Privacy Policy for Avocet Inns Limited, trading as The Swan Inn, Lympstone
Effective Date: 1st October 2023
1. Introduction
Avocet Inns Limited (“we,” “us,”, “our” or “The Swan Inn”) is committed to protecting your privacy and ensuring that your personal data is handled responsibly and in compliance with the UK Data Protection Act 2018 (DPA 2018). This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you visit our pub, visit our website (https://www.theswaninn-lympstone.co.uk/) (“our website”) or interact with us.
It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.
2. Controller
Avocet Inns Limited is the data controller of, and responsible for, your personal data processed when visiting or contacting the Swan Inn or data processed through the use of our website.
We are registered with the Information Commisioner’s Office under Registration Number Z
3. Information We Collect
We collect and process personal information related to providing you with the best possible experience. The primary legal basis we intend to rely on for this purpose is legitimate interest. The types of personal data we may collect include:
• Contact Information: Your name, email address, telephone number, and postal address.
• Reservation Details: Information related to your reservations, including date, time, and party size.
• Transaction Data: Information about your purchases, or deposit payments at The Swan Inn, including payment card details, if applicable.
• Marketing Preferences: Your preferences for receiving marketing communications from us.
• Feedback: Any feedback, comments, or reviews you provide about your experience at The Swan Inn.
• CCTV Footage: We may capture CCTV footage for security and safety purposes while you are on our premises, and for the prevention of crime.
4. How We Use Your Information
We use your personal information for the following purposes:
• Reservations: To confirm and manage reservations you make at The Swan Inn. The lawful basis we intend to rely on for this activity is performance of a contract with you.
• Customer Service: To respond to your enquiries, requests, and feedback, on the basis of legitimate interest.
• Marketing: To send you promotional and marketing communications, where you have provided your consent or as permitted by applicable law. Where you have provided your details, such as an email address, we may email you on the basis of legitimate interest with details of future events, or promotions which we believe may be of interest to you, with due regard to your rights. You may opt out of receiving these communications at any time by contacting us on the details in Section 10 of this Policy, ‘Contact us’, below.
• Transaction Processing: To process your payments for purchases made at The Swan Inn, or deposits etc. The lawful basis we intend to rely on for this activity is performance of a contract with you.
• Security: To maintain the safety and security of our premises and visitors through CCTV footage. We intend to rely on the basis of legal compliance in order to meet our legal and regulatory obligations and for the prevention of crime and disorder.
• Legal Compliance: To comply with legal and regulatory obligations.
We will use your personal information only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another purpose which is compatible with the original one.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.
Due to the nature of our business, Avocet Inns Limited does not knowingly collect any Personal Identifiable Information from children under the age of 13. We encourage parents and guardians to observe, participate in, and/or monitor and guide childrens’ online activity.
5. Sharing Your Information
We may share your personal information with the following parties:
• Service Providers: We may share your data with trusted service providers who assist us in providing services such as reservations, payment processing, CCTV providers and marketing.
• The Health and Safety Executive, local authorities, HMRC, law-enforcement agencies and any other central or local government bodies (in certain circumstances), where we are required to provide personal data to comply with our legal obligations or where it is requested and we may lawfully disclose it – eg for the prevention and detection of crime or to report serious health and safety incidents
• Business Transfers: In the event of a sale, merger, or acquisition of Avocet Inns Limited, or the Swan Inn, your information may be transferred to the acquiring party.
We do not allow our third-party processors to use your personal data for their own purposes. We permit them to process your personal data only for specified purposes and in accordance with our instructions.
Any payment transactions carried out by us or our chosen third-party provider of payment-processing services will be encrypted.
6. Your Rights
You have the following rights regarding your personal data:
• Access: You can request access to the personal data we hold about you.
• Rectification: You can request corrections to inaccurate or incomplete data.
• Erasure: You can request the deletion of your data under certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for our continuing to process it. You also have the right to ask us to delete or remove your personal data where you have 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 the law. However, please note that, for specific legal reasons which will be notified to you at the time of your request (if applicable), we may not always be able to comply with your erasure request.
• Objection: You can object to the processing of your data for direct marketing purposes or where we are relying on a legitimate interest because you consider that it affects your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Data Portability: You can request a copy of your data in a structured, commonly used, and machine-readable format, for example a spreadsheet.
In order to access, rectify, or request erasure of your data, please contact us using the details in Section 10 of this Policy, ‘Contact us’, below.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, in these circumstances, we could refuse to comply with your request.
What we may need from you
We may need to request specific information from you to help us to confirm your identity and to 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 about your request, to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month, but it could take longer – if this is the case, we will notify you and keep you updated.
7. Use of our website
When visitors use our website we follow a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
Like any other website, we use ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
Our website may contain links to other websites. This privacy notice only applies to our website so when you link to other websites you should read their own privacy policies.
8. Security Measures
We take appropriate security measures to protect your personal data against unauthorised access, loss, disclosure, alteration, or destruction.
9. Data Retention
We will retain your personal data only for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
In some circumstances, you can ask us to delete your data – see Section 6 above, ‘Your legal rights’, above, for further information.
10. Contact Us
If you have any questions, concerns, or requests related to your privacy or this Privacy Policy, including any requests to exercise your legal rights please contact Darren Newman by email or post:
Email: [email protected]
Postal Address: Avocet Inns Limited, The Swan Inn, The Strand, Lympstone, Exmouth Devon EX8 5ET
11. Changes to the privacy policy and your duty to inform us of changes
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal compliance. The updated policy will be posted on our website, and the effective date will be revised accordingly. This policy was last updated in October 2023 and we aim to keep our privacy policy under regular review.
It is important that the personal data we hold about you be accurate and current. If any of the details we hold about you change, please update us, so that we can ensure that our records reflect these changes.
By visiting The Swan Inn, using our website, or otherwise interacting with us, you consent to the practices described in this Privacy Policy.
