Data Protection

WHO WE ARE

Mckinnon Jardine Leisure Ltd trading as Kenegie Manor Holiday Park
Trading Address: Kenegie Manor Holiday Park, Gulval, Penzance, Cornwall TR20 8YN

Any reference to “we”, “us” or “our” in this policy shall mean Mckinnon Jardine Leisure Ltd and our associated trading names. Throughout this policy “you” means the customer, leaseholder, supplier or employee.

Under the General Data Protection Regulation 2018, we constitute the ‘data controller and processor’ in relation to the personal information that we collect about you. As data controller we have certain legal responsibilities surrounding how we collect, use and share your personal information. We must inform you about this, and it is important for you to be aware of the rights afforded to you.

INFORMATION WE COLLECT

We collect information about you in which you provide to us through our website and through verbal or written communications with us. The types of personal information we collect from you include:
a) Information you provide to us – personal information that you provide to us including your contact details (for example and not limited to your name, email address, phone number and postal address) and your bank account details.
b) Your correspondence – if you contact us, we may keep a record of that correspondence;
c) Sales and services information – details of transactions that you make with us and details of the services we provide to you;
d) Credit, Anti-Fraud and identification information – information relating to your creditworthiness, or any criminal or fraudulent activities provided to us either by you or third parties, including information which establishes your identity, such as: driving licences, passports and utility bills; information about transactions, credit ratings from credit reference agencies; fraud, offences, suspicious transactions, Politically Exposed Person and sanctions lists, where your details are included.
e) Exclusively Leaseholders – if you purchase a property at Kenegie Manor Holiday Park we will also collect such things as name ,proof of residential addresses, telephone number, email address, dates of birth, bank details and other associated information. We may collect information about who will be utilising your holiday home property in order to provide them and you with membership of the facilities on park.
f) Exclusively Employees – if you are an employee of Kenegie Manor Holiday Park we will also collect such things such as proof of residential address, identification information (ie driving licence and birth certificate) , telephone number, next of kin details, dates of birth, bank details, national insurance number and other relevant information relating to your employment.

We may collect information about your computing including, where available, your IP address, operating system and browser type. We may use your information to: manage your account, carry out customer-care activities and we may also record and/or monitor calls for quality checks and staff training. Information may be used to monitor the quality and security of the website and test and maintain our IT systems; we may analyse your use of the services for marketing purposes, including, but not limited to, the page of our site you look at and the services you purchase as well as your browsing history and use of our websites. We will not pass responsibility of your information to other organisations.

CCTV footage – We may use CCTV cameras at some locations on our park for crime prevention and safety or licencing reasons.

HOW WE WILL USE YOUR PERSONAL INFORMATION

We may use your personal information to provide our services more effectively to you. For example: to administer our services, including handling your requests, communicating with you (including any offer and promotions); keeping up-to-date records about you, and carrying out our obligations arising from any contracts entered into between you and us, to make payments to you and receive payments from you (where applicable). This will also assist in keeping up-to-date records about you, and carrying out our obligations arising from any contracts entered into between you and us, to make payments to you and receive payments from you (where applicable).

We will use your information to help identify, develop or improve products that we believe may be of legitimate interest to you. The information will be used to enable us to monitor and analyse our business and carry out market research. This information will be used to enable us to monitor and analyse our business and carry out market research. This information may be provided to independent external bodies such as governmental departments and agencies to carry out research.

Your data may also be used for other purposes for which you give your permission or where we are permitted to do so by law or it is in the public interest to disclose the information or is otherwise permitted under the terms of the General Data Protection Regulation.

MARKETING

We may use your information to market to you, of which is subject to having obtained specific consent under Article 4 of the General Data Protection Regulation.
Marketing may consist of updates and offers about our products and services, as well as products or services provided by selected third party companies we believe will be of interest to you (see next section – Transfer of Personal Information).
We will ask for your consent at the time we collect your data to conduct marketing. Marketing services will be communicated via email, SMS, letter, brochure or telephone.

YOUR RIGHT TO WITHDRAW CONSENT FOR MARKETING

You have the right to withdraw your consent at any time. If at any time you do not want us to contact you for marketing purposes, you can let us know by contacting us using details in the ‘Contact us’ section (Section 9) of this privacy notice in writing, email or telephone. We will action your request immediately or within 3 working days
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you, or you may opt out by contacting us using our contact details if you wish to withdraw from receiving printed marketing material. We will action your request immediately or within 3 working days.

