About this policy
This policy describes how we use your personal data when you use our websites www.holkham.co.uk and www.pinewoods.co.uk. We also use your data when you buy our goods or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.
You can read, print and save this whole policy or click on the links below to see specific information. We use sub-headings to help you find specific information that you may be looking for more easily, including information about:
Who we are and how you can contact us
We are Holkham Estate (registered as Coke Estates Limited) and associated companies. Our registered address is Holkham Estate Office, Holkham Estate, Wells-next-the-Sea, Norfolk, NR23 1AB. Associated companies include:
- Coke Estates Limited (also trading as Holkham Building Maintenance)
- Holkham Emerald Limited
- Holkham Enterprises
- Holkham Events Limited
- Holkham Farming Company Limited
- Holkham Game Partners
- Holkham National Nature Reserve Limited
- Holkham Holiday Parks Ltd
- The Holkham Estates Company Limited
- The Victoria at Holkham Limited
You can contact us in writing at Holkham Estate Office, Holkham Estate, Wells-next-the-Sea, Norfolk, NR23 1AB or by emailing email@example.com. If you would like to speak to us please telephone us on 01328 710227.
Please refer to the sections on Your rights to know what personal data we hold and to control how we use it and How to make a complaint for further contact information.
What personal data we collect about you
- personal data that you provide to us. There are lots of ways in which you may share your personal data with us. For example, you may register on our websites - www.holkham.co.uk or www.pinewoods.co.uk. You may post on social media sites that we run, namely Instagram, Facebook, Twitter, Google+, Flickr, Pinterest and YouTube. Or you may contact us in connection with goods or services that you would like to buy, or have already bought, from us. These include, but are not limited to, accommodation, holiday lettings, event ticketing, residential and commercial lettings, sporting and leisure events. The personal data that you provide to us may include your name, address, email address and telephone number, financial and credit card information, age, gender, dietary preferences, access requirements and any further information voluntarily provided to us by you.
- personal data that we receive from third parties. If we work with other businesses or use sub-contractors these parties may collect personal data about you which they will share with us. For example, we may have your name and contact details passed to us by our partners. These include, but are not limited to, Treasure Houses, online wedding and event directories that refer you to us so that we can provide you with our goods or services.
- personal data about your use of our website. This is technical information and includes details such as your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, such as scrolling, clicks, and mouse-overs.
- personal data from audio and visual recording equipment. This information includes, but is not limited to, CCTV, body cameras, video recording and stills and aerial photography.
- We have CCTV at the following sites: Holkham Hall, Holkham Studios, Pinewoods, Holkham Farming Company, external only at The Victoria Inn – covering the car park and entrance to Lady Anne’s Drive, Holkham giftshop, Wells Beach Café, The Lookout and north and south entrances/exits to Holkham park.
- For reasons of staff security and safety, some staff use body cameras, for example, car parking attendants, the Holkham National Nature Reserve team and at key events such as our open-air concerts.
What we use your personal data for
We use your personal data in the following ways:
- personal data that you provide to us is used to:
- provide you with the information, products and services that you request from us. These include, but are not limited to, accommodation, holiday lettings, event ticketing, residential and commercial lettings, sporting and leisure events.
- provide you with marketing information in accordance with your marketing preferences. (see How we use your personal data for marketing)
- manage and administer our business.
- review and improve our goods and service.
- personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
- personal data about your use of our website is used to:
- administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device.
- to allow you to participate in interactive features of our service, when you choose to do so.
- as part of our efforts to keep our site safe and secure.
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- personal data from audio and visual recording equipment is used for, but not limited to:
- security screening.
- estate management.
- marketing and promotion for which permission will always be sought.
When we need your consent to use your personal data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
- we are entering into and carrying out our obligations under a contract with you.
- we need to use your personal data for our own legitimate purposes, such as the administration and management of our business and the improvement of our services, and our doing so will not interfere with your privacy rights.
In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
Please refer to the section on How we use your personal data for marketing to read about marketing consents.
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our goods or services to you.
Your rights to know what personal data we hold and to control how we use it
You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter ‘Subject Access Request’ and send it to Holkham Estate Office at Holkham Estate, Wells-next-the-Sea, Norfolk, NR23 1AB or by email to firstname.lastname@example.org or by post or email using the details in the Who we are and how you can contact us section.
You also have rights to:
- prevent your personal data being used for marketing purposes. (see How we use your personal data for marketing for further details)
- have inaccurate personal data corrected, blocked or erased.
- object to decisions being made about you by automated means or to your personal data being used for profiling purposes.
- object to our using your personal data in ways that are likely to cause you damage or distresss.
- restrict our use of your personal data.
- require that we delete your personal data.
- require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file.
You can find full details of your personal data rights on the Information Commissioner's Office website at www.ico.org.uk.
Automated decision making and profiling
We do not make use of automated decision making or profiling.
How we keep your personal data safe
We take every care to ensure that your personal data is kept secure. The security measures we take include:
- only storing your personal data on our secure servers.
- ensuring that our staff receive regular data security awareness training.
- keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises.
- maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems.
- enforcing a strict policy on the use of mobile devices and out of office working.
Unfortunately, sending 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 personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features, some of which are described above, to try to prevent unauthorised access.
How we use your personal data for marketing
We will add your details to our marketing database if:
- you make an enquiry about our goods or services.
- you buy our goods or services.
- you have told a third party that you would like them to pass us your contact details so that we can send you information about our goods and services. As a business, we rely on a few third party services e.g. WeddingDates used by our weddings business, Holkham Events Limited. Data protection compliance is a prerequisite in our vendor selection process.
- you have opted in via other means e.g. offline data-capture forms or competitions.
We may send you marketing communications by email, telephone, post.
You can ask us to only send you marketing communications by particular method e.g. you may be happy to receive emails from us but not telephone calls, about specific subjects e.g. weddings and/or events, or you may ask us not to send you any marketing communications at all.
You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.
We will only share your personal data with third parties for marketing purposes if you provide us with your consent to do so by ticking a box on a form we use to collect your personal data.
When we will send your personal data to other countries
We store your personal data on a CRM system provided by a US supplier who has servers located in the US. We have verified that the US supplier is registered under the Privacy Shield.
Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact Coke Estates Limited to discuss this using the contact details set out in the Who we are and how you can contact us section above.
You are also entitled to make a complaint to the Information Commissioner's Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How long we will keep your data
Whenever we collect or process your personal data, we will only keep it for as long as necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised. You can always unsubscribe from our e-news; to unsubscribe from our postal correspondence, please telephone or write to us (see Who we are and how you can contact us). Our Google Analytics are set to ‘do not automatically expire’, identifying that data will be kept indefinitely (see our third party links/cookie functions).
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website www.holkham.co.uk or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown in the footer of the policy and the date on which that version of the policy came into force.
This is policy version 7 which came into effect on 24th May 2018 and has been checked and verified 16th June 2020.