Privacy Policy
The words “Company”, “Company’s”, “Us”, “We”, “Our” refers to the registered company Elstow Lodge Ltd Ltd trading as Elstow Lodge Ltd registered in England and Wales under company number 11654085. Elstow Lodge Ltd is the Data Controller of your Information for the purposes of the GDPR Act 2018 (the “Act”). Our business is based at Elstow Lodge Ltd, Elstow Lodge, Wilstead Road, Elstow, Bedfordshire, England, MK42 9YD. The word "Website" refers to the domain name http://www.elstowlodge.co.uk and all content within.
When using our website and services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. We encourage you to bookmark this Web page and review this Policy regularly. This privacy policy explains our views and policies for treating your data. By using http://www.elstowlodge.co.uk you agree to this privacy policy and the practices explained within.
CONTACTING US
If you would like to opt out of marketing and communications from us, you may do so using the opt out link in the emails that we send, or by contacting us via email at manager@elstowlodge.co.uk
This policy together with our terms of use http://www.elstowlodge.co.uk and any other documents referred to on 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.
For the purpose of General Data Protection Regulation, the data controller is Elstow Lodge Ltd, Elstow Lodge, Wilstead Road, Elstow, Bedfordshire, England, MK42 9YD
Data we may collect from you
Whilst conducting business we may have to process the following types of data about you:
Information you give us.
You may give us information about you by filling in forms on our site http://www.elstowlodge.co.uk or by communicating with us by phone, e-mail or in person and by any other method. This includes data that you provide to us when you register to use our website, subscribe to our mailing service, request a property viewing, view a property (s), request further information, request that we represent you for the purpose of sale and when you report any problems.
The data you give us may include:
First name, Middle name(s), Surname, Address, email address and preferred contact telephone number. The information will be held for the duration of the viewing(s), your time registered with us and whilst the property(s) is on our register. The information required for viewings is taken for the sole purpose of law enforcement and health and safety.
This data is not sold to a third party is kept confidential to the company.
Data we may collect about you:
When visiting our Website, the following data may be captured about you.
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;
Data about your visit to our Website, 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.
Data we may receive on you from other sources
We may receive data about you if you use any of the other websites we operate or the other services we provide. [In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.] We are also working closely 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.
How we use the data held about you
The data you give us
We will use this data to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us:-
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to 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 only contact you by 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 tick the relevant box situated on the form on which we collect your data (the [order form OR registration form]);
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.
Data we may collect about you
We will use this data:-
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Data we may receive on you 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 data we receive).
Disclosure of your data which we hold
We may share your data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may 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.
If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of use http://www.elstowlodge.co.uk and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where do we store your data?
All data you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology]. 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 as this may cause your data to become unsecure.
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 data, we will use strict procedures and security features to try to prevent unauthorised access.
Your Rights
You have the right to not consent to this privacy policy. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (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 can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@ab-fruits.com
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.
Access to data
The Act gives you the right to access data held about you. Your right of access can be exercised in accordance with the Act. You can exercise the right at any time by contacting us at manager@elstowlodge.co.uk
Cookies
Our cookie policy can be found at http://www.elstowlodge.co.uk/privacypolicy The website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The website will prompt you to agree to the use of cookies, by clicking OK you are agreeing to our use of cookies defined here. You can exercise your right to not accept the use of cookies by not clicking OK.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We may use the following cookies:
· Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
[Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies]
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
CCTV Policy
Introduction
The Company uses closed circuit television (CCTV) images to protect the Company’s property and to provide a safe and secure environment for employees and r visitors to the Company’s business premises.
This policy sets out the details of how the Company will collect, use and store CCTV images. For more information on your privacy rights associated with the processing of your personal data collected through CCTV images please refer to the Company privacy notice and data protection policy. .
The Company’s CCTV facility, unless there are exceptional circumstances (see covert recording below), will only record images. There is no audio recording i.e. conversations are not recorded on CCTV.
