Freelands Hampshire
Privacy Policy

Freelands Hampshire (hereinafter referred to as “Rich’s,” “Freelands,” “us,” “we,” “our,” or “Company”) have created this Privacy Policy to apply to all visitors to our Property at Fullerton Road, Wherwell, Hampshire, U.K. SP11 7JS, users of this website, www.freelandshampshire.com, and all digital assets contained or offered therein (collectively, our “Services”). This Privacy Policy describes, among other things, the types of information we collect from users when you use our Services, how we use it, and how you can access your information.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”). By using the Services and providing us with Information (defined below), you agree to the practices described in this Privacy Policy and to the updates to these policies posted here from time to time.

If you are a resident of the European Union (EU), European Economic Area (“EEA”), and UK, you may be entitled to certain individual rights under the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018, respectively. Please see the Notice to Certain Residents of Data Subject Rights Section of our Privacy Policy for your rights and how to exercise them for users located in the EEA and UK only.

If you have any privacy or data use concerns, please contact us as set out below under the heading “How to Contact Us.” To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the “Last Updated” date shown below.

I.INFORMATION WE COLLECT ABOUT YOU

We may collect the following categories of personal data about you, which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties. The information listed in (A)-(C) above is detailed below and hereinafter referred to as “Information.”

A. Information You Provide to Us

In using our Services, you may provide us with Information, including, without limitation:

Individual identifiers such as name, username, birth date, and contact information, including email address, mailing address, and telephone number(s);
Account information such as username and password used to register for an account with Freelands;
General demographic information such as your age, year of birth, or confirmation that you are above a certain age;
Payment and transactional Information such as products or services purchased;
Communications with us, preferences, and other information you provide to us, such as any messages (including via online chat feature), opinions and feedback that you provide to us, responses to contests or surveys, your user preferences (such as in receiving updates or marketing information/newsletters), and other Information that you share with us when you contact us directly (such as for customer support services);
CCTV footage when you visit Freelands; and
Additional Information as otherwise described to you at the point of collection or pursuant to your consent.

B. Information We May Automatically Collect About You

Our Services may automatically collect the following categories of usage and technical Information about you. This Information is used by Freelands for the operation of the Services, to maintain the quality of the Services, and to provide general statistics regarding the use of the Services. This Information may include:

IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider);
Date and time of your visit or use of our Services;
Domain server from which you are using our Services;
Type of computer, web browsers, search engine used, operating system, or platform you use;
Data identifying the web pages you visited prior to and after visiting our website or use of our Services; and
Your movement and activity within the website, which is aggregated with other Information;
Geographic data such as country or region;
Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.

C. Cookies & Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect Information about your activity or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, web beacons, pixels, software developer kits, third-party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

a. Cookies (or browser cookies). Cookies are small digital files that are transferred to your computer or smartphone’s hard drive when you visit a website or click on a URL. Most web browsers automatically accept cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

b. Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services may use retargeting pixels from Google, Facebook, and other ad networks. We may also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

c. Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with Information about traffic to our website and use of our Services, which Google may share with other services and websites that use the collected data to contextualize and personalize the ads of its own advertising network. Learn more about Google’s Privacy Policy here: https://policies.google.com/privacy?hl=en-US. You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

d. Location Information. When you use our Services, we will also use various technologies to determine location, such as sensor data from your device that will help us determine where our services are most commonly used throughout Freelands. You can generally disable sending your location through settings in your device, and we will inform you when we make use of location Information.

e. Mobile Application Technologies. If you access our website and Services through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.

You can opt out of these online tracking technologies by submitting a request to enquiries@freelandshampshire.com or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC), on the browsers and/or browser extensions that support such a signal. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Please note that some features of our website may not be available to you as a result of these choices.

D. Sources of Information

We may collect additional Information about you from third-party websites, social media platforms, such as but not limited to, Facebook, Twitter, or Instagram (“Social Media Platforms”), and/or sources providing publicly available Information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.

We may also receive Information from third parties (such as booking agents if you enquired through a third party) as well as affiliates in the Rich Andover Realty Ltd (RARL) Group.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to the following:

To respond to your inquiries and provide you with requested Information and other communications, including by email;
To process and deliver your booking and to notify you of the charges relating to your stay/visit. We will also amalgamate other Information you provide us while preparing for your visit to ensure that you enjoy your time with us.
To ascertain whether you meet the minimum age in your country for services and whether you are considered to be a minor for data protection and/or marketing law purposes;
If you choose to visit Freelands Hampshire, to send you a welcoming email, to communicate with you in response to any inquiries, and to send you service-related announcements, for instance, to discuss your booking (“transactional communications”).
To create and manage your account;
To send you our newsletter and other correspondence you request;
For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted out of receiving such communications;
To fulfill contracts we have with you;
To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
To maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
To comply with our Terms & Conditions;
For analytics for business purposes and business intelligence;
To comply with any applicable laws and regulations and respond to lawful requests; and/or
For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Sharing or Disclosing Your Information

We may share and/or disclosure your Information as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers. We may share your Information with third-party service providers or data processors that perform certain functions or services on our behalf (such as to host the Services, store or manage the data, perform analyses, process payments, provide customer service, or send communications for us). These third-party service providers will process this data only for purposes specified by us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required to by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate with or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
Business Transfers. Your Information may be transferred, sold, or otherwise conveyed to a third party (“Conveyances”) where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information. We may also share Information with prospective purchasers to evaluate the proposed transaction.
Information Shared with our Subsidiaries, Parents, and Affiliates. We may share your Information with our subsidiaries and affiliates. If you do not want us to share your Information with our subsidiaries and affiliates, please contact enquiries@freelandshampshire.com.
Aggregate and De-identified Data. We may share general Information, aggregated data, or publish Information based on aggregated data. However, we will only do so in a way that your personal identity is protected.
Online Communications. Any Information you submit in a public forum (e.g., contest, promotion, a blog, or social network) may be read, collected, or used by us and other participants and could be used to personalize your experience. You are responsible for the Information you choose to submit in these instances.
With Your Consent. We may share Information consistent with this Privacy Policy with your consent.

