Data Protection and Privacy Policy

  1. Information about us

The Caravan Club Limited, trading as Experience Freedom, is the owner and operator of experiencefreedomcycling.co.uk (our CycleFest website). We are a company limited by guarantee registered in England and Wales under company number 646027. Our registered company address is: The Caravan Club, East Grinstead House, East Grinstead, and West Sussex RH19 1UA. Our VAT number is 239719331.

  1. Contact us

If you would like any information about CycleFest please email enquiries@experiencefreedom.co.uk. You can also write to Experience Freedom at East Grinstead House, East Grinstead, West Sussex RH19 1UA. If you have any queries relating to this Privacy Policy, please contact the Data Protection Officer by letter at the address above.

If you would like to get in touch, you can send us a message on our Contact Us page.

Thank you for using our website.

  1. Privacy Policy

3.1. Our policy

Experience Freedom (We) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our policy and practices regarding your personal data and how we will treat it. By visiting our website you are accepting and agreeing to the practices described in this policy.

For the purpose of compliance with UK data protection law, the data controller is The Caravan Club Limited and the Data Protection Officer is our nominated person for data protection.

3.2. How do we collect information?

Your personal data, that is any information which identifies you, or which can be identified as relating to you personally, for example, and not limited to: name, address, phone number, email address, will be collected and used by us.

We obtain personal information from you when you enquire about our activities, register for events,   send or receive email, ask a question or otherwise provide us with personal information. We may also receive information about you from third parties, for example, our service providers or from a friend who wants to tell you about our website.

Examples of ways that you may share your personal data with us are by:

  • completing electronic and paper forms
  • registering for events
  • entering a competition, promotion or survey,
  • corresponding with us by email, social media or letter

We will inform you at the point of collection what the purpose of the data processing is and provide you with the relevant information to access this Privacy Policy.

3.3. What information do we collect?

The personal information we collect will depend on the nature of the data processing requirement. For example, it might include name, date of birth, email address, postal address and telephone number.

We also gather general information about the use of our website, such as which website pages users visit most often and which services, events or facilities are of most interest. We may also track the pages users visit when they click on links in emails and we may use this information to personalise the way our website is presented when users visit it, to make improvements to our website and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our website.

3.4. How do we use this information?

Depending on your relationship with us, we will use your personal information for the following purposes:

  • to provide you with the services or information you have requested
  • to administer your event booking
  • to provide information to you about us and third parties
  • to enable you to transact within certain areas of our website and perform activities such as make event bookings, enter competitions or sign up for a newsletter
  • for general administration purposes, such as handling your enquiries and managing the administration of services
  • to carry out research into the market for our goods and services
  • statutory and regulatory compliance
  • to prevent and detect fraud

As part of this, we may analyse the personal information we collect to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information. Where relevant, we may also assess your personal information for the purposes of fraud and credit risk reduction.

If you enter your contact details in one of our online registration forms, we may use this information to contact you even if you do not “send” or “submit” the form. We will only do this to see if we can help with any problems you might be experiencing with the form or with our website.

We may need to share your information with our service providers, associated organisations and agents for the purposes described above but we never sell your information to other organisations.

3.5. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

3.6. Processing your personal data for analytics

We know it is important to our website visitors to provide the best, tailored service possible. To help us do this, we use automated profiling and targeting to understand our visitor’s requirements and make sure that our communications (e.g. emails) and services (e.g. our website) are relevant, personalised and interesting to you, and our services meet your needs.  

To do this we’ll analyse how you interact with us on our website and other websites you may visit through use of data from bookings and use both geographic and demographic information to let you know what’s happening in your local area, nationwide and overseas and better understand your interests. We use specific tools, such as Google Analytics and Double Click for Advertisers, to look at how you interact with us online. Much of the information we collect is aggregated, however we may also collect some personal data for the use of personalising your experience, optimising our marketing campaigns, and to ensure the website site is functioning as intended.

3.7. How we use personal data to conduct research

We may carry out research to generate feedback on your experiences with us. We use this feedback to improve the experiences that we offer and ensure we know what is relevant and interesting to you. If you choose to take part in research, we’ll tell you when you start what data we will collect, why and how we’ll use it. All the research we conduct is optional and you can choose not to take part. We may share your personal data, e.g. contact information, to a third party data processor who will carry out research on our behalf, but only for the purpose explained here.

3.8. How do we protect your personal information?

All pages within our website are protected by encryption and we also use secure third party payments services when you make a payment via our website. We take appropriate measures to safeguard personal information that is disclosed to us and keep it secure, accurate and up to date. We utilise established market leading services for many of our processing activities which are compliant with stringent privacy and security standards based on industry best practices.

