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PERSONAL DATA PROCESSING INFORMATION
The user’s personal data are utilised by Coombe End Estate Partnership, who is the owner and manager of the personal data being processed, in respect of the protection principles of the personal data determined by the GDPR 2016/679 Regulations.
TERMS AND PURPOSES OF THE PROCESSING OF PERSONAL DATA
1) We inform you that the data will be processed with the support of the following means:
a) Filing Forms (Registration forms, order forms, etc.)
b) IT Data (management software, accountability, etc)
c) Telematic means on the following terms: The supply/distribution of the services requested by the client or available on portals run by ( staff recruitment, newsletters, advertising literature, complimentary material) as well as end of contract terms of whom all those concerned are part of; Administrative and accountability purposes related to service contracts; The eventual denial in allowing the processing of personal data involves the inability to make use of the service requested by the user. Unless there is no refusal on behalf of the person involved, the data of the user will also be processed for the following purposes: Sending proposals and business messages by email , SMS or by fax, either on behalf of Coombe End Estate Partnership or by a company partner ; Market research and statistics, marketing and references on adverts and commercials ( press, radio, TV, internet, etc.) , preferences on the products;
THE DATA COLLECTED
Personal data - Your name, e-mail address, phone number, physical address, company affiliation, title;
Demographic information and location, and government-issued identifiers;
Guest stay information, special requests and preferences (including preferred room type, spend, vacation preferences, amenities requested, language preferences, interests, hobbies, ages of children or companions and any other aspects of the Services used), telephone numbers dialled, faxes and telephone messages received;
Frequent flyer and travel partner program; hotel, airline and rental car packages booked;
Social media account information, profile pictures or posts; Information, feedback or content you provide regarding your marketing preferences, in surveys, comment cards, sweepstakes, or promotional offers on our Services and those of third parties; messages or SMS text messages, where permitted by applicable law or based upon consent; Contact details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents, bookers, event planners); and Other types of information that you voluntarily choose to provide to us.
Sensitive Personal Data
You may provide or we may collect what is considered sensitive personal information or “special categories of personal data” under applicable privacy laws (herein referred to as “Sensitive Personal Data”). For example, you may disclose your religious affiliation to us when you host or attend an event or provide your health information or dietary restrictions so that we can accommodate you during your stay. We only process Sensitive Personal Data if and to the extent permitted and required by applicable law or with your express consent. Unless otherwise required by applicable law, you are not required to provide us with any of your Sensitive Personal Data. Should you choose not to, your decision would not prevent you from using our Services.
Personal Data from Third Parties
We may collect Personal Data related to you from third parties such as from airlines, travel agencies and online booking services. Additionally, if you submit Personal Data relating to other people – such as your children or other companions – in connection with the Services, you are also deemed to be representing that you have the authority to do so and permit us to use their Personal Data for the purposes described in this Privacy Policy.
Social media
We collect information from social media activity such as when you ‘like’ the Website, share content or follow us on social media sites like Facebook or Instagram. Other sources
We may receive your Personal Data from other sources, like public databases, joint marketing partners, and other third parties including travel agencies, airline and credit card partners.
LAWFULNESS OF PROCESSING
2) The conferment of personal data is compulsory in compliance with legal obligations and as far as contracts are concerned, therefore, the eventual refusal in providing them in full or in part may cause the inability to provide the services requested. The Company processes the discretionary personal data of the users by consent, or rather, by means of an explicit approval of the present privacy policy and in relation to the terms and purposes hereinafter described.
RECIPIENT CATEGORIES
3) Without prejudice to the information carried out in compliance with legal agreements and obligations, all personal data collected and processed may be communicated exclusively for the above mentioned purposes, to the following categories: Consultants; Informatics; Bookkeepers and administration clerks; Suppliers; Partners.
STORAGE PERIOD
4) The necessary personal data for contractual and accounting purposes will be stored for as long as they are needed in regard to the ongoing business and accounting relations. The personal data of those whom are not purchasing or making use of the products/services , will be cancelled immediately or processed in an anonymous way even though they may have already had a previous agreement with some of the Company representatives - this is subject to the storage of their personal data being otherwise justified , and provided that consent has been given by those concerned, on the grounds of a subsequent marketing promotion or market research.
