Floors Castle respects your privacy and will take all steps to protect personal information we hold about you.
Privacy & Fair Processing Notice for the businesses which trade under Roxburghe Estates
Roxburghe Estates is made up of different legal entities, details of which are as follows:
- The Roxburghe Estates Partnership;
- Sunlaws Development Company Limited (T/A Floors Castle Enterprises);
- The Firm of Floors Farming;
- Floors Energy Limited;
- Bowmont Farming Limited;
- the 10th Duke of Roxburghe (in his capacity as a sole trader); and
- Virginia Wynn Williams Design (in her capacity as a sole trader).
This privacy notice is issued on behalf of each of the abovementioned entities forming part of Roxburghe Estates, so when we use the terms “we”, “us” or “our” in this privacy notice, we are referring to the relevant entity in Roxburghe Estates responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
We strive to protect the privacy of all personally identifiable information collected during the course of our activities and it is important for you to know how we process your data. We will process your personal information under the terms of this policy and in accordance with any agreement with you.
We are a “data controller” in terms under data protection laws (including from 25 May 2018, the EU General Data Protection Regulation 2016 and the Data Protection Act 2018) (“Data Protection Laws”).
We need to process personal data relating to the existing customers, new customers, potential customers, contractors, suppliers, professional advisers and tenants in order to function effectively as a business, ensure good governance, for audit purposes, to perform our business and to enable us to meet our legal obligations.
Personal data is processed for commercial, administrative, statutory and marketing/promotion purposes. All such personal data is collected and held in accordance with all applicable Data Protection Laws.
What personal information will we use?
This section includes all the ways we may use your personal information, and which of the reasons we rely on to do so. This is where we tell you what our legitimate interests are.
We process contact details and some financial information of our existing, new and potential customers for the purposes of fulfilling our contacts with customers. We also send marketing information about our products, services, offers, news and events to people who have opted in to receive marketing communications form us. In some cases it is in our legitimate interest to send marketing information to existing or potential customers in compliance with any applicable laws relating to marketing.
We process contact details, financial information, references, salaries, credit ratings and employment history of our tenants. We do this on the basis of fulfilling our contracts with tenants or on the basis that it is in our legitimate interest to administer our relationship with our tenants, to ensure that we fulfil our obligations to our tenants and to likewise ensure that a tenant is able to fulfil their obligations to us, including their obligations to pay rent.
We process contact details of our contractors, suppliers and professional advisers. We do this on the basis of fulfilling our contracts with them or on the basis that it is in our legitimate interest to administer our relationship with them, to ensure that we fulfil our obligations to them and to likewise ensure that they fulfil their obligations to us.
Personal Data of Third Parties: if you act on behalf of, or make reservations for, another person, we will also collect their data, for the purposes outlined in this privacy notice.
Failure to provide personal data
In some cases we may need to collect your personal data by law, or in order to perform our side of a contract we have entered into with you or with a view to entering into such a contract, or in our legitimate interests. If you fail to provide the requested data, we may not be able to perform under the contract we have with you, or to enter into the contract with you or way may be prevented from achieving our legitimate interests (such as engaging with you). In such circumstances, we may have to cancel the contract, or be unable to conclude the contract, which means we would not be able to provide the product or service to you. If that is the case, we will notify you of that at the time.
Where do we obtain your information?
In most cases we will obtain this information from you directly. We may also receive references and credit checks relating to our tenants, for example from credit reference agencies, banks and landlords.
We process the personal data referred to above for the purposes of any contract or potential contract with our existing customers, new customers, potential customers, contractors, suppliers, professional advisers and tenants; or for our legitimate interests in order to function effectively as a business, to ensure good governance, for audit purposes, to perform our business activities; and to enable us to meet our legal obligations that we may be subject to.
Who do we share your information with?
The information you provide to us may be accessed by our staff, our auditors, our professional advisors and carefully selected third parties in the course of providing services to us under suitable obligations of confidentiality.
In particular, we may share your information with the following entities:
- Let Alliance Ltd. Where you are a tenant of ours, your details may be shared with Let Alliance Ltd.
- Letting Protection Service Scotland (“LPS)”, a trading name of Computershare Investor Services Plc. Where you are a tenant of ours, your details may be shared with LPS.
We employ administrative, electronic and physical security measures to ensure that the information that we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.
Please be aware that unfortunately the transmission of information via the internet or by email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to us and any transmission is at your own risk.
The period for which the personal data will be processed
We will retain personal data securely and only in line with how long it is necessary to keep for the purposes or for a legitimate and lawful reason.
Our typical retention periods are as follows:
|Personal Data Held Within:
|At the end of the customer relationship or contract
|At the end of the customer relationship or contract
|Until the potential customer unsubscribes or indicates that it no longer wishes to receive marketing or promotional materials
|7 years from the end of the relationship or contract
|7 years from the end of the relationship or contract
Some personal data may be retained for longer where it is in our legitimate interest to do so, such as to protect and defend our legal rights; or for research, archiving or statistical purposes. Individuals can request that other information relating to them be erased and we will deal with such requests in accordance with the law.
Transfers outside the European Economic Area
We will not send personal data to countries outside the European Economic Area (‘EEA’).
Data subject’s rights
As an individual, you have the following rights as a data subject under applicable Data Protection Laws in relation to the processing of your personal data:
- The right to request from us access to information held about you – (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- The right to request that inaccurate data held about you is rectified – this enables you to have any incomplete or inaccurate information we hold about you corrected.
- The right to request the erasure of personal data – this enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing.
- The right to restriction of processing – this enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- The right to object to processing – objection to processing of your personal information can occur where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes; and
- The right to data portability.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Privacy Manager, in writing (details below).
Where we process your personal data based upon your consent, you have the right to withdraw your consent at any time.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Privacy Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
For more information and guidance about any of these rights please go to the website of the Information Commissioner’s Office at https://ico.org.uk/
If you think there is an issue in the way in which we handle your personal data, you have a right to raise a complaint with the Information Commissioner’s Office. Their website contains details of how to make a complaint.
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Changes to this Privacy & Fair Processing Notice
We keep our Privacy & Fair Processing Notice under regular review and reserve the right to update and amend it. This notice was last updated on 25 May 2018.
For further information about the proposed data sharing set out in this notice, or about any aspect of the processing of your personal data, please contact our Data Privacy Manager:
Roderick JacksonData Privacy Manager
Roxburghe Estates Office
Email [email protected]