3.9. How do we store your information, and do we send it outside the European Economic Area?

Experience Freedom’s operations are based in the UK and we store most of our data on secure cloud based services. Some organisations which provide services to us may transfer data outside the European Economic Area but we’ll only allow this if your data is adequately protected.

To protect your data when it is transferred outside the European Economic Area we will either:

  • put in place contract clauses approved by the European Commission or the relevant data protection regulator to protect your data;
  • ensure that the country that the data is transferred to has been approved as adequate for data protection by the European Commission; or
  • ensure the one of the other safeguards set out in the relevant data protection laws is in place.

Sometimes is may be necessary for us to transfer data out of the European Economic Area without us being able to put these safeguards in place. We will only do this where the law permits, for instance if the transfer is necessary to perform a contract with you.

3.10. Will we disclose the information we collect to third parties?

As indicated above, we may pass your information to our service providers, agents and associated organisations.

We share information with other data controllers and instructed data processors. Categories of recipients normally include:

  • event organisers
  • social media hosting services
  • communication distribution and marketing companies
  • third party sponsors
  • infrastructure service providers
  • cloud service providers
  • data storage, redaction and destruction partners
  • subcontractors we appoint to provide services to you  

The event organisers will only use personal information to provide you with services relating to the website including organisation of the competition relating to the event. Personal information will not be passed to any third parties other than in relation to the management of the event, taking / making payments and in relation to any competition prizes, provided by third parties.

We may also need to disclose your information if required by law, for example to government bodies and law enforcement agencies, or if we have your permission to do so.

We will not sell any personal data or your web browsing activity to a third party.

3.11. Links to other websites

Our website contains links to and from the websites of our partner networks, advertisers and third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we don’t accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. This Privacy Policy applies solely to the personal data collected by us.

3.12. What is the lawful basis for processing personal data?

Collecting, processing and using personal data is permitted only under a lawful basis. The lawful bases that we operate under are listed below, along with the data processing activities that fall under them.

(a)  Necessary for the performance of a contract

When you provide us with your personal data, certain processing activities are considered necessary for the performance of the contract between you and us.   

When you book to attend an event we will process your personal data where this is necessary for us to provide you with this services, including by sharing your data with third parties involved in providing the service to you.

(b) Legal obligations

There are circumstances when we are required to process personal data in order to meet our legal obligations. Processing data under this basis can relate to financial data and HMRC reporting requirements. When processing on the basis of legal obligations, you have no right to erasure or right to object.

(c) Legitimate interests

If you are a member of the Caravan and Motorhome Club (the Club) we may contact you with offers and services which we feel are relevant and may enhance your holiday experience. The lawful basis with which we use your personal data in this way is legitimate interests. This is because on balance, and taking account of your own interests, we have determined that the data processing is necessary for our legitimate business interests and to provide you with appropriate offers and services. You can object to being contacted for marketing purposes and manage your Experience Freedom preferences online (please refer to section 3.17 for more information about this).

(d) Consent

Where we rely on the lawful basis of consent to process personal data, it must be freely given, specific, informed, and must be an unambiguous indication of agreement.  We would require consent when you provide personal information when entering a competition. If you have provided consent you have the right to withdraw it at any time.

(e) Protecting vital interests

In an emergency situation we would share this information with emergency services and we would consider this type of processing as being necessary to protect your and other relevant individuals’ vital interests.

3.13. What is the lawful basis for processing special category data?

When we process special category data we rely on one of the lawful bases outlined above as well as one of the following legal bases, which apply to special category data:

(a) Your explicit consent

In some circumstances, we provide you with the opportunity to voluntarily inform us of your special category data, e.g. whether or not you have a disability, so that we can help you with any requirements. In these situations if you choose to provide the information we rely on your explicit consent as our basis for processing.

(b) Where processing is necessary for reasons of substantial public interest

In some situations it may be necessary for reasons of substantial public interest for us to process special category data, for example in relation to prevent or detect fraud. We only do this where the processing is permitted by laws that provide safeguards for your rights.

3.14. What are my data subject rights?

Under UK data protection law, a data subject is considered to be ‘an individual who is the subject of personal data’. Data subjects have certain rights and by exercising these rights, you can make requests regarding your personal data we process.  A summary of these rights is explained below.

The Supervisory Authority that regulates and enforces data protection law in the UK is the Information Commissioner’s Office (ICO) and additional information and guidance about these data subject rights can be found on their website as follows https://ico.org.uk/

1)  Right to be informed

At the point of collecting personal data from you, we must provide you with information such as the purpose and rationale for the processing of that data.

