BAMFORD COLLECTION 

PRIVACY POLICY 

(COVERING DAYLESFORD ORGANIC, BAMFORD & DAYLESFORD STAYS) 

(LAST UPDATED 27.09.23) 

1. WHAT ARE THESE TERMS

1.1 What these terms cover: We are committed to protecting your personal information and complying with the General Data Protection Regulations (GDPR). This policy describes how we collect, use, process, store and disclose your personal information. 

1.2 Why you should read them: This policy applies to any personal information provided by you to the Bamford Collection through any of the websites connected to the Bamford Collection, as further detailed below (“our Sites”) or through your interactions with the Bamford Collection via phone or in person, such as in store.  Please read this policy carefully (and any other privacy policy we may provide on specific occasion from time to time when we are collecting or processing personal data) so that you are fully aware of how and why we are using your personal information.     

1.3 Print or Save:  You should print a copy of this policy or save it to your device for future reference.  

1.4 Legal rights: As a consumer, you have legal rights. Advice about your legal rights is available from your local Citizens’ Advice Bureau or Trading Standards office. Nothing in these Terms will affect these legal rights. 

2. 2. OTHER APPLICABLE TERMS

2.1 Cookie Policy: Our Cookie Policies, which sets out information about the cookies on our Sites.  The Cookie Policy relevant to each of our Sites is available on each Site. 

2.2 Website Terms: There are terms of use of our Sites which apply to your use of our Sites.  These are available from each Site. 

2.3 Other Privacy Policy: There may be other privacy policies or fair processing policies that are provided on specific occasions when your personal data is collected or processed so that you are fully aware of how and why your data is used.  This privacy policy supplements other notices and privacy policies and its not intended to override them. 

2.4 Other Terms: If you purchase goods and/or services from us there are separate terms and conditions regarding such purchases that you will be made aware of during the transaction process. 

2.5 Third Party Terms: Our Sites may include links to third-party websites, plug-ins and applications outside of the Bamford Collection.  Clinking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our Sites, we encourage you to read the privacy policy of every website you visit. 

3. 3. ABOUT US

3.1 Who we are.  Bamford Collection is the overarching umbrella brand name covering the following entities: 

1. A. Bamford Collection Limited, a company registered in England as a limited liability company with company number 03064811 whose registered office and main trading address is at 19 Mossop Street, London SW3 2LY, which is the entity which carries out central functions for other entities making up the Bamford Collection;
2. Daylesford Organic Limited, a company registered in England as a limited liability company with company number 03868901 whose registered office is at 19 Mossop Street, London SW3 2LY, the activities of which include online sales of goods and events via https://www.daylesford.com/ and the operation of farm shops and cafes and events;
3. C. Bamford Limited, a company registered in England as a limited liability company with company number 04950734, whose registered office is at 19 Mossop Street, London SW3 2LY, the activities of which include online sales of goods and services via https://www.bamford.com/ and the operation of stores selling clothing and bath and body products, The Club by Bamford and directly owned spas;
4. D. Daylesford Stays being the overarching umbrella brand name for the group of companies which is made up of:

(i) Thrip Enterprises LLP, a company registered in England as a limited liability partnership with company number OC375071, whose registered office is at 25 Moorgate, London EC2R 6AY and whose main trading address is Church Street, Kingham, Oxfordshire OX7 6YA and which operates The Wild Rabbit including food and beverage sales, accommodation and events and Daylesford Cottages with the Site(s) of https://thewildrabbit.co.uk/.  

(ii) The Fox at Oddington LLP, a company registered in England as a limited liability partnership with company number OC433190, whose registered office is at 43 Gresham Street, London EC2V 7BG and whose main trading address is High Street, Lower Oddington, Moreton-in-Marsh, GL56 0UR which operates The Fox and The Bell including food and beverage sales, accommodation and events with the Site(s) of https://thefoxatoddington.com/, https://www.thebellatcharlbury.com; 

(iii) Windrush Taverns Limited, a company registered in England as a limited liability company with company number 08096787, whose registered office is at 13 Crescent Place, London SW3 2EA and whose main trading address is Asthall, Burford, Oxfordshire OX18 4HW which operates The Three Horseshoes (previously named The Maytime) including food and beverage sales, accommodation and events with the Site(s) of https://themaytime.com/, www.threehorseshoesasthall.com.  