Except as provided in this Privacy Policy, we will not sell, exchange, trade, or disclose your Information we have collected without your consent.

III. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, Twitter, Instagram, or YouTube, or may redirect you off our website away from our Services.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

IV. INFORMATION SECURITY

We use commercially reasonable measures to provide our Services. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you shall promptly contact us via the How to Contact Us section so that we can quickly take necessary measures.

V. DATA RETENTION

We will retain your Information for as long as needed to provide you Services and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

VI. YOUR CHOICES

A. Marketing Communications. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt out of marketing email communications, or see How to Contact Us below for more information.

B. Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may also review the following links:

You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
You may opt out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

VII. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

This section applies only to individuals coming to our Services from the EEA and UK, and only if we collected through the Services any Information from you that is considered “Personal Data” as defined by the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 respectively.

“Personal Data” includes any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (which may include some or all your Information as defined in this Privacy Policy).

A. Identity and Contact Details of Controller and UK Representative

Unless otherwise stated, we are the Data Controller for the Information we process.

Contact Details:

Email: ukdpo@rich.com

Call us: +44 (0)330 060 5100

Write us:

Rich Products
Unit 5, Andover Business Park
Pioneer Road
Andover, Hampshire SP11 8EZ

B. Your Data Protection Rights

To the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our capacity as a Data Controller as defined under those laws, you may request that we:

Restrict the way that we process and share your Information;
Transfer your Information to a third party;
Provide you with access to your Information;
Remove your Information if no longer necessary for the purposes collected;
Update your Information so it is correct and not out of date; and/or
Object to our processing of your Information.

You may also revoke your consent for processing of your Information. If you wish to object to the use and processing of your Information or withdraw consent to this Privacy Policy, you can contact us in the following ways:

Email: ukdpo@rich.com

Call us: +44 (0)330 060 5100

Write us:

Rich Products
Unit 5, Andover Business Park
Pioneer Road
Andover, Hampshire SP11 8EZ

The requests above will be considered and responded to in the time period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:

Email: ukdpo@rich.com

Call us: +44 (0)330 060 5100

Write us:

Rich Products
Unit 5, Andover Business Park
Pioneer Road
Andover, Hampshire SP11 8EZ

C. Lawful Basis for Processing Your Information

The lawful basis for our processing of your Personal Data will depend on the purposes of the processing. For most Personal Data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process Personal Data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.

Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:

Processing on the basis of legitimate business interests. When we process Personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting our Services; (ii) communicating with current and potential customers, other business partners, and their individual points of contact; (iii) managing our relationships with our customers and other business partners, and their individual points of contact; (iv) other business development purposes; (v) sharing Information within the Company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, Services, and employees, including fraud protection.
Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us.
Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on Company Services through cookies and similar technologies when consent is required by applicable law.
Processing because we are under a legal obligation to do so. Examples of situations in which we must process Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.

If the processing of your Personal Data is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please see the How to Contact Us section, below, to review or modify your consents.

D. Consent to Transfer

Some of our group companies operate in the United States, and we may use service providers based in the United States to operate our business and our relationship with you. Please be aware that Information, including your Personal Data, that we collect may be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We maintain measures to address the transfer of your Personal Data between our group companies and between us and our third-party providers in accordance with applicable data protection laws and regulations.

E. Retention

We will retain your Information for as long as needed for the purposes described in this Privacy Policy. More specifically, the time we maintain your Information depends on the following factors:

Whether we need the Information to provide the Services. We will maintain any data needed to provide you with the Services, such as contact information and payment or transaction information, for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).
Whether we need the Information to comply with our legal obligations. We may have legal obligations to maintain your Information where a legal or regulatory body may ask for it in the future, for example, in response to a data subject request or complaint. This Information may include contact information and location information.
Whether we need the Information for a legitimate business interest. We may store Information like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Information when it is no longer needed for our legitimate interest.

Regardless of our reason for retaining your Information, we delete all Information in accordance with our routine record-keeping policies.

VIII. EXERCISING YOUR DATA SUBJECT RIGHTS

To exercise any of the rights described above, please submit a verifiable consumer request to us via the methods described below. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain Information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request. Only you or your authorized agent may make a verifiable consumer request related to your Information. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent with written permission to do so and to verify your own identity directly with us (as described above). You may also make a verifiable consumer request on behalf of your minor child.

Email: ukdpo@rich.com

Call us: +44 (0)330 060 5100

Write us:

Rich Products
Unit 5, Andover Business Park
Pioneer Road
Andover, Hampshire SP11 8EZ

IX. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

Our Services collect Information and processes and stores that Information in databases located in the United States. As such, we may store and process Information on servers located outside of the country where you originally deposited the data. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting our Services and submitting Information, you consent to the transfer of such Information to the United States.

X. CHILDREN’S INFORMATION

The Services are intended only for users over the age of sixteen (16). If we become aware that a user is under sixteen (16) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of sixteen (16).

XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

XII. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.

XIII. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify, or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Last Updated” date below, and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

XIV. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Email: ukdpo@rich.com

Call us: +44 (0)330 060 5100

Write us:

Rich Products
Unit 5, Andover Business Park
Pioneer Road
Andover, Hampshire SP11 8EZ

Last Updated: October 17, 2023

Freelands HampshirePrivacy Policy

Contents:

Freelands Hampshire
Privacy Policy