RIGHTS OF THE USER
5) In compliance with the European Regulations 679/2016 (art. 13 and following) and with the National Legislation, the user , can exercise the following rights within the terms and values laid down by the standards of the legislation in force: Request confirmation as to whether or not personal data concerning them exist (right of access); Receive intelligible data communication; Be informed in relation to the logic, to the terms and purposes of the personal data processing; Request for the updating and rectification of such data, check for accuracy and request integration, request that their personal details be deleted, transformed into an anonymous format, that any unlawful use of their details be blocked, even the ones which are no longer necessary for the purposes for which they were collected; In cases of data processing , based on consent, they should be able to receive their own personal data supplied to the owner and manager of the collected data, in a structured manner, so that they are legible by a data processor and are set up in a format used by a standard electronic device; The right to file a claim against the Data Controller. The requests should be addressed to the owner and manager of the collected data .
6) The owner and manager of your personal data is:
Coombe End Estate Partnership
Elkstone
Cheltenham
Gloucestershire
GL53 9PT​
Tel: +44 (0) 1285 821 688 i
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INFORMATION ON COOKIES
A “cookie” is a file saved on the user’s computer as soon as access to a website has been given, with the aim to provide information each time the user goes back to the same site. It is a sort of reminder of the internet page one has visited. With the cookie, the web server sends information onto the user’s browser ( Internet Explorer, Mozilla Firefox, Google Chrome etc...) this is memorised on the user’s computer, and will be read again and updated every time the user goes back onto the site. This way the website can adapt automatically to the user. While surfing the net, the user may also receive cookies from other websites (i.e. “third-party cookies”) which may be installed during navigation by the website administrators of the said websites and used for the terms and purposes they have defined. According to their duration, they can be divided in session cookies ( that is to say the temporary ones which are eliminated automatically by the terminal at the end of the surfing session, once the browser is closed) and in persistent ones (those are the ones which remain memorised on the terminal until their expiry date or deleted by the user) Cookies can be subdivided into technical and proliferation cookies, according to their function as to how and why they are used.
TECHNICAL COOKIES
Some cookies are used to manage IT authentication when assessing on-line services and reserved areas and memorising specific information regarding the users who have access to this web page. These cookies, known as technical cookies , are often useful to allow safe and efficient navigation . Technical cookies are the ones which don’t need any consent by the user . The analytics cookies belong to this category. They are the cookies that collect information as to how the user makes use of a website and which can improve the correct functioning of the service offered. For example the analytics cookies show which pages are the most frequently visited ones, they enable to verify which recurring procedures are used for a website and help in understanding any kind of difficulty the user may encounter.
MONITORING COOKIES
Other cookies can be used to monitor and have an outline of the users surfing the net, by studying their movements and their navigation habits or even as consumers (what they actually buy, read etc. ), also aiming at sending them personalised and focused advertisement services. In this case one is talking about the use of profiling cookies. The use of these cookies are subject to having acquired advance notice in regard to the user’s informed free consent , in compliance to Art. 7 of the UE legislation 20016/679.
THIRD-PARTY COOKIES
It may happen that a web page may contain cookies sent by other websites or servers, which may contain elements hosted on the same page as for example, advertising banners, images, videos, maps, or specific links to other web pages of other domains which are located on different servers than the one they are visiting. In other words, these cookies are installed directly by the website managers or servers which are different from this website. We are talking, in these cases, of the said third-party cookies, which are normally used for monitoring purposes. The use of these cookies are subject to having acquired advance notice in regard to the user’s informed free consent , in compliance to Art. 7 of the UE legislation 20016/679.
THE COOKIES USED FROM OUR SITE
Our website uses TECHNICAL cookies.
COOKIES MANAGEMENT
The users can carry out their own preferences related to cookies through the functionality devices found in common browsers which allow to delete/remove the cookies ( all of them or some) or to change the planning of the browser itself, by blocking the cookies being sent or limiting this from happening on specific sites (compared to others). The present privacy policy may be subjected to changes in time - which are also connected to the eventual coming into force of the new regulations regarding this sector , together with the updating or with the supply of new services, that is to say – along with the technological breakthroughs as they arise - for this reason the user/visitor is advised to periodically consult the regular updating of the said privacy policy.
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