PRIVACY POLICY

Updated 15/11/19

Buckingham Plant Hire LTD (we, us or our) is committed to protecting and respecting your privacy and we look after your personal information (personal data) carefully in line with data protection and privacy laws. Below we detail the information we collect concerning you and how that information is used.

Please read this policy and our cookie policy in order to understand when and why we collect personal data, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

It is important that you read this privacy policy together with any other privacy policy 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 personal data. This privacy policy supplements those other notices and is not intended to override them.

We may change this policy from time to time so please check this page occasionally to ensure you are happy with any changes.

Any questions regarding this policy and our privacy practices should be sent by email to info@blackpitbrewery.co.uk or you can contact us using the contact details set out at the bottom of this policy.

For the purposes of the data protection laws in the UK Buckingham Plant Hire Limited t/a Blackpit Brewery is the data controller and is responsible for the way in which we handle your personal information. Buckingham Plant Hire Limited is a company registered in England and Wales (registered number is 542721) with registered office at Blackpit Farm, Silverstone Road, Stowe, Bucks, MK18 5LJ. Our VAT registration number is 119 1251 95.

We are registered on the Data Protection Public Register. Our Data Protection Registration Number is [ZA286011.]

Information

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.

• Identity Data which includes your name, marital status, title, date of birth and gender.

• Contact Data which includes your address, postcode, email address and telephone number;

• Health Data which includes whether you are registered disabled and any specific health matters you notify us of;

• Financial Data which includes our bank account and payment card details.

• Transaction Data which includes details about payments to and from you and other details of the services you have purchased from us or used whilst on or prior to visiting our site.

• Technical Data which includes details of your internet protocol (IP) address, operating system, browser version, cookie details, the content you viewed on our website, how long you stayed and on which pages, and your navigation around our and our group companies websites;

• Usage Data which includes information about how you use our website, products and services.

• Media Data which includes images of you (both still and videos) as well as voice recordings and other records of your likeness including those collected by our CCTV.

• Location Data from your IP address or by accessing global positioning functionality on your device (e.g. GPS) (where you have consented to us doing so);

• Marketing and Communications Data which includes your preferences in receiving marketing from us, our group companies and our third parties and your communication preferences including where you have asked us to send you a copy of our newsletter.

Personal data does not include data where your identity has been removed or which not associated with or linked to your personal data (anonymous data).

We may 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 people attending our event from a specific region. 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.

Please note that 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 reserve you a pitch). In this case, we may have to cancel your reservation or any other service you have requested but we will notify you if this is the case at the time.

Information Collection

We (or our authorised third parties) may collect information about you in a number of different ways:

• Direct interactions. You may give us your personal data including your Identity, Contact and Financial Data when you fill in forms or correspond with us by post, phone, email social media, through our website or otherwise, or when you purchase products or services on our website, contact us with an enquiry or to give feedback, participate in any interactivity, enter a competition or prize draw or when you otherwise update your details;

• Onsite collection. Where you attend an event on our site your Media Data may be collected through cameras and other recording equipment on that site which may be operated automatically or by an individual, such as a photographer taking photos of the event.

• 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 through the use of “cookies” server logs and other similar technologies. For further details, see our cookie policy;

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources for example we may obtain Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our sponsorship partners who may provide who may be based inside/ outside the EU.

HOW WE USE YOUR personal information

We will only use your personal data when the law allows us to. Your information may be used by us and our authorised third parties in respect of the following:

• Bookings: When you book an event we will use your Identity, Contact, Financial and Transaction Data in order to register you as a customer and to process your booking including the management of payments, fees and charges. This is necessary for the performance of our contract with you. We will only use your Health Data where you have voluntarily provided this to us when requesting a Personal Assistant ticket or otherwise and will then process it only for the purpose you have asked us to do so, in accordance with your consent for us to do so.

• Other Products and Services: Similarly when you order or purchase from us any other goods or services we may use your Identity, Contact, Financial, Transaction and, where we have your express consent to do so, Location Data to enable us to deliver those goods or services to you including the processing of payments, fees and charges in accordance with our contract with you.

• Contacting us: When you contact us with an enquiry or to request information (including brochures and other hard copy materials) or to make a complaint we will use your Identity and Contact Data to deal with your enquiry, request or complaint and to provide our response as is in accordance with our legitimate interests we may also use your personal data to contact you with services messages if necessary in accordance with our legitimate interest of providing you with the best possible customer experience..;

• Advertising, marketing and public relations: We may use the Identity, Contact, Technical, and/or Usage Data which you give to us to form a view on what we think you may want or need, or what may be of interest to you. In doing so we will only send information that is deemed relevant to your use of our services. This is necessary for our legitimate interests in growing and developing our business including our products and services. You will receive marketing communications from us only if you have requested information from us or purchased similar goods or services from us and, in each case, have not opted out of receiving that marketing. We will however ask for express consent before we share personal data with any third party for marketing purposes. You can ask us to stop sending marketing communications at any time by contacting us or by using the unsubscribe or opt out link in any such marketing communication. We may use your Media Data in our advertising and marketing materials in accordance with our legitimate interests.

• Safety and Security: We may use your Identity, Contact and Media Data (included that collected via our CCTV cameras) so as to ensure your safety and security and the safety and security of our other customers and visitors in accordance with our legitimate interests.

• Surveys: If you choose to complete a survey that we use for research purposes we will retain the information that you provide in response to that survey. This is necessary for our legitimate interest in understanding our customers and developing our business and to informing our marketing strategy.

