INTRODUCTION AND SCOPE OF THIS PRIVACY STATEMENT
Lois Hunt t/a Wilderness “we” want to give you the best experience possible. We use the personal information you share with us to make our services and your experience even better. This privacy statement aims to give you a clear view of how we use personal information that you provide, our dedication to protecting it, your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our websites, Wilderness itself, and how we use your personal information and the third parties we will share it with.
We use personal information for various purposes, as described in detail below.
WHO COLLECTS YOUR PERSONAL INFORMATION
Ocubis Ltd (Ocubis) and Wilderness jointly control the processing of any personal information collected through marketing cookies used on its website. Ocubis has its registered office at 15 Regent Street, London SW1Y 4LR.
PERSONAL INFORMATION WE COLLECT FROM YOU
“Personal information” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. Ocubis and Wilderness will collect various types of personal information about you, including the following (as applicable):
USE OF OUR PRODUCTS AND SERVICES
When you use our services we will ask for personal information (at the moment of collection we will explain what information is required in order for us to provide the particular service, and what information you may choose to provide), such as:
If you enquire about, visit or stay at Wilderness, we will ask for basic personal information (we will explain what information is required and what information you may choose to provide), such as:
Once you are registered as a guest or visitor, you may choose to provide us with additional personal information, such as:
INFORMATION WE COLLECT AUTOMATICALLY
We will also collect personal information about you when you interact with our brand and websites and how you use them, as follows:
SOURCES OF INFORMATION
Most of the information we collect about you will be personal information that you have voluntarily provided to us, for example, through our website, live chat etc. Other sources from whom we may obtain your personal information include:
HOW WE USE YOUR PERSONAL INFORMATION
The personal information we collect when you first log into our wi-fi will be used for identification and authentication purposes across Wilderness, so you can use the same account details to log in or access your information from any location on the Estate. It is necessary to process your personal data in this way for the performance of the wifi at Wilderness.
In addition, Wilderness will create an account for you with the information needed to provide you with our services. The personal information we collect from the above other sources listed above will be used in the format that it is received, or, where appropriate, may be combined with personal information we obtain from other internal or external sources. We use and analyse this personal information where necessary for the following purposes detailed below:
HOW WE SHARE YOUR PERSONAL INFORMATION
We treat your personal information with care and confidentiality and do not share it with third parties other than as set out below:
With other Group entities
Each Group entity that you interact with will share limited personal information which you provide when you sign up (your name, email address and contact number) with other Group entities for authentication purposes and centralised business administration. This is necessary for the performance of your contract with a Group entity.
Each Group entity may share information we keep in your profile with other Group entities if both entities are responsible for your personal information, or if the other entities are acting as our service providers and processing your personal information on our instructions or on our behalf. This sharing is to ensure that each Group entity has access to all data for which it is responsible, in order that it can comply with its legal obligations.
Each Group entity will also share your other personal information, as well as anonymised and aggregated information, with other Group entities. They will use this personal information for trend analysis, which is necessary for the purposes of their legitimate interests in analysing their performance.
The local office handling your booking will share information about your purchases when paying from one of the Wilderness buildings. Wilderness will share information collected through cookies used on the Wilderness website with the office handling your booking. We will collect and share information from marketing cookies on the basis of your consent. If you do not give your consent, we will only use functionality cookies. We will collect and share information from functionality cookies to meet our legitimate interests in ensuring that our website functions correctly and that we keep our records accurate and up to date. For more information about the types of cookies we use click here.
A complete list of Group entities can be found here.
With Service Providers
We will share the limited personal information you provide when you visit Wilderness (your name, email address, password and date of birth) with our wi-fi service providers for the purposes of identification and authentication, so that you can log on to the Wilderness wi-fi quickly and with the ease and speed you expect from us.
We will also share your personal information as necessary and only for the purposes and on the lawful grounds described above with various third parties who process your personal information on our behalf, such as hosting, payment and fraud management providers, credit scoring agencies and analytics platform providers. We require that these service providers and other third parties adhere to strict rules when processing your personal information, including to only use your personal information in accordance with Wilderness’ instructions and the applicable laws.
With Social Networks
Our website will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook or Twitter (for example by registering an account), your presence on our website will also be made available to that social network. This is necessary for the performance of your visit with Wilderness which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or apps or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings. If you would like to prevent this type of data transfer, please log out of your social network account before you enter one of our websites, or change the app’s privacy settings, where possible. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal information, what rights you have and how you can maintain suitable privacy settings for your needs.
With Legal and Law Enforcement
Wilderness will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Wilderness’ property and legal rights, to protect the personal safety of Wilderness’ website or by order of a valid injunction from a court or law enforcement agency.
With Your Consent
We will share your personal information with other third parties (different from those described above, for example, affiliated companies providing external services or products) in other limited circumstances. In these instances we will, where required by applicable law, obtain your consent to share your personal information in this way.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We are committed to protecting your personal information and implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
RETAINING YOUR PERSONAL INFORMATION
We will keep your personal information for two years from your last interaction with us, such as the date your account was deleted, your last purchase, or in some other way contacted or interacted, unless a longer or shorter retention period is required by law, is necessary in the course of legal proceedings or is otherwise needed for a particular purpose under applicable law.
The following are examples to illustrate how Wilderness keeps your personal information for as long as necessary for a particular purpose:
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
Unless stated otherwise, we store and process your personal information in the European Union. There will, however, be occasions when we need to transfer your personal information outside of the European Economic Area (“EEA”) to a country is not regarded under European Law as providing the same level of data protection as the country in which you normally use our products and/or services. For example, the personal information you provide when you sign up for a Wilderness visit will be stored in the European Union, and also by other Group entities and our cloud services providers located outside the EEA for the purposes of authenticating your account and business administration. In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as Pavilion, so your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the contact details below.
