Privacy Policy

The Wellspring (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use and any other documents referred to on 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. Before using our website you are required to give specific consent to the processing of your Personal Data for the purposes set out under section “Uses made of the information” which you have done by ticking the data processing consent box on our website.

For the purpose of the Data Protection Laws.

Definitions

"Applicable Law" means (a) any law, statute, regulation, byelaw or subordinate legislation in force from time to time to which a Party is a subject and/or in any jurisdiction that our services are performed in; (b) the common law and laws of equity as applicable to the Parties from time to time; (c) any binding court order, judgment or decree; (d) any applicable industry code, policy or standard; (e) any applicable direction, policy, rule or order that is binding on a party and that is made or given by any regulatory body having jurisdiction over a Party or any of that Party's assets, resources or business;

"Data Protection Laws" means any Applicable Law relating to the processing, privacy, and use of Personal Data, including (a) in the United Kingdom, (i) the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, SI 2003/2426, and any laws or regulations implementing Directive 95/46/EC (Data Protection Directive) or Directive 2002/58/EC (ePrivacy Directive); and/or (ii) the General Data Protection Regulation (EU) 2016/679 (GDPR), and/or any corresponding or equivalent national laws or regulations (Revised UK DP Law) (b) in member states of the European Union, the Data Protection Directive or the GDPR, once applicable, and the ePrivacy Directive, and all relevant member state laws or regulations giving effect to or corresponding with any of them; and (c) any judicial or administrative interpretation of any of the above, any guidance, guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant Supervisory Authority;

"Data" means information which is stored electronically, on a computer, or in certain paper-based filing systems;

"Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and where referred to in this policy includes special categories of Personal Data.

Information we collect from you

We will collect and process the following Data about you:

• Information you give us. This is information about you that you give us by filling in forms on our site https://www.thewellspring.uk (“our site”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our services and/or updates, register your interest in a property or properties, participate in discussion boards or other social media functions on our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and previous property purchase information.
• Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, domain names, and referring website addresses.
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time).
Cookies
Our website uses cookies 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 site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Uses made of the information

We use information held about you in the following ways:

1. processing of an enquiry form completed by you;
2. processing a request for further information or expressing an interest in one or more of our properties or services;
3. providing your information to our marketing department who may contact you by post, telephone or email to request feedback and comments on our services or to provide information to you which may be of interest to you;
4. providing your information to our agents and service providers for the purposes set out in 3 above;
5. if applicable processing your application for employment and we shall retain a copy of your CV in case of suitable future opportunities.

• 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 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 provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, volunteer, donor, or guest, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, volunteer, donor, or guest and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you will be able to withdraw your consent by contacting the Office in writing.
○ to notify you about changes to our service; and
○ to ensure that content from our site is presented in the most effective manner for you and for your computer.

• Information we collect about you. We will use this information:

○ to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
○ to improve our site 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 site safe and secure;
○ to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
○ to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

• 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).

Disclosure of your information

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

• 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;
○ credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

• In the event that we sell, buy or merge with any business or charity, or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.
• If The Wellspring or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of community, employees, volunteers, donors, guests, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your Personal Data

All information you provide to us is stored on our secure servers. Where any payment transactions are facilitated, they 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 either now or in the future, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by notifying the Data Protection Manager, in writing to The Wellspring, Woolpits Farm, Parkway, Ledbury HR8 2JG

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

Access to information

The Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Law. You also have the right to rectify Personal Data where it is no longer correct. If you wish to do so please contact us as set out below.

Under our data retention policy, your Personal Data will not be stored for any longer than is necessary. How long Personal Data is retained will depend upon the purposes for which the Personal Data was collected and whether you purchase a property from us.

Data will be retained in line with our Data Retention Policy which is available from the Data Protection Manager on request.

Right to Lodge a Complaint with Information Commissioner's Office ("ICO")

If you have any complaints about the way in which we process your Personal Data please do contact us, as set out below. Alternatively, you have the right to lodge a formal complaint with the ICO.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Children

Our website is not directed at children and we do not expect to receive any enquiries from children. If you are under 18 years old we ask that your parent or guardian provide their consent before you provide any Personal Data to us.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Data Protection Manager at The Wellspring, Woolpits Farm, Parkway, Ledbury HR8 2JG