PRIVACY POLICY

BACKGROUND:
The Gwrych Castle Preservation Trust understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our supporters, volunteers and customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us
The Gwrych Castle Preservation Trust. Limited Company (Company Registration No: 4331307) and Registered Charity (Charity Number 1092035)
Registered and main address: Gwrych Castle Preservation Trust,
Gwrych Castle, Abergele,
Conwy, LL22 8ET
Telephone number: 01745 826023

2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?
The website uses cookies – please view our Cookie Policy

We may collect some or all of the following personal data (this may vary according to your relationship with us):

· Name;
· Date of birth;
· Address;
· Email address;
· Telephone number;

CCTV – Some of our locations and properties have Closed Circuit Television (CCTV) and you may be recorded when you visit them.

CCTV is used to provide security and protect both our staff, visitors, and Gwrych Castle. CCTV will only be viewed when necessary (for example, to detect or prevent crime) and footage is stored for a set period of time, after which it is recorded over. Gwrych Castle complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is used.

6. How Do You Use My Personal Data?
Gwrych Castle Preservation Trust (“The Company”) will only use information collected about you in accordance with the Data Protection Act 1998 and any other applicable legislation.

The Company collects personal information from visitors to this website through your usage of this website (e.g. cookies) and when you e-mail the company your details for the purpose of registration i.e. name, postal address and e-mail address.

The Company may process information collected via this website for the purposes of: providing the Company’s services; answering your queries; dealing with your order(s) and account(s); and providing you with information about products and services.

To unsubscribe from products or services, you may opt-out by sending the Company an e-mail to gwrychtrust@gmail.com and or by post to Gwrych Castle Preservation Trust, Gwrych Castle, Abergele, LL228ET

The Company may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.

We do not send random marketing emails to personal email addresses (spam).

Under GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by writing to us in the address in Section 1).
· Process Gift Aid claims if you have requested us to do so.
· Co-ordinate your activities as a volunteer including compliance with Health and Safety legislation
· Maintain the accounts and records of the Trust

[With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on our products AND/OR [services]. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]

7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

· Supporter data while it is current, and for six months following Supporter expiry.
· Gift Aid and other accounting records will be retained for six years following the tax year to which they relate.
· Volunteer and employees data for six years.
· Applications for events and activities up to and including the date of the event and for twelve months after the event.

8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

· With HMRC in order to process Gift Aid returns if you have so requested
· If you are a volunteer and it becomes necessary to comply with Health and Safety legislation.
· In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request in not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Trust Secretary):

Email address: info@gwrychcastle.co.uk
Telephone number: 01745 826023.
Postal Address: Gwrych Castle Preservation Trust,
Gwrych Castle, Abergele,
Conwy, LL22 8ET

12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website: gwrychcastle.co.uk

13. Disclosure
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on our website: gwrychcastle.co.uk

14. Links
This Website may contain links to other websites which are outside the Company’s control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their own privacy policy.