Privacy Notice

PRIVACY NOTICE (MAY 2024)

 PLEASE READ OUR PRIVACY NOTICE CAREFULLY

 

Information about Mornacott Conservation

Mornacott Conservation Limited (company number 14788378)) (Mornacott Conservation, our, us or we) is the entity responsible for the collection and use of personal data in connection with the business and trading activities it conducts relating to the conservation site known as ‘Mornacott Estate’ in Bishops Nympton, South Molton, Devon (including the self-catering holiday cottages business operated under the trading names ‘Mornacott’ or ’Mornacott Cottages’ (Mornacott). We are registered as a data controller at the Information Commissioner’s Office (ICO) with registration number ZB537393.

 

Information about our Privacy Notice

Our Privacy Notice applies to individuals who provide personal data to Mornacott Conservation, including (without limitation) any personal data provided to us by our commercial or residential tenants or licensees, visitors or guests (including those visitors or guests who enquire about staying, or book to stay, at Mornacott), contractors or suppliers (including prospective tenants, licensees, visitors, guests, contractors or suppliers) including (without limitation) through our website (www.mornacott-cottages.co.uk) (our site) or social media channels (including www.instagram.com/mornacott.devon) (our social media channels).

Your privacy is important to us. We are committed to protecting and respecting your privacy and ensuring compliance with data protection laws. Our Privacy Notice gives you information about how we collect, use and protect any personal data that you provide to us. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

 

Why does Mornacott Conservation use personal data?

Personal data is any information about an individual which can identify that person. We will only use your personal data when the law allows us to.

Under the Data Protection Act 2018 and the General Data Protection Regulation as enacted in the United Kingdom (UK GDPR), we can only use your personal data if we have a proper reason. For example:

  • where you have given consent;
  • to comply with our legal and regulatory obligation;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

Set out below is a description of all the ways we expect to use your personal data. We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so. Please note that we may use your personal data without your knowledge or consent where this is required or permitted by law.

We may use personal data in the following ways:

  • to undertake any contractual or legal obligations we owe to you or others;
  • to deal with any enquiries or process any applications submitted by you to us;
  • to request feedback from you about your experience and/or stay at Mornacott;
  • to allow you to access our site;
  • to provide you with information, newsletters and other updates, products or services that you may request from us;
  • to provide you with other information that is similar to that which you have already enquired about or that we feel may interest you;
  • to conduct business and estate management activities at Mornacott (including maintaining and updating guest records and for health and safety compliance purposes);
  • to improve our site and ensure that content from our site is presented in the most effective manner for you and for your computer or other device;
  • to monitor and administer our site and keep it secure, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • for internal operations (for example, statistical analysis to help us manage our business); and
  • for audit purposes and record keeping.

We may combine personal data we receive from other sources with the personal data you give to us or that we collect about you.

We may use personal data we receive from other sources and/or combined personal data for the purposes set out in our Privacy Notice (depending on the types of personal data we receive).

 

Marketing information

We will only use your personal data for marketing purposes with your consent unless another lawful basis applies. You will be given the opportunity to opt out of receiving any marketing information by checking certain boxes on any forms we use to collect your personal data or unsubscribing from marketing emails via the hyperlink provided in such emails. You may also opt out of receiving any future marketing information at any other time by contacting us using the contact information set out in the ‘How to contact us’ section of our Privacy Notice. Please note that, even where you opt-out of marketing communications from us, you may still receive service messages from us where we need to send you important information for a particular reason (for example, relating to an existing booking).

If you stay at Mornacott and choose to write a review of your experience either online (including Trip Advisor and Google reviews) or in Mornacott’s physical guest books (which are available on-site), such review (or extracts therefrom) may be posted on our site or our social media channels, or the websites or social media channels of our eco-tourism partners (including our estate, conservation and property management service provider, Oxygen Conservation Limited (Oxygen Conservation) (which also operates the Oxygen Escapes eco-tourism brand)) and selected booking platforms and systems), however we will not identify you unless you authorise us to do so. Where you have opted to receive marketing information from us, we may share your personal data with Oxygen Conservation to provide you with special offers, and news and updates, about other eco-tourism venues which it operates.

 

How does Mornacott Conservation get personal data?

You may provide your personal data to us by making enquiries, sending us feedback, filling in forms or submitting applications to us or by corresponding with us or Oxygen Conservation by phone, e-mail or otherwise. This includes providing information via our site, email addresses (including info@mornacott.co.uk) or our social media channels, Oxygen Conservation’s websites (including www.oxygenconservation.com and www.oxygenescapes.co.uk), email addresses (including hello@oxygenconservation.com) or our social media channels, or our third party service providers, for example the online booking platforms and systems used for stays at Mornacott.

 

What personal data does Mornacott Conservation collect?

We may collect the personal data about you or other persons (for example, other members of your booking for Mornacott) that you give us about you and them, such as (without limitation and as applicable):

  • name;
  • gender;
  • date of birth;
  • postal address;
  • e-mail address;
  • social media handles;
  • telephone number (mobile and/or landline);
  • financial information (including credit ratings);
  • details of your dependents;
  • photograph; and
  • other information regarding work, education and employment history, activities and personal circumstances.

We may also receive personal data about you from:

  • our estate, conservation and property management service provider, Oxygen Conservation;
  • our contractors or suppliers, including the online booking platforms and systems used for Mornacott;
  • commercial data providers; and
  • publicly available sources.

