We are committed to protecting the privacy of your personal data. We will respect any personal data you share with us and keep it safe. We aim to be clear when we collect your personal data and only use your information for things you would reasonably expect.
1. Who we are
“Buckland Estate” refers to the following four separate entities:
a) Dungates Farms Limited (“DFL”)
DFL is a private limited company incorporated in England. If you buy a ticket for day-admission to Buckland Park Lake, become a member, you will be principally dealing with DFL.
b) Dungates Sporting Limited (“Sporting”)
Sporting is a private limited company incorporated in England. If you buy a subscription to the fishing club, you will be principally dealing with Sporting.
c) Frith Park Farm Limited (“FPFL”) and Underhill Farm Estates Limited (“UFEL”)
FPFL and UFEL are private limited companies incorporated in England and are affiliated to DFL and Sporting. While you are unlikely to be dealing directly with FPFL or UFEL, they provide services to DFL and Sporting in relation to Buckland Park Lake from time to time.
We refer to these four entities collectively as the “Buckland Estate Entities” throughout this policy, and references to “we” and “us” refer to the Buckland Estate Entities collectively.
DFL, Sporting, FPFL and UFEL may each be data controllers of your personal data. They each have different roles, but some activities they undertake overlap and personal data may be shared internally for certain purposes. Information may be shared between them to facilitate, support and integrate their respective activities, for example, DFL may administer invoices and payments made to Sporting, who are themselves responsible for promoting and running fishing at Buckland Park Lake. Where possible and appropriate, we do try to be clear which entity is collecting your information and to explain which entity does what, but there is inevitably some overlap.
The address of each of these four entities is Buckland Estate Office, Lawrence Lane, Buckland, Betchworth, Surrey RH3 7BE.
2. What personal data we collect and the purposes for which we use it
2.1 What personal data do we hold?
The various activities that we may undertake at Buckland Park Lake through the Buckland Estate Entities are described on the Website. However, we generally only hold the personal data that you volunteer or provide to us for use in connection with limited and specific purposes, which are explained to you at the time of collection.
Some examples of the type of information we may collect and hold about you are as follows:
But we may also collect, hold and process other personal data where it is appropriate and relevant, for example:
Special Categories or Sensitive personal data
We will only process sensitive personal data also known as special categories of data (e.g., in relation to your health), where really necessary. We will do this with your explicit consent (including where you volunteer it to us), where necessary to protect the vital interests of the data subject, to prevent or detect an unlawful act, or where necessary for the establishment, exercise or defence of legal claims. Most commonly this processing will arise in our management of a variety of situations, including: managing health and safety incidents, accidents or other complaints, security and the detection or prevention of crime on our premises and carrying out safeguarding obligations to protect those on our premises or involved in our activities.
2.2 How and why will we use this personal data?
2.2.1 We will use your personal data to:
3. What lawful bases do we rely on to use your personal data?
The legal bases that we rely on for processing your personal data are:
3.1 You have provided your consent to us using your personal data for a specific purpose:
We will ask for your consent to use your personal data to send you marketing emails and SMS.
You always have the right to withdraw your consent at any time.
3.2 It is necessary in connection with the performance of a contract with you:
Sometimes it is necessary to process your personal data so that we can enter into contractual relationships with you. For example, if you buy a ticket, purchase something from us, or become a member, we will require your personal data to enable us to perform our agreement.
3.3 It is necessary for compliance with a legal obligation to which we are subject:
This would include where we have to retain certain records, for example, to manage health and safety, for the detection and prevention of crime, safeguarding obligations, for maintaining suppression lists to ensure we comply with marketing laws, for tax reasons and undertaking due diligence before entering into certain relationships.
3.4 It is within our legitimate interests.
Applicable law allows personal data to be collected and used if it is reasonably necessary for our legitimate interests or a third party’s legitimate interests (as long as the processing is fair, balanced and does not unduly impact individuals’ rights). We will rely on this ground to process your personal data where we are confident that this will not impact your rights.