Further hospitality venues may be added to the Daylesford Stays brand over time either by separate legal entities or through such properties being owned by one of the above legal entities and this privacy policy shall cover any such new properties.  

3.2 Data Controller. The lead data controller in respect of personal data processed under this policy will be the entity with whom you initially share your personal data with, which shall depend on the interaction you have had (for example, Daylesford Organic Limited is the controller and responsible for the website www.daylesford.com). 

3.3 How to contact us: We can be contacted as follows in connection with any questions, queries or complaints you may have relating to our handling of your personal data or in connection with this privacy policy: 

Contact details: 

Email: [email protected] 

Postal address: Data Request, Bamford Collection, 19 Mossop St, London SW3 2LY 

Phone number: 01608 731 700 

3.4 References to “we”, ‘us’ and ‘our’:  This privacy policy is issued on behalf of all entities falling within the Bamford Collection so “we”, “us” or “our” in this privacy policy is reference to the relevant data controller (see Clause 3.2) above.  Depending on your interactions, there may be a number of data controllers (for example, if you have purchased goods via both www.bamford.co.uk and www.daylesford.com you will have had interactions with both Bamford Limited and Daylesford Organic Limited, each of whom will have processed your data according to those interactions).   

4. CHANGES TO THIS POLICY

This policy may be amended at any time.  Please check this page from time to time to take notice of any changes that have been made.  Historic versions can be obtained by contacting us. 

5. 5.  WHY DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?

We collect personal information about you to inform you about, and provide you with, our services, to deal with any enquiries you may have about them and to improve and develop these and the site for the future. 

6. WHAT PERSONAL INFORMATION DO WE COLLECT?

6.1 Personal Data: Personal data, or personal information, means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data). 

6.2 Information collected from you: We may collect the following types of personal information about you: 

• Identity Data – Forename and surname, Company name (if relevant), gender, marital and family status (if you make this known to us in our dealings), date of birth, passport details 
• Contact Data – E-mail address, Telephone number, Address, billing name and address 

• Financial Data – includes payment card details and bank account 
• Transaction Data – Details of goods and/or services you have purchased from us and information about whether payment has been made  
• Profile Data – such as user name and password, purchases, orders or reservations made by you, your interests and preferences and any feedback and survey responses 
• Marketing and Communications Data – such as your preferences in receiving marketing from us and your communication preferences 
• Special Categories of personal data – We do collect health information about you (which is a Special Category of Personal Data) with your consent when you attend for treatments at a Bamford spa as this is necessary to protect your vital interests to ensure that we provide you with a suitable treatment taking into account your health or where you provide us with allergen information at any of our hospitality venues.  You have the right to object to providing such health information but we may not be able to provide you with our services. 

6.3 Information obtained from third parties: Depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services.  For example, if you’re using the site on your mobile, you may choose to provide us with location data.  The information we obtain from those services does depend on your settings for that service or their privacy policies.  So you should always regularly check what those are.   

6.4 Information collected from the website: We may automatically collect the following information about each of your visits to our Site(s): 

• Technical Data – including the Internet protocol (IP) address used to connect the computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; 
• Usage Data – information about your visit to our Site(s), including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; 
• Aggregated Data – which includes statistical or demographic data, for example we may aggregate your usage data to calculate the percentage of users using a specific Site feature.  Aggregate data is not considered personal data in law as this will not directly or indirectly reveal your identify, however if we combine aggregate date with personal data so that it can directly or indirectly identify you then we then treat it as personal data. 

6.5 Third party collection:  Certain third parties may collect personal information when you interact with our Site(s): 

• Rakuten – this entity may collect information including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please see https://rakutenadvertising.com/legal-notices/services-privacy-policy/ and https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/ 
• Klarna – In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice. 