Purposes of CCTV
The purposes of the Company installing and using CCTV systems include:
• To assist in the prevention or detection of crime or equivalent malpractice.
• To assist in the identification and prosecution of offenders.
• To monitor the security of the Company’s business premises.
• To ensure that health and safety rules and Company procedures are being complied with.
• To assist with the identification of unauthorised actions or unsafe working practices that might result in disciplinary proceedings being instituted against employees and to assist in providing relevant evidence.
• To promote productivity and efficiency.
Location of cameras
Cameras are located at strategic points throughout the Company’s business premises, principally at the entrance and exit points. The Company has positioned the cameras so that they only cover communal or public areas on the Company’s business premises and they have been sited so that they provide clear images. No camera focuses, or will focus, on toilets, shower facilities, changing rooms, staff kitchen areas, staff break rooms or private offices.
All cameras (with the exception of any that may be temporarily set up for covert recording) are also clearly visible.
Appropriate signs are prominently displayed so that employees, clients, customers and other visitors are aware they are entering an area covered by CCTV.
Recording and retention of images
Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.
Images may be recorded either in constant real-time (24 hours a day throughout the year), or only at certain times, as the needs of the business dictate.
As the recording system records digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and, in any event, are not held for more than 2 weeks. Images that are stored on, or transferred on to, removable media such as CDs are erased or destroyed once the purpose of the recording is no longer relevant. In normal circumstances, this will be a period of 2 weeks. However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.
Access to and disclosure of images
Access to, and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.
The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other employees will not have access when viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.
Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:
• The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.
• Prosecution agencies, such as the Crown Prosecution Service.
• Relevant legal representatives.
• Line managers involved with Company disciplinary and performance management processes.
• Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).
The Managing Director of the Company (or another senior director acting in their absence) is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.
All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.
Individuals’ access rights
Under the UK’s data protection laws, including the General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image.
If you wish to access any CCTV images relating to you, you must make a written request to the Company’s Data Protection Officer or Data Representative. This can be done by using this email address manager@elstowlodge.co.uk Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images.
The Company will usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous the Company may extend the one month to respond by a further two months.
The Company will always check the identity of the employee making the request before processing it.
The Data Protection Officer or Data Representative will always determine whether disclosure of your images will reveal third party information, as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.
If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.
Covert recording
The Company is aware that covert recording can only be done in exceptional circumstances for example where the Company suspects criminal activity taking place. On this basis the Company will only undertake covert monitoring if it has carried out a data protection impact assessment which has addressed the following:
• the purpose of the covert recording;
• the necessity and proportionality of the covert recording;
• the risks to the privacy rights of the individual(s) affected by the covert recording;
• the time parameters for conducting the covert recording
• the safeguards and/or security measures that need to be put in place to ensure the covert recording is conducted in accordance with the data protection laws, including the GDPR.
If after undertaking the data impact assessment the Company considers there is a proportionate risk of criminal activity, or equivalent malpractice taking place or about to take place, and if informing the individuals concerned that the recording is taking place would seriously prejudice its prevention or detection, the Company will covertly record the suspected individual(s). In doing this the Company will rely on the protection of its own legitimate interests as the lawful and justifiable legal basis for carrying out the covert recording.
Before the covert recording commences the Company will ensure that Managing Director (or another senior director acting in their absence) agrees with the findings of the data protection assessment and provides written authorisation to proceed with the covert recording.
Covert monitoring may include both video and audio recording.
Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity or equivalent malpractice. Once the specific investigation has been completed, covert monitoring will cease.
Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity or equivalent malpractice. All other information collected during covert monitoring will be deleted or destroyed unless it reveals information which the Company cannot reasonably be expected to ignore.
Staff training
The Company will ensure that all employees handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the laws regulating data protection and privacy about that system.
Implementation
The Company’s Data Protection Officer is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and they will conduct a regular review of the Company’s use and processing of CCTV images and ensure that it always remains compliant with the laws regulating data protection and privacy.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to manager@elstowlodge.co.uk