INFORMATION ABOUT CHILDREN
As a general rule, we do not intentionally collect personal information about children under the age of 16, unless this is provided as a part of your booking. If we become aware that we have inadvertently collected personal information about children under the age of 16, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it. Infortmation about your child(ren) would only ever be stored as a part of your booking and is not transferred to any other database or made searchable by Wilderness.
Where we know a child is above the age of 16, but considered a minor under applicable law, we will obtain parental/guardian consent prior to using that child’s personal information.
LINKS TO OTHER WEBSITES AND SERVICES
Our websites may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks).
We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Fair play and transparency are important to us. We are open about the personal information we collect and have implemented mechanisms to enable you to exercise any rights you might have with respect to your personal information.
Where we have obtained your consent in relation to any matter in relation to your personal information (e.g. your consent to receiving direct marketing messages or your consent to the placement of cookies on your device), you can withdraw this consent at any time by contact us using the contact details set out below or changing your cookie settings.
ACCESS TO, DELETION, AND CORRECTION OF PERSONAL INFORMATION
You can send us a request for access to this information at no cost using the contact details set out at the end of this privacy statement.
After receiving your request and sufficient information to verify your identity we will provide you with a copy of the personal information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such personal information is being used, its recipients and the origin of the information.
You may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information. You may also write to us at any time to object to our use of your personal information, restrict our use of your personal information, or request that we provide your personal information in a usable electronic format and transmit to a third party (right to data portability). We will comply with these requests in relation to your personal information in line with applicable law.
OPTING OUT AND UNSUBSCRIBING FROM MARKETING MESSAGES
All our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. You may also opt out for particular channels (for example email or post) as indicated in the message received in such channel or through your subscription portal.
If you would like to opt out of receiving Wilderness marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you could contact our:
Data Protection team
by E-mail at : Data.Protection@Ocubis.co.uk
Note that if you choose to opt out of receiving marketing messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalised or non-personalised marketing messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.
CHANGES TO THIS POLICY
Wilderness has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our online privacy statement in order to ensure that it is free of errors and clearly visible on websites, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. We may update this privacy statement from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites and/or mobile apps along with an updated version of the privacy statement.
If you have any questions about our use of your personal information, how to exercise your rights or about our privacy statement you are welcome to contact us:
By completing the form on our website: TBC
by E-mail at : Data.Protection@Ocubis.co.uk
if you prefer to contact us by regular mail, please send your request to the following address:
Data Protection Team
Lois Hunt t/a Wilderness
15 Regent Street
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority using their website.
LAST UPDATED: May 2018
LAST UPDATED: May 2018
WHAT YOU SHOULD KNOW ABOUT COOKIES
FIRST OF ALL… WHAT ARE COOKIES?
Cookies are small text files that are stored on your computer or mobile device when you visit a website. For this section, we conveniently use “cookies” as an umbrella term for techniques such as cookies, Flash cookies and web beacons. They don’t take much space and they will be removed automatically when expired. Some cookies expire at the end of your internet session, while others will be saved for a limited amount of time.
SECONDLY… WHAT ARE THE DIFFERENT COOKIE TYPES WE USE?
There are different types of cookies with different uses. Some are there just to allow you to browse the website and see certain features. Some give us an idea on your browsing experience, i.e. when you have trouble finding what you are looking for, so we can improve and make your future visit as pleasant as possible.
Cookies set by Wilderness are called “first party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer or mobile both when it visits the website in question and also when it visits certain other websites. We use first party and third party cookies for several reasons.
The most important cookies are the required cookies. They are essential and help you to navigate on the website and to use basic features, such as media plugins. Then there are functionality cookies that enable you to make an enquiry through our live-chat or online enquiry form. The performance and analytics cookies we use to improve our website. We also like to show you relevant promotions. To manage this we collect browsing data, which may be linked to a unique identifier to allow us to understand how you interact with Wilderness across different platforms as described in our privacy statement (click [here] for our privacy statement). Interaction cookies are used for you to interact with social media or to submit reviews. Targeting cookies, advertising cookies and social media cookies capture your preferences in order to show you relevant ads outside Wilderness sites. In addition, social media cookies may be used to track your activity over social media platforms.
are essential and help you navigate, move around on the website and see certain features. These cookies are required to enable core site functionality. These cookies are stored for the duration of your browsing session.
are there so we can give you an even smoother customer experience (e.g. these cookies help you to continue conversations with us after closing your session). These cookies allow us to analyse site usage so we can measure and improve performance. These cookies may be placed by us or a third party on our behalf (see our cookie opt-out tool) and are stored for the duration of your browsing session.
WHAT IF YOU DON’T LIKE COOKIES?
You can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings. Find out how this works for your browser here:
Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html
Note that you may visit http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to learn about the options that some of the third parties we work with offer for opting out of certain ad targeting activities. You will need to visit those websites from each browser and device that you would like to be covered by your opt-out. Because the opt-out tools may depend on cookies, you may need to visit these sites again to reinstate your preferences if you delete your cookies.
HOW OFTEN WILL YOU UPDATE THIS COOKIE STATEMENT?
The date at the top of this Cookie Statement indicates when it was last updated.
FINALLY…WHERE CAN I GET FURTHER INFORMATION?