Privacy Policy

Introduction

Welcome to The Dartington Hall Trust’s website privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit and use our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can expand and contract the specific areas set out below as required. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

This policy was last amended on 29.06.2018.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This privacy policy aims to give you information on how the Dartington Hall Trust and its subsidiary companies collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up a mailing list, comment on an article, purchase a product or service, make a donation, or take part in a competition or survey.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Data Controller

Dartington is made up of different legal entities, details of which can be found below. This privacy policy is issued on behalf of the Dartington Hall Trust Group so when we mention “Dartington”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Dartington Hall Trust Group responsible for processing your data (the ‘data controller’). We will make clear which entity is the controller for your relevant data when you engage with or purchase a product or service with us. This should usually be contained in the relevant privacy notice.

Controller nameActivity
The Dartington Hall Trust
Charity no. 279756
Company no. 1485560
Responsible for the overall integrated website, including all charitable activity, fundraising and supporter schemes, the historical archive, general management of the estate including the formal gardens, , arts activity and bookings (including the Barn Cinema and Box Office), learning activity (including Schumacher College, RiP & RiPfA & Dartington School for Social Entrepreneurs), commercial & residential property lettings, recruitment of staff.
Dartington Accommodation and Catering Services Ltd
Company no. 1212831
Trading as Dartington Hall (Hotel & Conference Centre), The White Hart, Green Table Café, & The Roundhouse.

Responsible for management and processing of accommodation and eatery bookings, including weddings and conferences.
(The) Dartington Trading Company Ltd
Company no. 1218378
Trading as The Shops at Dartington and Totnes Bookshop.

Responsible for the retail offer on the website and Shops related events.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO.

DPO contact details

Chris Moores, Company Secretary
Email: chris.moores@dartington.org

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.

Changes to the privacy policy

Following the GDPR coming in to force on 25 May 2018, we recognise that  data protection law in the UK will continue to evolve as the UK Data Protection Act 2018 develops and the UK moves towards exiting the EU.  Although we will endeavour to ensure this privacy policy is maintained and up to date, there may be instances where upcoming changes will are yet to be satisfied where we are still working towards getting our systems ready for some of these changes.

Your duty to inform us

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Social media

Where we operate a social media page or channel and it is identified that we have a responsibility for your personal data as either a controller or joint-controller with that social media website, we will make this clear to you via a privacy notice.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name and last name. We may ask for further identity data (such as title, marital status, data of birth and gender) but only in situations where we believe this is essential to delivering the service in question.
  • Contact Data includes billing address, delivery address, correspondence address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories (of Personal Data)

Other than as part of our recruitment process, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

For more information on the Special Categories of Personal Data collected as part of a recruitment process, please refer to the privacy notice provided to you at that time.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with tickets for an event, or goods you have purchased). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    – apply for our products or services;
    – create an account on our website;
    – subscribe to our service or publications;
    – request marketing to be sent to you;
    – make a donation
    – enter a competition, promotion or survey; or
    – give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
    Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:- Technical Data from the following parties:
    (a) analytics providers (such as Google)
    (b) advertising networks
    (c) search information providers- Identity & Contact Data from publicly available sources such as social media (when you engage with our Facebook pages, Twitter accounts, or Youtube channel)- Identity, Contact, Transaction and Profile Data from publicly available sources (such as wiki pages, publications, etc) as part of an effort to better understand our supporter networks and inform fundraising strategies.Where information is received or likely to be received from third parties or publicly available sources, we will communicate this to you at the earliest opportunity through either a privacy notice or other communications.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by reviewing your contact preferences in your Dartington Account.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we might use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please check the privacy notices supplied to you or contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer(a) Identity
(b) Contact
(c) Marketing and Communications preferences
(a) Performance of a contract with you
To process and deliver your order or service including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications preferences
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications preferences
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications preferences
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications preferences
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
General marketing to you (when no other basis or relationship exists)(a) Identity
(b) Contact
With your consent (supplied by you either through an electronic form or similar mechanism)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
To use data analytics to segment our database and gain a better understanding of our supporters to inform our fundraising activity(a) Identity
(b) Transaction
Necessary for our legitimate interest to inform our fundraising strategy and develop relationships with our supporters.
Supplementary information from third party and public sources to better understand our supporters (providing nothing is prohibiting us from legally doing so).(a) Contact
(b) Transaction
(c) Profile
Necessary for our legitimate interest to inform our fundraising strategy and develop relationships with our supporters.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Through your Dartington Account, we have provided an area containing personal data control mechanisms, which you can access here.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased tickets, goods or other services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Dartington Hall Trust Group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into your Dartington Account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions, or any non-marketing related communication with you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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 either explain the legal basis which allows us to do so, or request your consent to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Section 1 of this Policy.
  • Specific third party service providers whose systems are used for the processing of your personal data, including:

(a)  Spektrix, acting as a data processor, based in the UK and Ireland, who provide our box office, Membership, donations, emarketing subscription and stakeholder management functions
(b)  Allocate from Airspace Software Ltd, based in the the US, who provide our accommodation booking engine function
(c)  OpenTable Inc, based in San Frascisco, California, US, who provide our table booking function for the White Hart Restaurant
(d)  Raise Your Profile Ltd, based in the UK, who provide fundraising and crowdfunding platforms, including TotalGiving.co.uk

  • Other External Third Parties as might be required by law

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 our third-party service providers 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.

6. INTERNATIONAL TRANSFERS

Some of our third party service providers (named in section 5 above) are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we will use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield [CM1] (or similar) which requires them to provide similar protection to personal data shared between the Europe and the US.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. KEEPING YOUR DATA SECURE

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.

8. HOW LONG DO WE KEEP YOUR DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘Request erasure’ within section 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. 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.
  • Request erasure of your personal data. 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • 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.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • 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. 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.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Company Secretary in the first instance (chris.moores@dartington.org).

Fees

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 may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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.

Time limit to respond

We try to respond to all legitimate requests within one month of verification of your identity. Occasionally it may 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 at the earliest opportunity and keep you updated.

10. GLOSSARY

Lawful basis for processing

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means asking an individual for their permission to process their personal data, offering them real choice and control. It requires a positive action from the individual.

Key roles

Data Controller is an entity that determines the purposes, conditions and means of the processing of personal data. Controllers have a legal obligation to give effect to the rights of Data Subjects. This includes the obligation to ensure that the rights of the individual are upheld at all times.  Data Processor is a natural or legal person, authority or agency or any other which processes personal data on behalf of the Controller. Data Processors are obliged to act only under the instructions of the Data Controller, comply with the Controllers’ obligations and assist the Controller with regards to Data Subject rights and handling any requests.

Data Subject is a living individual who is the subject of the personal data.