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This notice sets out how FXC Brands (being Freixenet Copestick Limited and its subsidiaries) uses your personal information, which may be recorded on CCTV systems for the purpose of security, crime detection, public safety and other legitimate reasons set out in section 2 below. This notice explains how we comply with data protection law and what your rights are.
For the purposes of data protection laws and this privacy notice, Bolney Wine Estate Limited (company number: 04697328) of Bolney Wine Estate Foxhole Lane, Bolney, Haywards Heath, West Sussex, England, RH17 5NB will be the controller of any of your personal information recorded on our CCTV system. Being the controller of your personal information means we are responsible for deciding how we hold and use it.
We have appointed a Data Protection Officer to oversee our compliance with data protection laws, and contact details are set out in the “Contacting us” section at the end of this privacy notice.
Contents
- What information may we hold or process that relates to you?
- What do we do with your personal information?
- Who we share your personal information with?
- Transferring your personal data internationally
- How long do we keep your personal information for
- Your rights in relation to your personal information
- Changes to this notice
- Contacting us
1. What information may we hold or process that relates to you?
We may collect video recordings and still pictures of you if you are in the field of view of any of our CCTV systems. This personal information may include your activities, your face, car registration details and other visual information about you which is recorded on our CCTV system.
We may also collect personal information about you if you, your representative or a person authorised by you contacts us regarding an enquiry, complaint or other communication.
2. What do we do with your personal information?
As the data controller, we will collect personal information on our CCTV system and use it for the following purposes:
- For the prevention and detection of crime
- For evidence in any civil or criminal legal proceedings
- To assist in investigations
- For safety and security (including but not limited to the protection of employees, customers and contractors)
- Dealing with any queries, complaints or enquiries
- Retaining records
In addition to the purposes for which we use your personal information, all of the above are also legitimate reasons for us to use and store personal information relating to you captured on our CCTV system, and legitimate interests are our legal basis for processing your personal information.
We may anonymise any personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face), and it therefore ceases to be your personal information. We may use this anonymised information for any other purposes.
3. Who we share your personal information with?
We share your personal information with the following parties:
- Suppliers and service providers: to manage and operate the CCTV system as our data processor.
- Joint data controllers: who may jointly operate and maintain the CCTV system with us.
- The police and other law enforcement agencies: carry out policing, assist in investigations, trace missing people, and investigate alleged criminal activities.
- The security services: where relevant for matters of national security.
- People who have been injured, attacked or had property damaged or stolen and their insurance providers: to assist them with any criminal or civil investigations or legal proceedings.
- People who have been involved in road traffic accidents and their insurance providers: to assist with insurance claims, legal claims and investigations.
- Private and other investigators: to aid their investigations.
- Any relevant regulators: where we are required to do so by law or to assist with their investigations or initiatives, including but not limited to the Information Commissioner’s Office.
We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.
4. Transferring your personal data internationally
The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.
In limited circumstances, the people to whom we may disclose personal information from our CCTV system, as mentioned in section 3 above, may be located outside the UK and the European Union. In these cases, we will apply any legally required protections to the personal information before it is disclosed.
If you require more details on the arrangements for any of the above, then please contact us using the details in the “Contacting us” section below.
5. How long do we keep your personal information for
We will keep your personal information for up to 31 days after the recording is made. After this time, the recording stored on the hard drive of our CCTV system will usually be overwritten. However, if we receive an enquiry about a particular recording on our CCTV system, we will generally retain that part of the recording until it is no longer required. This period can vary, as it depends on the circumstances of the particular case, but for criminal or civil legal proceedings, it may mean that the personal information is retained until after the legal case and any appeals have concluded, which may be many years. As soon as it is no longer required, we will then delete the personal information.
6. Your rights in relation to your personal information
You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; (iii) the right to request the correction of inaccurate personal information we hold about you; (iv) the right to request the erasure of your personal information in certain limited circumstances; (v) the right to restrict processing of your personal information where certain requirements are met; (vi) the right to object to the processing of your personal information; (vii) the right to request that we transfer elements of your data either to you or another service provider; and (viii) the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision-making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored in our CCTV system. For example, we do not use automated decision-making regarding your personal data in our CCTV system. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing is absolute.
There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal information.
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 anyone who does not have the right to receive it.
More information about your legal rights can be found on the Information Commissioner’s website.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us.
If you are unhappy with how we use your personal information, you can also complain to the UK Information Commissioner’s Office, or to your local data protection regulator in the European Union if you are based outside the UK, or bring a claim in court. However, we are here to help and would encourage you to contact us to resolve your complaint first. Our data protection complaints policy can be obtained by emailing our Data Protection Officer at [email protected].
7. Changes to this notice
We may update this privacy notice from time to time. You are encouraged to regularly check for any updated version of this privacy notice.
8. Contacting us
In the event of any query or complaint in connection with the information we hold about you, please email our Data Protection Officer at [email protected] or write to us at:
FAO Data Protection Officer
Bolney Wine Estate
Foxhole Lane
Bolney
Haywards Heath
West Sussex
England
RH17 5NB