• Competitions: If you enter any competition which we are running we will use you Identity and Contact Data to administer the prize if you are a prize winner, and to publish or otherwise make available a list of prize winners;

• Social Media Access: If you choose to access a social media platform via our website, we may use your personal data to provide you with access to those social networking sites. Any personal data shared with a third party social network provider will be processed in accordance with their own privacy policy.

• Administration: We may use your Identity, Contact and Technical Data for the purpose of protecting our business and our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data and monitoring compliance with our policies and terms. This is necessary for our legitimate interest in running our business, providing a good customer experience to you and our other customers, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation, sale or group restructuring exercise, and for compliance with our legal obligations.

• Website Analytics: As you navigate our website, Technical and Usage Data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of the website, and to help us to improve the content of the website and to customise the content or layout of the website for you, in accordance with our legitimate interests. This is necessary for our legitimate interest in defining 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.

• Fault reporting: If you contact us to report a fault with our website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with our legitimate interests.

We may also use personal data which you provide to us, where the law allows us to do so, as follows:

• To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where we need to comply with a legal or regulatory obligation, including the prevention of crime.

• 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.

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 or in respect of the use of your Location Data. You have the right to withdraw consent at any time by contacting us on the details below.

Please note your Media Data will not always constitute personal data. Where your Media Data is captured as part of a crowd or a large group it is unlikely to constitute personal data. Where you are the focus of the Media Data it is likely to be personal data and we will handle it as such, in accordance with this privacy policy.

Where we process personal data on the basis of a legitimate interest, as set out in this privacy policy, legitimate interest means the interest of our business in conducting and managing our business and to enable us to give you the best service and the best and most secure and enjoyable 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.

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 we will explain the legal basis which allows us to do so.

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

Marketing messages and Location Data

We will only send you marketing messages where you indicate that you consent (i.e. by “opting-in”) to receiving such messages or where we are otherwise legally permitted to do so. Where we have your consent or are otherwise permitted to do so, we may:

• Send you information by email about existing and new services and special offers from us;

• Send you information by email about related products or services of selected third parties that may be of interest to you; and

• Pass your details to selected third parties so that they may send you information by email about products or services that may be of interest to you but only where you have consented to us doing so.

To stop receiving marketing communications from us, you can use the ‘unsubscribe’, ‘stop’ or similar facility contained in any such communication or you can let us know at the details set out in “Contact Details” below stating that you do not wish to receive further communications from us.

Similarly we will only use your Location Data where you have expressly consented to us doing so. You can withdraw your consent to our using your Location Data at any time by either disabling location services on your device or letting us know using the details set out in our “Contact Details” section below.

Is personal information shared?

Your personal data will only be disclosed to those of our employees or workers that have a need for access to such information for the reason it was provided. We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes unless you have specifically given us permission to do so.

We may pass information about you to other parties as follows:

• To third parties working on our behalf such as contractors, suppliers and/or agents including without limitation our customer care teams to administer your bookings and the services provided to you now or in the future. Rest assured when we use third party service providers, we disclose only the personal data that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes;

• Where we have your consent to do so, for marketing communications;

• Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract entered into between us.

• As part of general statistical information about our customers however these details will not include information personally identifying you;

• To other companies within our group who provide support services to us or ancillary services to our customers in accordance with our legitimate interests;

• To the police and/or other emergency services, regulatory bodies or legal advisers in connection with any alleged criminal offence, major incident, unlawful activity or suspected breach of the Terms of Use and or the breach of other terms and conditions or otherwise where required by law or where we suspect harm or potential harm to others. We will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders. We shall not be obliged to give you any further notice of this;

• In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

• If we or substantially all of our assets are acquired by a third party, in which case personal data that we hold about our customers will be one of the transferred assets.

• Where relevant, the user name and some profile information you voluntarily provide may be published on areas of our Website such as forums, chat rooms or pages where user submissions are displayed and this will be the identity by which you are known on those areas. Please always think carefully before disclosing information to other users or otherwise making your information publicly available.

Protection of personal information

We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect. In addition, the access to and use of the personal data that we collect is restricted to our employees who need the personal data to perform a specific job role or activity. Where personal data is shared with third parties in line with this privacy notice responsible measures are used to protect your personal data. 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.

Non-sensitive details (your email address, etc.) are transmitted normally over the internet, and this can never be guaranteed 100% secure. As a result, whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Please always think carefully before disclosing information to other users of our services or otherwise making your information publicly available. It is important that you are aware that any information you disclose to another user may then be disclosed by that user. We have no responsibility or control over the contents of communications made between users of our services.

International Transfers

Some of our external third parties, such as the company which hosts our website, may be 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 may use specific contracts 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 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.

Data retention

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.

For example:

• By law we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.

• We may retain details of your booking or any enquiry which you may make, including your personal data, for a period of 7 years to enable us to deal with any follow-up communications from you or to ensure that we are in possession of all relevant papers in the event of a legal claim relating to the contract between us.

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.

Your 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 that 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 that we hold about you corrected, although we may need to verify the accuracy of the new personal data that 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 personal data unlawfully or where we are required to erase your personal data to comply with local law. Please 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 personal data 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. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) 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 purchase, product/service experience or other transactions.

If you wish to exercise any of your above rights, please send a written request to us at the address listed at the end of this privacy notice.

You will not have to pay a fee to access your personal data or to exercise any of your 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.

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.

We try to respond to all legitimate requests within one month. 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 and keep you updated.

Changes to this privacy notice

This version was last updated on 15 November 2019.

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.

Complaints

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.

Contact details

You can email us with any questions, queries or complaints at info@blackpitbrewery.co.uk or alternatively you can write to us at Blackpit Brewery, Blackpit Farm, Silverstone Road, Stowe, Bucks, MK18 5LJ