WHO Are we?
This website (“Site”) is operated by Loyton LLP a company registered in England and Wales under registration number OC304961 (“Loyton LLP”, “we”, “us” and/or “our”). Our registered address is Lime Court, Pathfields Business Park, South Molton, Devon, EX36 3LH. You can contact us as indicated under the “Contact” section below.
The data controller responsible for your personal data is the Loyton LLP, a company with whom you contract as a customer, member of one of the sporting clubs administered by us or membership applicant (“Loyton LLP”, “we”, “us” and/or “our”). Loyton Sporting, Loyton Lodge and Loyton Farms, which are all trading names of Loyton LLP.
The sporting clubs and other entities administered by Loyton LLP are:
The Haddeo Sporting Club Ltd, a company registered in England and Wales under registration number 07543735
The Stuckeridge Sporting Club Ltd, a company registered in England and Wales under registration number 07035910
The Bray Valley Sporting Club Ltd, a company registered in England and Wales under registration number 08522798
The Exmoor Sporting Club Ltd, a company registered in England and Wales under registration number 06673947
The Molland Sporting Club Ltd, a company registered in England and Wales under registration number 11141155
The above sporting clubs are referred collectively as (the “Sporting Clubs”).
Loyton Estates Management Ltd, a company registered in England and Wales under registration number 10625823
Loyton Holdings Ltd, a company registered in England and Wales under registration number 111257997
RVB Design Ltd, a company registered in England and Wales under registration number 10699915
Loyton Retail LLP, a company registered in England and Wales under registration number OC303892
Haddeo Land LLP, a company registered in England and Wales under registration number OC363912
Galloping Bottom LLP, a company registered in England and Wales under registration number OC£12296
PERSONAL DATA WE COLLECT
We collect the following personal data about you:
• Membership Application: The personal details you provide when submitting a membership application. This includes your name, address, e-mail address; business address and phone number. We may also collect information about your debit/credit card and bank account information provided by you to our payment service providers if required for the purposes of taking payment for goods or services we may provide to you. For further details please also refer to the section below headed “Payment Information”.
ensure that you read our privacy notice on the reservation website that we may provide to you when we collect or process your personal data.
• Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with this Site or any other websites we operate, and personal data that you provide to us when you stay at Loyton Lodge or shoot at one of the Sporting Clubs administered by us.
AUTOMATICALLY COLLECTED PERSONAL DATA
• Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
HOW WE USE YOUR PERSONAL DATA
We use your personal data in the following ways:
• To acknowledge, confirm and deal with your application to become a member of one or more of the Sporting Clubs. Such use of your data is necessary in order to implement your request to become a member of a Sporting Club.
• Where you are a member, provide you with membership services, administer your membership and contact you regarding your membership of one or more of the Sporting Clubs generally. Such use is necessary to enable us to fulfil the requirements of your membership of the Sporting Clubs in accordance with the rules of the Sporting Club in question.
• To complete and fulfill any your reservations and stays you may make at Loyton Lodge, for example, to process your payment, ensure that your room is available, and provide you with related customer service, including sending confirmations or pre-arrival messages, assist you with any meetings, events or celebrations. Such use is necessary for the performance of the contract between you and us.
• To contact you in connection with user/customer/member surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.
• Loyton LLP and the Sporting Clubs and our affiliated businesses may provide you, or permit selected third party service providers to provide you, with information about goods or services, events and other promotions we feel may interest you as a member or future member of the Sporting Clubs. We (or such third party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.
• As necessary for certain legitimate business interests, which include the following:
• where we are asked to deal with any enquiries or complaints you make.
• to administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.
• to conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our members and our communications,
including by creating customer or member profiles to enable personalised direct marketing communications.
• to provide postal communications which we think will be of interest to you.
• if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
• to share personal data among our affiliated businesses for administrative purposes, for providing membership services and in relation to our sales and marketing activities.
• we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business
purposes, including sharing it with our current and prospective members, business partners, our affiliated businesses, agents and other third parties for commercial,
statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
• for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.
• to (a) comply with legal obligations, (b) respond to requests from competent authorities; Rules(c) enforce the rules of any applicable Sporting
Club; (d) protect our operations or those of any of the Sporting Clubs (e) protect our rights, safety or property, and/or that o the Sporting Clubs, you, other members of the Sporting Clubs or others; and (f) enforcing or defending legal rights, or preventing damage.
• We may use your personal data for other purposes which you have consented to at the time of providing your data.
When we process your personal data for our legitimate interests, we make sure to considerand balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You havethe right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information onyour rights, please see “Your Data Protection Rights” section below).
DISCLOSURE OF YOUR INFORMATION
We share your personal data with third parties in the following situations:
• Service Providers: Loyton LLP, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members, (iv) web analytics providers, (v) providers of digital advertising services and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in
order to perform the services we have hired them to provide.
• The Sporting Clubs may access and process the information which we collect from you for the purposes described above, including to offer products and services to you. The Sporting Clubs will only use your data for the purposes for which we originally collected it.
• Business Transfers: if we sell our business or our company assets are acquired by a third party personal data held by us about our members, membership applicants or customers may be one of the transferred assets.
• Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms & Conditions, Sporting Club rules or other applicable contract terms that you are subject to or (iii) to protect us, the our members and prospective members of the Sporting Clubs or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.
Any credit/debit card payments and other payments you make through our Site will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit. We may arrange that card or payment data you submit in support of an application for membership of a Sporting Club or any membership fees subscription fee is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees.
We store and use this card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted. You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate any membership or for the purpose of making any future purchases.
PERSONAL DATA TRANSFERS
Your personal data may be transferred to and stored in countries other than the UK, including the United States and other destinations outside the European Economic Area (“EEA”), to our service providers and affiliated businesses for the purposes described above.
Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where we transfer your personal data to countries outside of the EEA we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service providers’ Privacy Shield certification or implementing standard contractual clauses for data transfers.
Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else. Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.
PERSONAL DATA RETENTION
YOUR PERSONAL DATA PROTECTION RIGHTS
Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:
• Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
• Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your personal data, and we will do so:
- If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or
- If we are processing your personal data for direct marketing.
• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns (you may find EU Data Protection Authorities’ contact information here.) If you wish to exercise any of these rights please contact us as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.