Legal

Privacy Policy

Introduction

The Goodwood Art Foundation CIC knows that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This notice describes The Goodwood Art Foundation CIC's privacy policy; please read it in order to understand what we do with your information.

This privacy notice aims to give you information on how the The Goodwood Art Foundation CIC Group collects and processes your personal data. By visiting Goodwoodartfoundation.org or accessing and using our services, you are accepting and consenting to the practices described in this Privacy Notice and our Cookie Policy.

Who we are and how you can contact us

The Goodwood Art Foundation CIC is responsible for this website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email these to dataprivacy@goodwoodartfoundation.org

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance

In accordance with the UK Data Protection Act 1998, the Goodwood Art Foundation CIC is registered with the United Kingdom's Information Commissioner's Office as a data controller to collect information:

Goodwood House, Goodwood, Chichester, West Sussex, PO180PX

Registered Company Number: 14211037
ICO number:

Contact details:

Data privacy manager
Email address: dataprivacy@goodwoodartfoundation.org
Postal address: Goodwood House, Goodwood, Chichester, West Sussex, PO180PX
Telephone number: 01243 755000

The data we collect about you

All personal information that we collect about you will be recorded, used, and protected by us in accordance with applicable data protection legislation and this privacy policy. We may supplement the information that you provide with other information that we obtain from our dealings with you or which we receive from other organisations, for example, our sponsors and partners.

The type of data we collect about you includes:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender, job title, your image, car registration numbers and motor insurance policynumbers.
Contact Dataincludes billing address, delivery address, email address and telephone numbers.
Financial Dataincludes bank account and payment card details.
Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us.
Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, as well as your journey through our digital platform (such as the links you click on and searches you make), which videos you have watched and for how long, what content you like and share, your subscription status, which pop up or push messages you might have seen and responded to and information collected in any forms you complete. We may also analyse which marketing activity led to your taking specific action on our digital platforms (e.g. downloading the app).
Profile Data includesyour username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Dataincludes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Sensitive Personal Data includes data about your health or dietary requirements (we do not collect any other type of sensitive personal data).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data doesnotdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with thisprivacynotice.

In certain situations, we may collect Special Categories of Personal Data about you but this is limited to information about your health where this is required for certain activities and biometric data for some aspects of security.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Individuals under 16

Goodwood Art Foundation CIC does not intentionally or knowingly process personal information from individuals under the age of 16, with the following exceptions:

lessons for children in golf, driving and swimming;
some of our pleasure or leisure experiences;
use of actors at our events; and
school visits to our Education Centre.

When necessary, underage users will be told not to submit any personal details and we will make every effort to delete any details of such users where a parent or guardian has informed us that these details or applicable data as defined by law have been collected.

Where we collect data relating to children we have a separate privacy notice which can be accessed here

How your personal data is collected

We use different methods to collect data from and about you including through: Direct interactions:You may give us your data by filling in forms, using our website, using Wi-Fi, by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

attend one of our events;
apply for membership of one of our clubs;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition or promotion;
surveys; or
give us some feedback.

Automated technologies or interactions.As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

CCTV We operate a number of CCTV cameras across our premises and at our events.

Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources, such as:

Technical Data from analytics providers such as Google; advertising networks and search information providers all based inside or outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU;
Identity and Contact Data from data brokers or aggregators such as Mint based insideoroutside the EU and from publicly available sources such as Companies House and the Electoral Register based inside the EU;
Identity, Contact and Financial Data from land agents such as Savills based in the EU.
Identity, Contact, Marketing and Communications Data from research or marketing agencies such as Two Circles.