In the event that we buy any business, property or assets or enter into any joint venture arrangements, we may receive personal data about you from the seller of such business, property or assets or our joint venture partners.

Please note that any payment information you provide (for example, when paying for your stay at Mornacott) will be processed directly by secure PCI compliant payment gateway provider(s) and we will not have access to it.

With regard to each of your visits to our site, we may automatically collect the following personal data (which may not be personally identifying by itself, however it may be possible to personally identify you if combined with other personal data):

  • technical information, including the internet protocol (IP) address used to connect your computer or other device to the internet, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from our site.

 

Cookies

A cookie is a small text file which is placed onto your computer or other device when you use our site. We use cookies to help with website functionality and to improve your browsing experience. We will seek your consent to place cookies if they are not essential to core functionality such as security, network management and accessibility of our site.

‘Necessary’ cookies enable core platform functionality and features such as security, network management and accessibility and do not require user consent to be set. Cookies that enable functionality that is not strictly necessary for core platform functions and features are classed as ‘Optional’ and therefore consent is sought via a cookie banner.

For further general information about cookies and how to delete or control cookies stored on your computer or other device, you can visit www.aboutcookies.org or www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

 

Third party websites

Our site may include links to third party websites (including our social media channels), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third party websites, plug-ins or applications and are not responsible, and do not accept any liability, for their compliance with data protection laws.

When you leave our site, we encourage you to read the privacy notices of every website you visit or plug-in or application you download, in particular before submitting any personal data to those websites, plug-ins or applications.

 

How does Mornacott Conservation share personal data?

Oxygen Conservation has been appointed by Mornacott Conservation as our estate, conservation and property management service provider, and its services include management and operational responsibility for our business and trading activities at Mornacott.

We may transfer any personal data we may collect about you, including personal data that you have provided to us, to Oxygen Conservation for any reason in connection with such appointment, and Oxygen Conservation may transfer such personal data to third parties for the same purpose.

We may also share your personal data with:

  • any companies within our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006, and any associated companies which have common ownership. This may include (without limitation), Oxygen House Group Limited (which operates oxygenhousegroup.com) and Oxygen House Limited (which operates www.oxygenhouse.com);
  • selected third parties, including business partners and service providers in connection with the performance of any contract we enter into with them or you and third parties who provide email delivery, customer relationship management and helpdesk services, IT hosting services or any other services which we choose to outsource;
  • research partners and project collaborators (including prospective research partners and project collaborators);
  • analytics and search engine providers that assist us in the improvement and optimisation of our site; and
  • other third parties:
    • in the event that we sell any business, property or assets or enter into any joint venture arrangements, in which case we may disclose or transfer your personal data to the buyer of such business, property or assets or our joint venture partners;
    • if we are under a duty to disclose or share your personal data with any regulatory or law enforcement authorities and are required to do so;
    • in order to exercise or defend our legal rights or in connection with any legal proceedings or anticipated legal proceedings; and
    • in order to comply with any other legal obligation or enforce or apply our Terms of Use and any other agreements.

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 use your personal data for specified purposes and in accordance with our instructions.

 

How long is personal data stored for?

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 and to welcome your repeat business.

To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we use your personal data, whether we can achieve those purposes through other means and applicable legal requirements. Different retention periods may apply for different types of personal data.

 

Where is personal data stored?

The personal data we collect is stored and/or processed where we or our partners and third-party service providers maintain facilities.

The UK, the European Economic Area (EEA) and other countries outside the UK and EEA have differing data protection laws. It may be necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

 

Security of personal data

We have put in place appropriate physical, electronic and managerial 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 directors, employees and third parties who have a business need to know. They will only use your personal data for specified purposes and are required to keep your personal data confidential.

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.

Unfortunately, the transmission of information 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 our site or our social media channels; any transmission is at your own risk.

 

Your rights

In certain circumstances, you have legal rights under UK GDPR in relation to your personal data which are known as data subject rights. Those rights are:

  1. The right to be informed of processing.
  2. The right to access personal data by making a subject access request.
  3. The right to rectification where personal data is inaccurate or incomplete.
  4. The right to erasure, sometimes called ‘the right to be forgotten’.
  5. The right to restrict processing.
  6. The right to data portability.
  7. The right to object to processing.
  8. The right not to be subject to a decision based solely on automatic processing.

Where you seek to exercise any of your data subject rights, we may need to request specific information from you to help us confirm your identity and establish your right to exercise such rights. This is a security measure to ensure that your 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 exercise your data subject rights to speed up our response. Your legal rights do not apply in all instances. We will inform you if, in the context of your request, we do not consider that your legal rights apply.

If you wish to exercise any of your data subject rights set out above, please contact us using the contact information set out in the ‘How to contact us’ section of our Privacy Notice.

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.

You have the right to make a complaint at any time to the ICO regarding our collection and use of personal data. However, we would appreciate being given the chance to help you with your concerns before you approach the ICO, so please contact us using the details below in the first instance.

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.

 

How to contact us

As explained above, Oxygen Conservation has been appointed by Mornacott Conservation to manage and operate our business and trading activities at Mornacott, including our privacy procedures and practices. Accordingly, if you have any questions or would like more information about the collection and use of personal data by Mornacott Conservation, please contact Oxygen Conservation by sending an email to hello@oxygenconservation.com or by writing to us at Oxygen Conservation Limited, Oxygen House, Grenadier Road, Exeter, Devon EX1 3LH. If your query relates to your stay at Mornacott, you can contact our team directly via info@mornacott.co.uk.