Privacy Information Notice
At the Lockinge Estate, we’re committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and what choices you have. Further information is contained in our Transparency Notice: Lockinge Trust Transparency Notice for Tenants, Customers, Contractors and Suppliers
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our services, you’re agreeing to be bound by this Policy.
1. Who are we?
We are the Lockinge Trust, an organisation providing over 200 commercial and residential properties for rent, as well as bespoke joinery services.
The Lockinge Trust is a discretionary trust. VAT Registration No. 434522862.
Office Address: Lockinge Trust, Lockinge Estate Office, Ardington, Wantage, Oxfordshire, OX12 8PP.
Full contact details can be found on our contact page.
2. How do we collect information from you?
We obtain information about you when you contact us to enquire about our services.
We also collect information from you if you leave a comment on our blog.
3. What information do we collect & how is it used?
We obtain information about you when you visit our website, and when you contact us to enquire about our services.
3.0. Sensitive Data
We do not gather sensitive personal data (e.g. health, genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions). We expressly request that you do not provide any such sensitive data to us.
3.1. Children’s information
Our services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.
3.2. Third Parties
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
We may pass your information to third party service providers who we have engaged for the purpose of completing tasks and providing services to you on our behalf (for example, we may provide your contact details to the Search Engine Optimisation company we work alongside). We disclose only the personal information that is necessary to deliver the service.
We also use a number of third party services to help us fulfil our contractual obligations – for example, our computers are backed up using a third party automated service called Backblaze. These third party services are listed in full below; we have verified that these third party services are GDPR compliant (or are working towards GDPR compliance), and are certified under the EU-US Privacy Shield Framework (or are working towards certification) where these organisations are based outside of the EU.
The following table outlines the personal data we collect and for what purpose. The table also outlines the third parties the data is processed by or shared with, and how long the data is stored for:
|Data Type||Description of Data||Legal Ground||Purpose for collecting||Third Parties involved||Data Retention|
|Email address & other contact information||Prospective clients, client & supplier contact information||Contract||To allow initial and ongoing contact with prospects, clients, suppliers, etc.||Giacom Message stream hosts the emails||Until request for deletion.|
|Contact details of other professional contacts||Legitimate interest||To enable communication with professionals including joint working|
|Backup of emails||History of email conversations||Contract||Cloud backup to ensure business continuity||Giacom Message stream hosts the email backup||Until request for deletion|
|Analytics||Website visitor behaviour (anonymised – full IP address is NOT stored)||Legitimate interest||To analyse popular content, website performance, etc – so we can further improve.||Google Analytics
We have signed DPA & anonymise IP addresses
|Server Logs||IP address||Legal obligation||To help prevent DoS (Denial of Service) attacks; for website security and diagnostics.||WP Engine||Server logs are stored unencrypted for 7 days, and then moved to an encrypted backup which is stored indefinitely and only accessible by WP Engine.|
4. Controlling your information
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation. If you wish to exercise these rights, please contact the DPO at firstname.lastname@example.org or in writing to the Lockinge Estate Office.
4.0. Requesting a copy of your information
Upon written request to the DPO at email@example.com, we will provide a statement regarding the personal data we hold on record about you.
4.1. Updating or correcting your information
The accuracy of your information is important to us. If your contact details change, or you become aware that any of the other information we hold is inaccurate or out of date, please contact us so we may update our records.
4.2. Deleting your information
You have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted upon request.
Users have the ability to leave comments on our blog. To maintain flow of conversation, blog comments will not normally be deleted (unless there is a compelling reason to do so), but all personally identifying information will be removed.
4.3. Automated decision making
We do not use any personal information for automated decision making or profiling.
5.0 Use of ‘cookies’
We us Google Analytics which sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible.
By using and browsing our website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of this website.
5.1. Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
The Lockinge Estate takes data security seriously. In order to protect your information from loss, misuse or unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
- Data minimisation
- Password best practice
- Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
- Staff training and accountability on data protection
A copy of our internal Data Protection Policy & Transparency Notice are available on request.
7. Data Breaches
Adkin’s internal ICT and Data Protection Policy includes a clear process for handing a personal data breach, should one occur.
Any data breaches that are discovered externally should be reported to the Data Protection Officer immediately. Where appropriate, Adkin will promptly notify any clients should any unauthorised access to their personal information have occurred.
If you wish to raise a complaint on how we have handled your personal information, you can contact our DPO directly and we will investigate the matter.
If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law you can complain to the Information Commissioner’s Office (ICO).