Our legitimate interests include the following:
The types of activity where we may rely on legitimate interests include the following:
When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
Please see section 2.1 above for the limited legal basis for when we process sensitive personal data.
3.5 It forms part of our “public task”
We are committed to preserving the heritage of Buckland Park Lake as well as its natural qualities. As such we obtain information and objects into our collections ranging from documents, books, letters and correspondence which often have historical value, as well as environmental studies relating to the site.
Some items will contain personal data within them (such as letters or details of the author of a study) and where items are donated to us, we are also obliged to record details about the donor themselves. Please note that certain historical items, may relate to an individual who is deceased. As such the details they contain are no longer legally deemed to be “personal data” and are outside the scope of this notice.
We process the above-mentioned personal data as part of our statutory duties and are required to demonstrate its provenance. We therefore include public statements of source, including the donor, volunteer or author, but do provide opportunities to remain anonymous if preferred.
4. How we collect personal data
We collect information about you:
4.1 When you give it to us directly
You may give us your personal data in order to receive information from us; visit our facilities; buy products or services from us including such things as purchasing, administering and renewing membership; when you volunteer with us or take part in any of our community programmes (or request information about these); when you respond to a survey or when you otherwise engage with us on our Website and digital products.
4.2 When a third party provides us with your personal data
4.3 When it is available publicly
We may combine personal data you provide to us with personal data available from external publicly available sources such as Companies House and published articles and newspapers. Depending on your privacy settings for social media services, we may also access personal data from those accounts or services. We use this personal data to gain a better understanding of you, and to improve our communications approaches (see section 3 above).
4.4 When you use our Website and digital products, such as https://www.bucklandparklake.co.uk
We may collect personal data about you when you use our Website and digital products. Whenever you input personal data into our website (for example, if you buy a ticket or renew a membership online or otherwise support us through our website, book a visit online or download any of our resources), we will collect the personal data that you give to us.
We use “cookies” to identify you when you visit our Website and digital products. Amongst other things this helps us to understand our website users and may enable us to improve the website experience for you and/or other users. Please refer to our Cookies Policy for details on how and why we use this data at https://bucklandparklake.co.uk/cookies
We may collect other personal data from your use of the Website, such as your IP address and access times.
5. Communications and marketing
5.1 We may contact you by post, SMS and telephone, and, where you have provided consent, by e-mail, to let you know about our events and activities (and we may also mention those of third parties, particularly where they are collaborating with us or sponsoring our events) that might be of particular interest to you; retail offers and promotions, or about the work of the Buckland Estate Entities more generally. In the case of venue hire or group bookings, we may also contact you by post, phone or email to tell you about associated events which support or relate to your venue hire or group booking. We provide the opportunity for you to opt-out from receiving our marketing communications every time we contact you.
You can opt-out from receiving our marketing communications, or update your contact preferences at any time by emailing: firstname.lastname@example.org.
5.2 Digital advertising targeting
We may reach out to users across the internet with adverts for things we think you might be interested in using a variety of digital advertising providers. These could be social media providers like Facebook and Instagram, search engines like Google and Bing, display and programmatic advertisers like Adverity and MIQ or through our email marketing if you’ve opted in to receive marketing emails from us. Please note this list isn’t exhaustive. The following sets out what activities we undertake and some we don’t, many of which are based on cookies and / or pixels.
A cookie is a simple text file that is stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.
A pixel is a snippet of code that enable cookies to be downloaded to your device. Pixel tags are usually third-party tags which identify a device as it browses different websites, partly so that targeted advertising can be shown to the user of that device.
You can find out more information about cookies and pixels on the Information Commissioner’s Officer (ICO) website.
5.2.1 Interest and behaviour-based advertising
We will use certain targeting options provided by the digital advertising providers based on the data they already hold to reach out to users of their platform. You would see an advert from us only because you fall into a particular demographic, location, interest or behavioural group, not because we have specifically targeted you as an individual.
