References to “you” or “your” are to you as an individual using our website or otherwise contacting us (including as a prospective or current consumer customer or on behalf of a business or commercial customer).
1 IMPORTANT INFORMATION
This version was last updated on 11 July 2018.
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.
Our website is not intended for children and we do not knowingly collect data relating to children.
2 WHO WE ARE
Camp Kerala provides luxury tent accommodation facilities at public events, such as Glastonbury Festival, and at private events.
We are bound by applicable data protection laws in respect of the handling and collection of your personal data. Camp Kerala is registered as a data controller in England and Wales, with the Information Commissioner’s Office (ICO) under the ICO number ZA330933.
3 CONTACT DETAILS
Our full details are:
Full name of legal entity: Camp Kerala LLP
Partnership Number: OC313055
Email address: [email protected]
Telephone number: +44 (0) 1749 860077
Camp Kerala LLP
Cockmill Croft Farm
4 WHAT DATA DO WE COLLECT ABOUT YOU?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data relating to a corporate entity.
We may collect, use, store and transfer different kinds of personal data about you, or your business, which we have grouped together as follows:
- Identity Data includes first name, last name and title.
- Contact Data includes address, billing address, email address, telephone number(s) and fax number(s).
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
- Profile Data includes your purchase history.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not generally collect Special Categories of Personal Data about you (this is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic data, biometric data, data concerning health, sex life, sexual orientation and information about criminal convictions and offences). However, we may collect such information indirectly in the following circumstances:
- when you provide details of your dietary requirements (which may reveal details of your personal health or religious beliefs) when purchasing our services in order for us to cater for you, and we have obtained your consent to process this personal data; and
- when you provide details of your special access requirements (which may reveal details of your personal health) when purchasing our services in order for us to cater for you, and we have obtained your consent to process this personal data.
The legal basis on which we process such data will usually be your explicit consent. However, in the circumstances, where we are unable to obtain such consent, the legal basis for such processing will be to protect your vital interests and/or to meet our specific legal obligations (for example, pursuant to equality and anti-discrimination legislation).
5 IF YOU FAIL TO PROVIDE PERSONAL DATA
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 provide you with our services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.
6 HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions with you
You may give us your Identity, Contact, Financial and Profile Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase our services;
- contact us using the details provided or through the enquiry form on our website; or
- request marketing to be sent to you.
- Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
- Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Squarespace based outside the EU.
- CCTV images
We may receive personal data about individuals who enter our property or premises from our CCTV monitoring equipment. Appropriate notices regarding CCTV monitoring are placed around our sites.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Legitimate Interest
This means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure 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.
- Performance of Contract
This means processing your data where it is necessary for the performance of a contract to which you are a party (for example when you express an intention to purchase our services) or to take steps at your request before entering into such a contract.
- Comply with a Legal or Regulatory Obligation
This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
This means agreement which must be freely given, specific, informed and be an unambiguous indication of your wishes by which you, by a statement or by a clear positive action, signify agreement to the processing of personal data relating to you. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email and for collecting special categories of personal data (as discussed above). You have the right to withdraw consent to marketing at any time by contacting us.
We have set out in the table below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
In a business-to-business context, we may make contact with you to provide or seek information in connection with our services or your products/services (or those of your employer). The legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interests in doing business together. When we make contact with you, you can exercise your right to object to such contact from us (for more information about your rights, please see no.71).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- Unsubscribe link displayed on every email marketing communication; and
- Individuals are able to report a change to their preferences to us and we will update our records accordingly.
Promotional Offers from Us
If you provide your express, opt-in consent, we may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us after you have requested information from us or purchased our services and, in each case, you have opted-in to receiving that marketing.
You can withdraw your consent at any time.
In some limited circumstances, we may contact you about similar products and/or services where you have purchased services from us and you have not opted-out of receiving this information.
We will get your express opt-in consent before we share your personal data with any company outside Camp Kerala for marketing purposes.
Opting Out / Unsubscribing
You can ask us or our third parties to stop sending you marketing messages at any time 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 of our services or other transaction.
Change of Purpose
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.
7 DISCLOSURES OF YOUR PERSONAL DATA
For the purposes set out in the table above (‘How we use your personal data’), we may have to share your personal data with the following parties:
External Third Parties
- Financial processors based in the EU who manage online payments and transactions.
- Service providers acting as processors based in the UK who provide website design and IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK (or other relevant jurisdictions) who require reporting of processing activities in certain circumstances.
- Other third party companies where we have an agreement in place and only where you have agreed that we may share your Identity and Contact Data with them.
Specific Third Parties
- Squarespace: Based in the US, who provide and host our website.
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 process your personal data for specified purposes and in accordance with our instructions.
8 INTERNATIONAL TRANSFERS
Individuals or customers who access our website may be based outside the European Economic Area (EEA) so the processing of their personal data will involve the transfer and storage of data outside the EEA. Some of our suppliers are based outside the EEA.
Whenever we transfer 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 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.
9 DATA SECURITY
We have put in place appropriate 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 employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
10 DATA RETENTION
How long will you use my personal data 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.
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.
We will generally retain our customers’ data for a period of 6 (six) years after you cease to be a customer, to ensure that we are able to assist you should you have any questions or feedback in relation to our services or to protect, or defend our legal rights.
Where we have processed your personal data to provide you with marketing communications, we may contact you at least every twenty-four (24) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a “do not contact” list).
Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with our services), subject to the periods discussed above, we will retain your data for twelve (12) months.
In some circumstances you can ask us to delete your data: see no.71 for further information.
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.
11 YOUR LEGAL RIGHTS AND COMPLAINTS
What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
- Request access
You may 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 we hold about you and to check that we are lawfully processing it.
- Request correction
You may request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure
You may 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 information unlawfully or where we are required to erase your personal data to comply with local law. 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
You may 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 information which override your rights and freedoms.
- Request restriction of processing
You may 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
You may 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
You may 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly.
You have the right to make a complaint at any time to the 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.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.