How we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the reasons we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose of processing	Our legal basis for processing your personal information
To register you as a member of any of our memberships or clubs and to manage and administer this	Legitimate interests - to administer your membership and manage our relationship with you, so that you get the full benefits of your membership
To communicate with you about and to manage your order for a product or service, reservation, booking or appointment and to provide you with these	Contractual necessity – to meet our obligations under our contract with you (for example, to deliver a produce you have ordered) Legitimate interests – to contact you with details of the service, product, booking or appointment; to be efficient about how we administer and deliver these; to deal with all enquiries and to recover payments due to us
To provide you with information about our products and services, as well as free gifts, vouchers, offers and discounts	Legitimate interests – to understand which of our products, services and activities (or those of our sponsors and partners) may interest you and to tell you about them, to contribute to the overall commercial success of the business by marketing such products, services and activities to existing customers or to those who have purchased a product or service, signed up, made a booking, or who are currently in negotiation or have negotiated for the purchase of our products, services or activities. In some cases (such as where we’re required to do so by law) we will ask for your consent before sending you this information, in which case we rely on consent and not legitimate interests as our legal basis.
To review, develop and improve our brand, products and services. For example, calls to our customer services may be monitored and/or recorded for quality control and training purposes. If you raise a query (for example about a product or about our service) while we still hold a recording of your call, and we can investigate or answer your query by referring back to this call, we may do so. This may mean that your call recording will be held until your query has been resolved.	Legitimate interests – to develop and test products and services via your feedback in order to deliver the best quality to you and our other customers, to define types of customers for new products or services and to improve your customer journey
To notify you about changes to our services and products and to otherwise communicate with you	Legitimate interests – to keep you up to date with information about our services and products, and to respond to your queries or complaints
To enable you to participate in a prize draw, competition or complete a survey	Legitimate interests – to administer and run competitions and other promotions
To monitor details of your activity on our digital platforms for business and data analysis purposes	Legitimate interests –to respect your preferences and so personalise and improve your experience on digital platforms; to help us understand the effectiveness of our advertising and to make sure you see adverts that are most relevant to you; to provide you with tailored advertising; and to enhance your experience when using our digital platforms, to review your past purchases and viewing history on our website to provide you with special offers or to tailor your experience online.
To operate an effective PR process, including media accreditation, relationship building	Legitimate Interests - to manage effectively the flow of information between us and the public; to provide exposure to our audiences using topics of public interest and news items
To process invitations, experiences and guest lists	Legitimate interests - to deliver your guest experience Where the personal information constitutes special categories of personal data (e.g. dietary requirements or health data) we will process the information on the basis that it is necessary to comply with legal requirements
To administer and protect our business, carry out security checks and to detect, investigate, report and seek to prevent crime, fraud or threats to security	Legitimate interests – to protect and manage risk for our business and customers; to protect against unlawful activities and to develop and improve how we do so In some cases, we may also be under a legal obligation to disclose your personal information (for example, to law enforcement agencies)
To obey laws and regulations that apply to us or our customers or contracted third parties	Compliance with legal obligation – to comply with and be efficient about how we fulfil our legal and regulatory duties and obligations
To manage disputes, claims and complaints	Legitimate interests – to address any complaints or claims that are made against us. In some cases, we may also be under a legal obligation to disclose your personal information (for example, accident logs or CCTV footage with our claims handlers and insurers); Legal proceedings – Where the personal information constitutes special categories of personal data (e.g. health data) we will process the information on the basis that it is necessary for the establishment, exercise or defence of legal claims (as the case may be).
To enforce or apply our various Terms and Conditions, Website Use Terms or other agreements we have with or otherwise concerning you	Legitimate Interests – to conduct and manage our business Contractual necessity – to meet our contractual obligations
To manage our financial position, business capability, corporate governance or audit functions or to protect our rights, property or safety or those of our customers, employees or other third parties.	Legitimate Interests – to conduct and manage our business Compliance with legal obligation - to comply with our legal and corporate obligations
To fulfil landlord obligations and manage tenancies	Compliance with legal obligation - to comply with our legal obligations as a landlord or licensor Contractual necessity - to fulfil our contractual obligations to you as our tenant or licensee Legitimate interests - to keep the records of our property portfolio updated and to manage any tenancies or property arrangements you may have with us.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by lemailing us at dataprivacy@goodwoodartfoundation.org.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of membership of a club as we will still need to contact you regarding your membership, or where it is necessary to send you service emails.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

We may also participate in Facebook's ‘Custom Audience’ service from time to time. This service enables The Goodwood Art Foundation CIC to display to you personalized advertisements when you visit Facebook’s social media platforms. It works by converting your email address to a unique number that Facebook uses to match to unique numbers that Facebook generates from email addresses of its users. Where we use Facebook Custom Audiences, we will only include you if you have consented to receive marketing from us.

International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Data security

We may monitor or record telephone calls for security purposes and to improve the quality of services that we provide to you.

Please note that for your safety and security, CCTV is in operation in all of our premises which are open to the public.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You have the right to ask Goodwood Art Foundation CIC to provide you with all the information it stores on you. If you wish to access your personal data you can make a Subject Data Access Request by contacting dataprivacy@goodwoodartfoundation.org.

You have the right to ask Goodwood to rectify, block, complete and delete your personal data, to restrict its use, and to port your data to another organization. You also have the right to object to the processing of your data by Goodwood Art Foundation CIC in some circumstances and, where we have asked for consent to process your data, to withdraw this consent.

You may contact dataprivacy@goodwoodartfoundation.org if you would like assistance with any of the aforementioned rights.

There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if Goodwood Art Foundation CIC is legally prevented from disclosing such information. In addition, Goodwood may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process your data.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully 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 local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the privacy manager at dataprivacy@goodwoodartfoundation.org

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and 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 in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.