6.6 Failure to provide personal data: Where we need to collect personal data by law, or under the terms of a contract 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 into with you.  In this case, we may have to cancel a product or service or reservation you have with us but we will notify you if this is the case at the time.  

7. HOW DO WE RECEIVE PERSONAL INFORMATION ABOUT YOU?

7.1 Direct interactions: We receive the personal information about you when you contact us directly in person (through our stores, spas or hospitality venues) or via post, email or telephone or through your visits to our Site(s) to request to purchase goods and/or services and/or to make a reservation, to create an account on our Site(s), to make a general enquiry, to provide us with feedback or to request marketing information or to subscribe to our newsletters, or when you enter a competition, promotion or survey. 

7.2 Automated technologies or interactions: As you interact with our Site(s), we will automatically collect Technical Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see the Cookie Policy on each Site for further details.  

7.3 Your interactions with third parties: We may receive personal information about you from various third parties: 

• Bamford Collection branded venues –  if you attend Bamford Collection branded venues operated by third parties your details may be provided to us to ensure that we can provide continuity of service and transition for you through your customer journey with us and to ensure that such operators are providing customers with the best possible service in line with brand requirements. Each such third party operator will have its own privacy policy also. 
• Technical Data – we may receive Technical Data from analytics providers such as Google, advertising networks, search information providers 

• Contact, Financial and Transaction Data – from providers of technical, payment and delivery services 
• Identity and Contact Data – from publicly available sources such as Companies House and the Electoral Register. 

8. HOW DO WE USE PERSONAL INFORMATION ABOUT YOU?

8.1 Principles of processing: We will only use your personal data when the law allows us to : (a) where we need to perform a contract with you, (b) where necessary for our legitimate interests where those are not overridden by your interests and rights (‘Legitimate Interests’ means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. It can and does also apply to processing which is in your interests too) (c) for legal compliance and (d) where none of those apply, with your consent.  

8.2 Use of personal information: We have set out below a description of all the ways we may use personal information about you and which of the legal bases we rely on to do so.  Note, we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 

In summary we use your personal information to: 

• identify who you are when you contact us 
• provide you with the goods and/or services you have requested (and note we may not be able to perform a contract if you fail to provide certain of the information requested) 
• to ensure payment for goods and/or services purchased and to prevent or detect fraud  
• to understand which of our goods and/or services you may be interested in 

• to contact you regarding goods and/or services you have ordered/booked to provide you with confirmation details, e-receipts and updates and to administer warranty claims or product safety related communications 
• to contact you to answer your general enquiries  
• to improve our goods and/or services and to carry out customer surveys 
• to resolve complaints or issues you may have  
• to manage our relationship with you 

• to send you marketing information about our goods/services or general news that you may be interested in regarding the Bamford Collection or parts of the Bamford Collection 
• to invite you to events you may be interested in 
• to improve our customer relationship with you 
• to administer our Site(s) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes 
• to improve our Site(s) to ensure that content is presented in the most effective manner for you and for your computer 

• as part of our efforts to keep our Site(s) safe and secure 

8.3 Marketing: You will receive newsletters and marketing communications (including email and/or SMS) from us if you have requested this or if you have purchased goods and/or services and have not opted out of receiving that marketing.  We strive to provide you with choices regarding personal data choices around marketing and advertising.  However, sometimes system functionalities limit the choices.  For example, an initial opt-in may be to marketing for all of Daylesford, Bamford and Daylesford Stays (rather than us being able to do a multiple choice opt-in to each of those brands separately).  However, you may then opt-out of marketing from any one or more of the brands upon request.  Other than the sharing of personal data between the entities within the Bamford Collection, where your opt-in to marketing expressly covers all of the brands rather than a part only, we will not share your personal data with any third party for marketing purposes.  

8.4 Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

9. HOW WILL WE CONTACT YOU?

We and our third-party service providers (e.g., order fulfilment and booking system providers, payment processors, marketing fulfilment agencies and customer service agencies) may contact you by post, telephone, email and/or text message depending on the reason for correspondence, unless you have told us not to or have registered with the telephone or post preference services. 