To do this we have told the digital advertising provider what type of people we would like to see our ads (for example anyone over the age of 16 who has demonstrated an interest in outdoor recreation). They have then identified you based on the data they hold on users of their platform. We never see any of your data and are not able to identify any individuals who may then see these adverts.
5.2.2 Cookie and pixel-based remarketing
Third party digital advertising providers may place cookies and pixels on our website where we allow them to. When you visit our website and accept targeting cookies, these targeting cookies will be placed on your device. Each time you interact with our website it will send usage data about the fact that your device has been used to access our website back to the digital advertising provider. We tell the digital advertising provider which type of users should be shown a Buckland Park Lake advert, for example “any device which has visited a Buckland Park Lake event page”. The digital advertising provider will then assess their usage data and send an advert to those users who visited the event page. We never see any of your data and are not able to identify any individuals who may see our adverts.
You can see how else the digital advertising providers may use this data and find out how you can control how they use your data in the digital advertising providers’ privacy policies and terms and conditions. You can see all the remarketing cookies and pixels that we use on the Buckland Park Lake website and find out more about managing third party cookies in our Cookies Policy.
5.2.3 Lookalike audience targeting
We may work with digital advertising providers to identify and advertise to individuals who share a similar interest, characteristic or behaviour to users who have already engaged with our content, adverts and/or website. We do this to increase the number of individuals who visit our sites and products by providing digital advertising providers with set criteria of behaviour people may have taken that shows interest in what we’re promoting, for example “people similar to those who have already visited a Buckland Park Lake event page”. They use these criteria to identify a new audience by reviewing who has already engaged with our content, adverts and/or website and identifying users with similar characteristics. Data which is identified in this way is called a lookalike audience. If a lookalike audience is used, we will never see any data of individuals and will never be able to identify individuals who may see our adverts.
5.2.4 Custom audience targeting
We do not undertake any custom audience targeting with digital advertising providers or use custom audiences to create lookalike audiences. We do not share your personal data with any digital advertising providers and this will never be the reason you see an advert from us. But for thoroughness we are including an explanation of what this activity involves.
The digital advertising provider may also use this personal data to identify a “lookalike audience” of similar users who have similar characteristics to those within the custom audience.
5.2.5 Other digital services
We may use the location data provided by the devices you use to access our main website and in any mobile app we develop. If you let your device share this information with us, we may use it to personalise your experience with us. Your device or web browser will usually prompt you when this is requested.
The type of things we may use your location for include:
You can change your location settings at any time in your device or computer settings.
YouTube API services
We may use YouTube API services to display video across our website. By using our website, you agree to be bound by the YouTube Terms of Service.
5.2.6 Opting out of advertising from the Buckland Estate Entities
There are several ways to minimise the amount of advertising you see on the internet and to opt out of any targeted advertising from us. Please visit our Cookies Policy for more information about how to update your cookies opt in on our website and how to update your settings with the digital advertising providers.
6. Data sharing
We do not sell your information under any circumstances. We may from time to time share your personal data with third parties, such as The Surrey Hills Adventure Company (our water activities partner) or Fiesta Fields (our events partner), for them to use for marketing purposes. However, we will only ever do this where you have given us permission to do so or where we are carrying out joint research as detailed in section 3.4.
The Buckland Estate Entities may share your personal data between themselves, so if you give your information to DFL then this may be shared with Sporting, FPFL and/or UFEL, for example. Your personal data will only be shared between the entities for the purposes set out in section 2.2 of this policy.
We work with service providers and other third parties who provide services and support to us to run our daily operations, including providing and improving our information, products and services, and we may share information with them for these purposes only.
Whilst we may allow our staff, consultants and/or external service providers acting on our behalf to access and use your personal data for the activities we have described in this policy (e.g., to provide services or products to you, deliver mailings, to analyse data and to process payments), we only permit them to use it to deliver the relevant information, goods or services, and only if they apply an appropriate level of security protection.