TRANSFERS OF PERSONAL INFORMATION

We may permit selected third-party companies to use your personal information, for the purposes set out in section 3 ‘How we use your personal information’. These companies will not use your information to contact you. Selected third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.
We work carefully with selected data processing companies such as:

We work to provide you with information about relevant insurance services. If we intend to pass on your details, we will inform you beforehand and give you an opportunity to object easily through the medium in which we have requested consent. If you tell us that you do not wish to have this information passed (and we are not legal required to do so), we will respect your wishes.

Your personal information may be accessed by staff or suppliers, in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA.

Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. Please see the full list here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

In countries which have not had these approvals, we will either ask for your consent to the transfer, or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.

Under the General Data Protection Regulations 2018, when personal information is being transferred outside the EEA, we as a data controller and processor, are under an obligation to ensure that such transfers are performed in a manner than ensures that your personal information is adequately protected. We may disclose and exchange information with law enforcement agencies and regulatory bodies should we be required to do so following legal request/obligations.

We may disclose and exchange information with law enforcement agencies and regulatory bodies should we be required to so following a legal request.

As part of the process of providing you with the product or service requested, we may undertake certain checks or exchange information through various fraud and credit-check databases.

HOW LONG WE KEEP YOUR INFORMATION

The periods for which we keep your information depend on the purpose for which your information was collected and the use to which it is put. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements. For example:
– When you expressed an interest in our products or services
– Where we have collected your details for us to provide you with information about our services

We will keep your information for 5 years unless you have requested that we stop holding or sending you information sooner. In the event that you have purchased a product from us, we will keep your personal information for so long as we are providing you with services, plus 2 years to deal with queries, complaints or legal claims you may have.

LEGAL GROUNDS FOR PROCESSING

The legal grounds we rely on to process your personal information, are that processing is necessary for:
a) Our legitimate business interests or those of a third party and these interests are not overridden by your interests or fundamental rights and freedoms in relation to the protection of your personal information. Our legitimate business interests include enabling us to provide you with products, services and information about our products and services (marketing) if in our reasonable belief that you have a legitimate interest in receiving Third party legitimate business interests include the promotion of insurance services to you so that we have sufficient insurance coverage at our site(s);
b) Our performance of a contract or services made with you. This includes our providing you with products and services and our taking steps at your request towards, and in anticipation of, providing you with products and services;
c) Our compliance with legal or regulatory obligations.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

If you have any questions in relation to our use of your personal information, you should first contact us. Please see the ‘Contact us’ in Section below. You have the right to request a copy of the information which we hold about you. This is called a Data Subject Access Request and is in reference to the following:

– Provide you with further details as to how we use your personal information
– Provide you with a copy of personal information we have collected about you
– Update any inaccuracies in the personal information we hold
– Delete any personal information that we no longer have lawful grounds to use.
– Object to our use of your personal information if our use of your personal information is causing you undue harm. In such cases we must cease using your personal information for that purpose

We may charge an administrative fee when a request is manifestly unfounded or repetitive. We may also charge a further administrative fee when you request for us to provide further copies of the information already provided to you.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We will acknowledge and respond to your request within one month of receiving your request. We will inform you of the third parties to whom your data has been disclosed.

Information will be provided without delay and within one month of receipt. This time span can be extended upwards of an additional two months depending on the complexity or amount to which have been requested. You will be informed if an extension is required within one month of the receipt of the request.

CONTACT US

If you have any questions, or you would like to find out more about this privacy notice you can contact us through written documentation, call or email. Please see as follows:
Data Controller
McKinnon Jardine Leisure Ltd, Kenegie Manor Holiday Park, Gulval, Penzance, Cornwall TR208YN.
Telephone: 0800 043 6449
Email: reception@kenegie-manor.co.uk

THIRD PARTY LINKS

Our site may contain links to third party websites. If you follow a link to any of these websites, please note that these websites have their own terms and privacy policies and that we do not accept any responsibility or liability for them.

CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and we will place any updates on this webpage. This privacy policy was last updated in May 2018