Privacy and Disclosure Policy
Section 1 - Introduction
Partington's Holiday Centres is committed to protecting your privacy and security. This policy explains how and why we use your personal data and to ensure you remain informed and in control of your information.
This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
This is due to a change to the rules which govern how we can communicate with you and a new regulation on personal data (the General Data Protection Regulation) coming into force in May 2018.
Any questions you have in relation to this policy or how we use your personal data should be sent to GDPR@partingtons.com or addressed to GDPR Officer, Partington's Holiday Centres, Chapel Court, 204 Fleetwood Road North, Thornton-Cleveleys, FY5 4BJ.
Section 2 - About us
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by Partington's Holiday Centres.
For the purposes of data protection law, Partington's Holiday Centres will be the data controller.
How the law protects you, as well as our Privacy Promise, your privacy is protected by law. This section explains how that works. Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Section 3 - What information we collect
Personal data you provide
We collect data you provide to us. This includes information you give when joining or registering, placing an order or communicating with us. For example:
- Personal details (name, date of birth, email, address, telephone etc.) when you become a customer or visitor
- Financial information (payment information such as direct debit details);
- Details of your interests and preferences
If you purchase a Partington's Holiday Centres gift card for someone, holiday maker, tourer or caravan owner, your details will be recorded (as will the recipients) and your relationship to that person will be recorded.
Information created by your involvement with Partington's Holiday Centres will result in personal data being created.
Information we generate.
We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement we may be able to build a profile which helps us decide which of our communications are likely to interest you.
Information from third parties
We sometimes receive personal data about individuals from third parties. For example, if we are partnering with another organisation.
We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.
Occasionally, we may collect information about certain customers (e.g. particularly well known or influential people) from public sources. This could include public databases (such as Companies House), news or other media. We don't do this to everyone, and it is the exception not the rule.
Sensitive personal data
We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation). However, there are some situations where this will occur. If this does occur, we will take extra care to ensure your privacy rights are protected.
Accidents or incidents
If an accident or incident occurs on our property, at one of our events or involving one of our staff then we will keep a record of this (which may include personal data and sensitive personal data).
Section 4 - How we use your information
We only ever use your personal data with your consent, or where it is necessary in order to:
- Enter into, or perform, a contract with you
- Comply with a legal duty
- Protect your vital interests
- For our own (or a third party's) lawful interests, provided your rights don't override the these
- In any event, we will only use your information for the purpose or purposes it was collected for (or else for closely related purposes)
We use personal data to communicate with people and to promote Partington's Holiday Centres. This includes keeping you up to date with our news, updates, campaigns, club and bar information.
We use personal data for administrative purposes. This includes:
- Maintaining databases of our customers, members and customers
- Performing our obligations under membership contracts
- Fulfilling orders for goods or services (whether placed online, over the phone or in person);
- Helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we will keep a record of this)
Internal research and analysis
We carry out research and analysis on our customers to determine the success of campaigns and appeals, better understand behaviour and responses and identify patterns and trends. This helps inform our approach towards campaigning and make Partington's Holiday Centres a stronger and more effective organisation. Understanding our customers, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications).
Section 5 - Disclosing and sharing data
- To keep your data safe and private
- Not to sell your data
- To give you ways to manage and review your marketing choices at any time
We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, or third-party products and services, but these communications will always come from Partington's Holiday Centres and are usually incorporated into our own marketing materials (e.g. advertisements in magazines or newsletters).
We may share personal data with subcontractors or suppliers who provide us with services.
Section 6 - Marketing
Partington's Holiday Centres will inform all customers about GDPR and have an "opt-out" option for most communications.
This means you will have the choice as to whether you want to receive these messages and be able to select the method of communication.
You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact us by emailing GDPR@partingtons.comor writing to Partington's Holiday Centres, Chapel Court, 204 Fleetwood Road North, Thornton-Cleveleys, FY5 4BJ.
What does 'marketing' mean?
