Privacy Policy

BLACKTHORNS HOUSE LIMITED PRIVACY POLICY

BACKGROUND:

Blackthorns understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.theblackthorns.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1.    Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:

“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“personal data”    means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our”    means Blackthorns House Limited, a company registered in England and Wales under number 07182619, whose registered office is at Admiral House, Waterfront East, Brierley Hill, DY5 1XG(“the Company”).

2.    Information About Us
2.1    Our Site is owned and operated by Blackthorns House Limited, of Admiral House, Waterfront East, Brierley Hill, DY5 1XG (“the Company”)
2.2    If you have any queries about this please contact the Admin Director, Mel Samms by email  at mel.samms@theblackthorns.co.uk, by telephone 01384 880180 or by post at Admiral House, Waterfront East, Brierley Hill, DY5 1XG.

3.    What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.    Your Rights
4.1    As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1    The right to be informed about Our collection and use of personal data;
4.1.2    The right of access to the personal data We hold about you (see section 11);
4.1.3    The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4    The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5    The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6    The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7    The right to object to Us using your personal data for particular purposes; and
4.1.8    Rights with respect to automated decision making and profiling.
4.2    If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3    For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5.    What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 12 on Our use of Cookies and similar technologies and Our Cookie Policy https://www.theblackthorns.co.uk/cookies-policy/
5.1    name;
5.2    address;
5.3    contact information such as email addresses and telephone numbers;
5.4    demographic information such as post code, preferences, and interests;
5.5    IP address;
5.6    web browser type and version;
5.7    operating system;
 
6.    How Do We Use Your Data?
6.1    All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2    Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1    Providing and managing your access to Our Site;
6.2.2    Personalising and tailoring your experience on Our Site;
6.2.3    Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4    Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the link on our emails, by post or via our website);
6.2.5    Personalising and tailoring Our products for you;
6.2.6    Replying to emails from you;
6.2.7    Market research;
6.2.8    Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3    With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4    Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 12. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5    You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

7.    How and Where Do We Store Your Data?
7.1    Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
7.1.1    Ensuring that data is only stored by parties who undertake to comply with the GDPR.
7.2    Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

8.    Do We Share Your Data?
8.1    We may sometimes contract with third parties to supply services to you on Our behalf. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2    We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. Data will only be shared and used within the bounds of the law.
8.3    Certain third party data processors used by Us are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.4    In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9.    How Can You Control Your Data?
9.1    When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails, by post or on Our Site and at the point of providing your details).

10.    Your Right to Withhold Information
10.1    You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.2    You may restrict Our use of Cookies. For more information, see section 12 and Our Cookie Policy https://www.theblackthorns.co.uk/cookies-policy/

11.    How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held) using the contact details below in section 13.

12.    Our Use of Cookies
12.1    Our Site utilises Cookies and in addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies.
For more details, please refer to Our Cookie Policy https://www.theblackthorns.co.uk/cookies-policy/.

13.    Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at mel.samms@theblackthorns.co.uk, by telephone on 01384 880180 or by post at Admiral House, Waterfront East, Brierley Hill, DY5 1XG.

14.    Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations.