Privacy Policy

This privacy policy applies between you, the User of this Website/the data provider and Nene Park Trust (NPT), the owner and provider of this Website. NPT takes the privacy of your information very seriously and is committed to protecting and respecting your privacy.

This privacy policy (together with our terms and conditions and any other documents referred to in it) 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 views and practices regarding your personal data and how we will treat it.

By visiting www.nenepark.org.uk and/or by providing NPT with your personal data you are accepting and consenting to the practices described in this policy. For the purpose of the General Data Protection Regulation (GDPR), NPT is the data controller.

1. Definitions and interpretations

1.1 In this privacy policy, the following definitions are used:

Cookies	A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies).
Data	Collectively all information that you submit to NPT in written or electronic format. This definition incorporates, where applicable, the definitions provided in the GDPR.
Nene Park Trust, NPT or us	Nene Park Trust, Registered Charity No. 800067 and Company No. 2288607, whose registered office is at Ham Farm House, Ham Lane, Peterborough, PE2 5UU.
Data Subject	Any third party that provides their personal data to NPT and/or accesses the Website and is not either (i) employed by NPT and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to NPT.
UK and EU Cookie Law Website	The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. The website that you are currently using, www.nenepark.org.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• “including” is understood to mean “including without limitation”;
• reference to any statutory provision includes any modification or amendment of it; and
• the headings and sub-headings do not form part of this privacy policy.

2. Scope of this privacy policy

2.1 This privacy policy applies only to the actions of NPT and the Data Subject with respect to any personal data provided to the Trust and/or any users of this Website.

It does not extend to any websites or organisations that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

3. Data collected

3.1 We will collect and process the following data about you:

3.1.1 Information you give us. This is information about you that you give us in written or electronic format or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, and personal character information.

3.1.2 Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet (automatically collected), browser type and version (automatically collected), time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, your activity on our Website, the site you exit to (automatically collected) length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

3.1.3 Information we receive from other sources. This is information we receive about you from third parties. If possible and necessary we will notify you when we receive information about you from them and the purposes for which we intend to use that information.

4. Our use of your data

4.1 We use information held about you in the following ways:

4.1.1 Information you give to us.

We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to process your data in a way that you would expect for the purpose intended
• (with your consent) to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to notify you about changes to our service;
• to ensure that content from our Website is presented in the most effective manner for you and for your computer;
• to fulfil legal or regulatory requirements.

4.1.2 Information we collect about you.

We will use this information:

• to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Website safe and secure;
• to fulfil legal or regulatory requirements.

4.1.3 Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4.2 Personal Data shall be processed and stored for as long as required by the purpose it has been collected for.

4.3 Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and/or other companies within our group.

4.4 All Personal Data is stored securely in accordance with the principles of the GDPR and will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and up-to-date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

4.5 For more details on security see the clause below (Security).

5. Rights

5.1 As per the GDPR Data subjects have the following rights:

• Right to be informed about the processing of their personal data
• Right to rectification if their personal data is inaccurate or incomplete
• Right of access to their personal data and supplementary information, and the right to confirmation that their personal data is being processed
• Right to be forgotten by having their personal data deleted or removed on request where there is no compelling reason for an organisation to continue to process it
• Right to restrict processing of their personal data, for example, if they consider that processing is unlawful or the data is inaccurate
• Right to data portability of their personal data for their own purposes
• Right to object to the processing of their personal data for direct marketing, scientific or historical research, or statistical purposes.

5.2 You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Selected third parties including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimisation of our site.

5.3 You may not transfer any of your rights under this policy to any other person. We may transfer our rights under this policy where we reasonably believe your rights will not be affected.

5.4 Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

6. Third party services

6.1 NPT may, from time to time, employ the services of other parties if sharing the personal data complies with the consent received with the Data Subject and for dealing with certain processes necessary for the operation of the Website.

6.2 Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the GDPR.

7. Links to other websites 

7.1 This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

8. Changes of business ownership and control 

8.1 NPT may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of personal Data provided by Users.

Where personal Data is transferred the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

8.2 We may also disclose Data to a prospective purchaser of our business or any part of it.

8.3 In the above instances, we will take steps with the aim of ensuring your privacy is protected.

9. Controlling use of your data 

9.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

• use of Data for direct marketing purposes; and
• sharing Data with third parties.

10. Functionality of the website 

10.1 To use all features and functions available on the Website, you may be required to submit certain Data.

10.2 You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

11. Accessing your own data 

11.1 You have the right to ask us not to process your personal data. We will usually inform you (before collecting your data) if we intend to process your data or if we intend to disclose your information to any third party. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected].

11.2 You have the right to ask for a copy of any information held about you. Your right of access can be exercised in accordance with the GDPR.

11.3 If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

11.4 Our Data Protection Officer is the Head of Marketing who can be contacted via [email protected]. The response time for subject access requests, once received, is one month.

11.5 If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

12. Where we store your data 

12.1 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

12.2 All information you provide to us is stored on our secure servers or on the Cloud. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

13. Security 

13.1 Data security is of great importance to NPT and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure personal data provided to the Trust.

13.2 The Trust will regularly evaluate and test the effectiveness of these measures to ensure security of its processing of personal data.

13.3 We endeavour to do our best to protect your personal data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your data transmitted to the Website.

14. Cookies 

14.1 This Website may place and access certain Cookies on your computer 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. NPT has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

14.2 All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

14.3 By visiting this website you are giving your consent to the placing of Cookies and you are enabling NPT to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

14.4 This Website may place the following Cookies:

• Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

14.5 You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

14.6 You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

14.7 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

15. Data Breaches 

15.1 Any high risk breaches of personal data will be reported to the Information Commissioner’s Office within 3 working days of becoming aware of the breach.

15.2 If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms then we will inform those individuals without undue delay.

15.3 We will keep a record of any personal data breaches.

16. General 

16.1 If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

16.2 This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.

17. Changes to this Privacy Policy 

17.1 NPT reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact NPT by email at [email protected].