Data in order to:
- deliver the services and information that you request from us and correspond with you in relation to their provision
- provide support to you in respect of these services
- improve our Website and/or our apps and services
- comply with our own legal obligations (for example, financial and health and safety)
- perform internal business processes
- provide relevant information associated with your stay
- provide relevant information associated with your property you own or are staying in
- provide relevant information associated with our estate and surrounding environment
- For the prevention and detection of crime, for evidence in any civil or criminal legal proceedings, to assist in investigations, for safety and security, dealing with any queries, complaints or enquiries
Improving our services
We will use your Personal Data to analyse your purchasing preferences and to ensure that the content, services and advertising that we offer are tailored to your needs and interests or to ensure that content from our Website is presented in the most effective manner for you and for your computer, including monitoring customer traffic patterns and website usage to help us improve the design and layout of our website and provide content that is of interest to you, and to improve the services which we offer to customers.
We (or a third party on our behalf) may contact you to ask you about your experience with Habitat First Group. We use this information to improve our services so we can provide you and others with the best standard of service. We will never include any form of marketing in these communications and you may opt-out of being contacted at any time.
For our research, we may use data gathered from the booking form to include your postal address details to ascertain an appropriate method of contact and provide relevant literature.
Marketing Communications and Newsletters
When you complete a holiday booking form with us and choose to opt in to receive our latest news; we will use your Personal Data to send you newsletters, special offers and other marketing communications providing information on our products and services we offer. These will be similar to those that you have already purchased, by electronic means directly (e-mail or SMS).
In other instances where you have explicitly consented to receive marketing material, we will use your Personal Data to send you our newsletters, special offers and other marketing communications which will be sent primarily by email but may also be sent via post, text message or telephone. A separate consent will be obtained for each type of electronic marketing so that we only contact you by the method you have consented to. Consent to this can be withdrawn at any time, and if you withdraw consent, we will add your details to our suppression list so that you are not inadvertently re-added.
8. Your rights
You have a number of rights under data protection legislation as set out at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
To make a request in relation to any of these rights, please contact us at: firstname.lastname@example.org
Please be aware that not all rights are absolute and do not apply in all circumstances, for example if we have a legal obligation to retain and continue using your data. We may also require some form of proof of identity prior to processing a request.
Rights in relation to direct marketing and sharing preferences
Whenever you book a holiday or otherwise purchase a product or service from Habitat First Group, you may opt-out of receiving marketing communications by ticking a box on our website or via an unsubscribe link in your booking confirmation emails.
When you leave a review or share your favourite Habitat First Group memory with us through our Website, you can choose to opt-out of our sharing of that information with third parties, such as using it in our advertisements, by ticking the relevant box on the form.
If you change your mind and decide you do not wish to receive communications from Habitat First Group (including our marketing or market research communications), you can unsubscribe by clicking on the ‘unsubscribe’ link at the bottom of any emails you receive from us, or by emailing us at: email@example.com
Should you have any queries or complaints in relation to how we use your Personal Data, please contact us at firstname.lastname@example.org Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.
9. Security and retention
We employ security measures to protect your Personal Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. These measures include: –
- Using a high security server
- The sever adheres to government standards for encryption
- Pin authentication
- Fully trained staff
Once the relevant purpose to store your data has been satisfied, we will securely delete or anonymise your Personal Data unless we are required to retain a copy of such information by law. The retention period will depend on the type of information and the purpose for which we are using it. This will normally be for a period of 3 – 6 years.
10. Sharing Personal Data with third parties
We share your Personal Data with third parties where you have given us your explicit consent or it is necessary (i) for the performance of the services you have requested or booked, (ii) for us to comply with our legal obligations or (iii) for our legitimate business interests.
- Financial transactions – Where you make a booking or purchase products from us, your card details will be shared with third parties as necessary to process your transaction e.g. we need to contact card issuers for validation checks and authorisation on all card payments. Any Personal Data you provide may be disclosed to a registered Credit Reference Agency which may keep a record of the information to comply with their own legal obligations. These measures are taken as extra protection for you, to ensure your online experience with us is as safe and secure as possible. The Credit Reference agencies used in most circumstances are World Pay, Elavon or First Data Merchant System.
- Online services – Some of the services on our Website and/or our apps and at our locations, are delivered or served by third party companies, in their own right or as our services providers or our agents, which may collect information about your use of the services. For example, where you have booked activities with us through a third-party activity provider, we will need to share your Personal Data with the relevant third party. Where this is the case, they shall be the data controller over such information, and we advise you to read their own privacy statement as to how they will process your Personal Data.
- Website analysis – As part of an on-going testing programme we may record a random sample of website sessions to identify usability problems and improve our guest experience. These session recordings are held temporarily whilst solutions are built and deployed and any numerical input relating to your session is excluded.
If you choose to opt-in to such communications, we may also share your Personal Data with our affiliates and/or business partners for marketing purposes or we may send you information about other organisations’ goods and services. You can indicate which of our affiliates and/or business partners you would like to receive marketing information from on your Booking Request or contact us using the details below. You may change your mind about the permissions you have given us to use your Personal Data at any time. You may opt-out of receiving any marketing communications from third parties by following the instructions outlined in the communication, by contacting us on the details below or contacting the third party directly.
Sales and mergers – If we (or any part of us) enter into a joint venture or are sold, transferred to or merged with another business entity or if our business structure changes, your Personal Data may be disclosed to the new business partners or owners, so that they and we can continue to provide the services you have requested. Your Personal Data will still only be used in accordance with this Privacy Statement.
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12. Links to third parties
Links from our site to external websites do not mean we endorse these websites. We advise you to read the privacy statement applicable to each third-party site you visit, and we will not accept any responsibility for or liability in respect of either the contents or your use of these third-party sites.
14. Changes to this Privacy Statement
We will review this Privacy Statement and may make changes depending on how we use your personal data. Any changes will be posted to this page on our Website and, where appropriate, notified to you when you next access our Website or our apps, book a holiday with us or otherwise request services from us therefore you should continue to check this page to ensure you are happy with any changes.
15. Contact us
If you have any questions, please feel free to contact us by email at email@example.com