Marketing does not just mean offering things for sale, but also includes news and information about:
- Partington's Holiday Centres benefits and offers
- Our events, activities and local groups
- Products, services and offers (our own, and those of third parties which may interest you)
When you receive a communication, we may collect information about you, respond to, or interact with that communication, and this may affect how we communicate with you in future.
Partington's Holiday Centres operates a Holiday Home owners discount scheme. Only our home owners receive these discounts. We will collect information on purchases in order to provide you with a better service. We might use this information to contact you about similar products and services that may be of interest to you.
Section 7 - Research and profiling
This section explains how and why we use personal data to build profiles which enable us to understand our customers, improve our relationship with them, and provide a better customer experience.
Analysis and grouping
We analyse our customers to determine common characteristics and preferences. We do this by assessing various types of information including behaviour (e.g. previous responses) or demographic information (e.g. age or location).
By grouping people together on the basis of common characteristics, we can ensure that group is provided with communications, products, and information which is most important to them. This helps prevent your inbox from filling up, and also means we aren't wasting resources on contacting people with information which isn't relevant to them.
Profiling to help us understand our customers
We profile customers in terms of financial and practical support.
We will also obtain information about you from other sources, much of which is available on public and private databases. We do this to enhance and fill-in any gaps so that we can understand our customers better, send you the most relevant communications and target our resources effectively.
In some cases, we will obtain likely indicators of interest or financial status based on your postcode rather than at an individual level. This information will not be specific to you, but probable characteristics based on your postcode.
We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new customers, or to identify trends or patterns within our existing customers. This information helps inform our actions and improve our campaigns, products/services and materials.
Section 8 - Young people
Photographs, pictures, stories and competitions
We want young people to join in, and there are opportunities for customers to share their photos, stories and pictures. If we publish your child's picture, photo or story, we will usually include their first name and age with it.
If your child enters a competition and is one of the lucky winners or runners-up, we will publish their name and winning entry alongside the other winners.
Parental permission: If your child is under 18 then we will need permission from you as their parent or guardian for them to enter one of our competitions or to share a picture, photo or story with us.
Information for parents
We take great care to protect and respect the rights of individuals in relation to their personal data, especially in the case of children. If your child is under 18, we will only use his or her personal data with your consent. This means that, for example, if your child wants to have his or her name or picture featured, we will need you to confirm you are happy for us to do so.
Marketing and fundraising
We will not send marketing emails, letters, calls or messages to under 18-year-olds.
Section 9 - How we protect data
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to or use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
All electronic Partington's Holiday Centres forms that request financial data will use the Secure Sockets Layer (SSL) and the latest encryption protocol as defined by PCI-DSS to encrypt the data between your browser and our servers.
- If you use a credit card we will pass your credit card details securely to our payment provider
- Other payment methods are handled in a similar manner
- Partington's Holiday Centres complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details
Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user's own risk.
Some of our premises have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and the Partington's Holiday Centres. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily. Unless it is flagged for review, CCTV footage will be overwritten.
Partington's Holiday Centres complies with the Information Commissioner's Office CCTV Code of Practice, and we put up notices so you know when CCTV is in use.
Section 10 - Storage
Where we store information
Partington's Holiday Centres operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we will only allow them to do if your data is adequately protected.
For example, some of our systems use Microsoft products. As a US company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we will allow this as we are certain personal data will still be adequately protected (as Microsoft is certified under the USA's Privacy Shield scheme).
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we will keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required. We never store payment card information.
Section 11 - Keeping you in control
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- The right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as a subject access request)
- The right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason)
- The right to have inaccurate data rectified
- The right to object to your data being used for marketing or profiling; and
- Where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
If you would like further information on your rights or wish to exercise them, please contact us by emailing GDPR@partingtons.com or writing to Partington's Holiday Centres, Chapel Court, 204 Fleetwood Road North, Thornton-Cleveleys, FY5 4BJ.
You can complain to Partington's Holiday Centres directly by contacting our data protection officer using the details set out above. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner's Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk
Section 12 - Cookies and links to other sites
Our website uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality. Further information can be found in our Cookies Policy.
Links to other sites
Our website could contain hyperlinks to other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the 'Contact us' link).
When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with Partington's Holiday Centres.