Sharing for regulatory or legal reasons. We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies. We may also merge or partner with other organisations and in so doing, acquire or transfer personal data but your personal data would continue to be used for the purposes set out above.
Transmission outside Europe or via the Internet. The personal data we collect from you may be transferred to, shared and/or otherwise processed by organisations or companies outside the European Economic Area (“EEA”). Where your personal data is transferred outside the EEA, we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your personal data (for example, by entering into EU Commission approved standard contractual clauses).
Unfortunately, the transmission of personal data 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 personal data transmitted to or via our Website and digital products; any transmission is at your own risk. If you have any questions about the international data transfer of your personal data, please contact us using the details below in section 12.
7. Children’s data
We may collect and manage personal data about children in some circumstances, such as where children participate in activities at Buckland Park Lake (such as educational and learning activities) or have requested to receive certain communications from us, such as newsletters. Those aged under 13 are not permitted to receive our newsletters, or enter any competitions or prize draws with us. We will not knowingly have any other direct contact with those aged under 13.
Where consent is required to process children’s personal data and the child is under 13 years, where appropriate we shall seek consent from a parent or guardian, or shall ensure such consent is in place before any data is shared with us. We shall only hold personal data about children that is absolutely necessary for the purpose of the event/programme that they are applying for or participating in.
Where a parent or guardian gives consent on behalf of a child, we may contact that child after their 16th birthday, to check if they wish to maintain their relationship with us.
8. How we keep your personal data safe and who has access to it
We are committed to ensuring that there are appropriate technical controls in place to protect your personal data including protection from misuse and unauthorised access. For example, our network is protected and routinely tested.
Your information is only accessible by staff, volunteers and contractors who are bound by appropriate policies and procedures to protect your information.
9. Your rights
Please note that you may only use/ benefit from some of the following rights in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – or please contact us using the details in section 12 below.
9.1 Right to restrict processing
In certain circumstances as outlined in the ICO guidance referred to above, you have a right to require us to stop processing your personal data in a particular way.
9.2 Right to erasure
You have the right to request that your personal data is erased from our records in certain circumstances.
9.3 Right of access
You have a right to ask for a copy of the personal data we hold about you. If you want to access your personal data, please send a description of the personal data you want to see and proof of your identity by post to The Data Protection Officer, Buckland Estate Office, Lawrence Lane, Buckland, Betchworth, Surrey RH3 7BE.
9.4 Right to rectification
We also want to make sure that your personal data is accurate and up to date. Please let us know if your details change. You may also ask us to correct or remove personal data which is inaccurate.
9.5 Right to object
You can also opt-out of receiving all or some of our marketing communications or request that we stop processing personal data about you for certain purposes at any time by contacting us using the details below.
9.6 Right to data portability
In certain circumstances you have a right to data portability which means we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format.
If you are unhappy with the way in which we have handled your personal data please contact us using the details below.
Please let us know if you have any queries or concerns about the way that your personal data is being processed by us by contacting us on the details below. You are also entitled to make a complaint to the Information Commissioner’s Office. For further information see the Information Commissioner’s guidance here.
11. Data retention
We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected. We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries. In some cases, we are also obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep records of contractual or financial matters).
Whilst the specific time periods vary depending on the circumstances, in general we will not keep records that include personal data for more than 10 years after a particular matter or exchange has concluded. If you ask us to stop sending you marketing communications, we will retain certain details, such as your name and email address, but only to ensure that you are not contacted again.
13. Websites and digital products
In this policy “Website” or “websites and digital products” refers to all Buckland Estates Entities’ websites, including the primary Buckland Park Lake website found at https://www.bucklandparklake.co.uk/, any associated sub-domains and websites facilitated and branded by Buckland Estate and all our digital products, such as email, applications and digital channels, including social media.