2)  Right of access

This right provides you with the ability to access to your personal data that is being processed by us. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your requested personal data. The information will be provided free of charge unless the request is manifestly unfounded or excessive; in those cases, the request may be refused or a reasonable fee charged.

3)  Right to rectification

This right provides you with the ability to ask for modifications and rectification to your personal data in the event you believe that your personal data is not up to date or accurate.

4)  Right to erasure

Also known as ‘the right to be forgotten’ this right, under certain circumstances, provides you with the ability to ask for the deletion of your personal data. We may refuse to fulfil the right to erasure if there is legal reason why the personal data must be retained, the grounds are not valid or if the data is required for use in the defence of a legal claim.

5)  Right to restriction of processing

You have the right to restrict the processing of your personal data where you have a particular reason for wanting the restriction. This may be because you have concerns with the personal data we hold about you or how we have processed your data. In most cases we will not be required to restrict your personal data indefinitely, but will need to have the restriction in place for a certain period of time.

6)  Right to data portability

This right provides you with the ability to ask for a copy of or a transfer of your personal data, in a certain format. You may ask for your personal data to be provided back to you or transferred to another data controller. When doing so, the personal data must be provided or transferred in a structured, commonly used and machine-readable format.

7)  Right to object

You have the right to object to the processing your personal data, including marketing activities and profiling, on grounds relating to your particular situation. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8)  Right to object to automated processing

This right provides you with the ability to object to a decision based solely on automated processing, including profiling. Under this right, you may ask for your processing to be reviewed manually and with human intervention.

3.15. Exercising your data subject rights

To make the request process easy for you and to ensure we have all the information we need to be able to process it, a Subject Request Form is available for download and completion here. Please complete all relevant information and post to the Data Protection Officer at our registered address (see section 2), as set out in the form. We may request further information from you to help us verify your identity.

You are not obligated to use the form to make a request but we will need all the information asked for on the form in order to process it.

Once we have all the information necessary to respond to your request and have confirmed your identity, we’ll locate your information and manage your request without undue delay and in any event within one calendar month. Note that this timeframe may be extended by two further months if your request is particularly complex or there is a large volume of requests.

3.16. How long do we keep personal data for?

We retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each data type, taking into account the reasons that the personal data was obtained, but if relevant, the length of retention is determined in a manner consistent with legal and regulatory obligations.

3.17. Managing your preferences

As a Caravan and Motorhome Club member, you have a choice about whether you want to receive information about our services. We will not use your personal information for marketing purposes or share your information with any third party if you have indicated that you do not wish to be contacted in this manner.

You can change your marketing preferences at any time by writing to Experience Freedom at our registered address provided in section 2.

Please note that if you do request not to receive marketing information, you may continue to receive communications relating to the administration of your bookings and any services purchased.

If you are a Club member, you have a choice about whether you want to receive information about Experience Freedom services. You can change your marketing preferences at any time by:

  • accessing the Club website via your membership ‘My profile’ page (you will need to login), or
  • selecting the ‘update preferences’ link at the bottom of our products and services email communications, or
  • speaking to our membership team on 01342 318813

3.18. CCTV

Some of our locations and properties have Closed Circuit Television (CCTV) and you may be recorded when you visit them. CCTV is used to provide security and protect both our guests and visitors and our property. CCTV will be only be viewed when necessary, for example, to detect or prevent crime, and footage is stored for a set period of time after which it is overwritten. We align with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is used.

3.19. Making a complaint

If you think your data has been misused or that we haven’t kept it secure, please contact us using the contact details provided in section 2 and we will investigate any concerns you may have. If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO).

The telephone number for the ICO Helpline is 0303 123 1113 or you can also chat online with an advisor.

The ICO can investigate your claim and take action against anyone who has misused personal data. You can also visit their website for information at https://ico.org.uk/concerns/.

3.20. Tell us about changes to your information

If your personal details change, please help us to keep your information up to date by notifying us at: Experience Freedom, East Grinstead House, East Grinstead, West Sussex RH19 1UA.

3.21. Changes to this Privacy Policy

We will amend this Privacy Policy from time to time to ensure it remains up to date and reflects how and why we use your personal data as well as any new legal requirements. Please visit our website to keep up to date with any changes as the current version of this policy will always be posted on our website.

 

Version no.

1.0

Description of change

First publication

Date published

20 February 2018

2.0 Major update to include GDPR requirements 25 May 2018

3.22. Monitoring of telephone calls

Your telephone calls to us may be recorded and monitored for quality control and regulatory purposes.

3.23. Last update

This Privacy Policy (Version 2.0) was last updated on 25 May 2018.