Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice

Who we are and how you can contact us:

Benguela Cove Investments Ltd (T/A Leonardslee Wine Estate and T/AS Leonardslee Family Vineyards and T/AS Mannings Heath Golf Club)

Registration number: 00321529, Registered address: 92-96 Lind Road, Sutton, surrey, SM1 4PL

This privacy notice incorporates the registered company as well as any trading names associated with the company. Therefore, when mentioning "we", "us" or "our" in this privacy notice, we are referring to the relevant company and trading names responsible for processing your data and that company is the controller of your data.

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 dpofficer@leonardslee.co.uk

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 below company is registered with the United Kingdom's Information Commissioner's Office as a data controller to collect information:

Data controller: Benguela Cove Investments Limited

Registered company number: 00321529

ICO number: ZA186368

Registered Office: Benguela Cove Investments Limited, 92-96 Lind Road, Sutton, Surrey, SM1 4PL

Contact details:

Email address: dpofficer@leonardslee.co.uk, Postal address: 92-96 Lind Road, Sutton, surrey, SM1 4PL, Telephone number: 0330 1235 891

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 that 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, image and car registration numbers.

Contact Data includes billing address, delivery address, email address and telephone numbers. Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes 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 includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes 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 does not directly 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 this privacy notice.

In certain situations, we may collect Special Categories of Personal Data about you 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 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 that time.

We don’t intentionally or knowingly process personal information from individuals under the age of 16, with the following exceptions: if they hold membership with us (Name, address and sometimes DOB) lessons for children in golf some of our pleasure or leisure experiences; use of actors at our events; and

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.

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, or corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

apply for our products, tickets, experiences or services; attend one of our events.
apply for membership in 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 several 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 Talent or 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 inside or outside 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 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.

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 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. To provide you with information about the products and services of our sponsors and partners where this is directly relevant to the product or service, we have provided you,

• 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 are 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 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 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, or 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.

To deliver relevant website content and advertisements to you and measure the effectiveness of these.

To create an individual profile for you and to ascertain the products, services, promotions, special offers and discounts that are likely to be of particular interest to you in order to send tailored or personalised marketing information or product recommendations to you (where we are permitted to do so).

• 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 (Public Relations) process, including media accreditation, and relationship building.

• Legitimate Interests - to effectively manage 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 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 carry out H&S, accident and food safety reporting.

• 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 defense 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.

Information We Collect

We may collect the following types of information:

• Personal Information: Name, email address, phone number, and other contact details.

• Usage Data: Information about how you interact with our website, including IP address, browser type, and pages visited.

• Cookies and Tracking Technologies: Data collected through cookies and similar technologies.

How We Use Your Information

We use your information for the following purposes:

• Providing Services: To deliver the products and services you request. Communication: To send you updates, newsletters, and promotional materials. Improvement: To improve our website, products, and services.

• Compliance: To comply with legal obligations and protect our rights.

We aim to provide you with relevant and valuable marketing content. This section explains how we handle your information for marketing purposes.

Purpose of Marketing

Our marketing activities are designed to keep you informed about our latest updates, offers, and services. We strive to offer content that is both engaging and pertinent to your interests.

Collection of Information. When you subscribe to our newsletter or interact with our marketing content, we may collect personal information such as your name and email address. This helps us personalize our communications and ensure they are relevant to you.

Use of Information

The information collected for marketing purposes is used to:

• Send newsletters, updates, and special offers.

• Provide personalised content and recommendations based on your preferences

• Analyse user engagement to refine our marketing strategies.

Data Protection

We prioritise the security of your personal information. We employ secure methods to store and process your data and ensure that it is only accessible to authorised personnel. We do not sell or share your personal information with third parties for their marketing purposes.

Consent and Opt-Out

By subscribing to our marketing communications, you consent to receiving emails and other forms of communication from us. You can opt-out at any time by clicking the unsubscribe link in our emails or by contacting us directly.

Cookies and Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather analytics data. You can control cookie settings through your browser preferences.

Your Rights Under GDPR

You have the following rights under GDPR:

• Right to Access: You can request a copy of the personal information we hold about you.

• Right to Rectification: You can request that we correct any inaccuracies in your personal information.

• Right to Erasure: You can request the deletion of your personal information where there is no lawful basis for us to retain it.

• Right to Restrict Processing: You can request that we restrict the processing of your personal information in certain circumstances.

• Right to Data Portability: You can request that we transfer your personal information to another organization or to you.

• Right to Object: You can object to the processing of your personal information for direct marketing purposes.

Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and we will notify you of significant changes by email or through a notice on our website.

Change of Purpose

We will only use your personal data for the purposes for which we collected it unless we need to consider 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 us 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 the 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.

Disclosures of your personal data

Information about our customers, guests and invitees is an important part of our business and we do not sell it to others. We only share it in the circumstances set out below.

Affiliated Businesses we do not control: We have relationships with a small number of other companies who are our commercial partners with whom we may share data for the purposes of our events, for prize draws and competitions or for marketing their goods or services. please contact us for a list of those businesses. They have access to a limited amount of personal information needed to put their sponsorship rights into effect but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.

Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf, fulfil our obligations and as activation partners. Examples of such activity include fulfilling orders, providing hospitality, catering and event services, carrying out surveys, analysing data, providing marketing assistance, processing credit card payments, providing customer services, delivering ticketing and merchandise, retailers, social networks, fraud prevention agencies, payroll service providers, land agents, medical practitioners, digital agencies, hosting providers, data storage providers and other technical partners. They have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.

Promotional Offers: Sometimes we send offers to selected groups of customers on behalf of other businesses. When we do this, it will only be in circumstances where you have indicated the necessary marketing preferences.

Protection of Benguela Cove Investments and third parties: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Conditions of Use and other agreements; or protect the rights, property or safety of Benguela Cove Investments Ltd, our customers or others. This includes exchanging information with Health and Safety and Food Safety consultants, our brokers and insurers, emergency services, and other organisations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, renting, sharing or otherwise disclosing personally identifiable information from customers for commercial purposes in a way that is contrary to the commitments made in this Privacy Notice.

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 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 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 us to provide you with all the information it stores on you. You can make a Subject Data Access Request by contacting dpofficer@leonardslee.co.uk. You have the right to ask us 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 us in some circumstances and, where we have asked for consent to process your data, to withdraw this consent. You may contact dpofficer@leonardslee.co.uk if you would like assistance with any of the 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 we are legally prevented from disclosing such information. In addition, we 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. 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 the 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 situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. You also have the right to object to 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 overrides 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 to override legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with your consent for us to use or where we used the information to carry out 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 process 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 dpofficer@leonardslee.co.uk

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 several 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 such a contract. Complying 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.