10. WHO DO WE PROVIDE THIS PERSONAL INFORMATION TO?

10.1 Internal Third Parties: Your information may be shared throughout the Bamford Collection for the purposes set out above where relevant.  For example, if you place a booking with Daylesford Stays which includes a cookery course then your information will be shared with Daylesford Organic Limited or if it includes a spa treatment it will be shared with Bamford Limited.  Where your marketing opt-in clearly identifies that it is an opt-in to Bamford Collection marketing in the entirety rather than any particular part then your information will be provided amongst the entities within the Bamford Collection to enable such marketing. 

10.2 External Third Parties: We will provide your personal information to: 

• our service providers who perform services on our behalf, such as our IT service providers who manage the site and its performance, booking system providers, gift card providers, delivery companies, marketing fulfilment agencies or professional advisers who provide legal, consultancy, insurance or accounting services; 

• Mention-Me Ltd if you apply to or are enrolled onto our refer-a-friend programme.  The personal data is shared for the operation of the refer-a-friend programme and includes customer email address and certain order data.  The information is processed to enable the enrolment, monitor the programme, for safeguarding against gaming or fraudulent use of the programme, communicate with customers in connection with the operation of the programme and delivery of rewards and for Daylesford to receive reports on the performance of the programme; 
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances 
• analytics and search engine providers that assist us in the improvement and optimisation of the site 
• the payment facilitators to process payment and to undertake fraud prevention checks. 

10.3 Phone payments: If you make payment over the phone then we directly input the payment details into our encrypted payment system.  These details may be held to secure bookings and to draw payment of any booking fees or cancellation fees in line with our cancellation policy but will not be fully visible to us or otherwise recorded. 

10.4 Limited third party use: We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

11. HOW YOUR INFORMATION IS SECURED

11.1 Storage by us: All personal information we have about you which you provide to us directly or through the Site(s) is stored on secure servers operated by us or our third-party IT service providers. Where you have a personal shopping service with members of our staff they may keep your contact details to hand in their records. We have put or ensure that there are in place appropriate security measures and policies to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

11.2 Third Party storage: Where information has been passed to our third-party service providers it will be stored on their secure servers. These third party service providers have access to your personal information needed to perform their functions, but may not use it for other purposes. We ensure that these third-party service providers will only process your personal data in accordance with this policy and applicable Data Protection legislation. 

11.3 Breaches: 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. 

12. DATA TRANSFERS

Your personal information may be processed by our third-party service providers operating outside the EEA in accordance with this privacy policy. We ensure appropriate safeguards are used to ensure that your personal data is given a similar degree of protection and is treated securely and in accordance the Data Protection legislation in connection to such transfers or processing of your personal data outside the EEA.  This could be through ensuring that your personal data is only transferred to countries that have been deemed to provide an adequate level of protection for personal data or through using specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

13. DATA RETENTION

Your personal information will be held in our customer relationship management systems for an indefinite period. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  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, regulatory, tax, accounting or other requirements.  We will carry out periodic data cleanses of this information to ensure that it is up to date and accurate and it is still reasonably necessary for us to retain it to fulfil the purposes we collected it for. In some circumstances we will 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. 

14. YOUR RIGHTS

14.1 Available rights: You have the following rights in connection with your personal information processed by us: 

• Access – you can request access to your personal information and further details about how your personal information is handled (commonly known as a ‘data subject access request’). 
• Object – you have the right to object to our processing of your personal information for direct marketing purposes or where the processing isn’t necessary for the purposes of the contract between us or legitimate interests pursued by us or by a third party.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Rectification – you can request rectification of any incomplete or incorrect personal data held about you.  It is important that the personal data that we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us. 
• Erasure – you can request erasure of any personal data where there is no good reason for us to continue processing 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. 

• Restriction – This enables you to ask us to suspend the processing of your personal data if you want us to establish the data’s accuracy, where our use of the data is unlawful but you do not want us to erase it, 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 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
• Transfer – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

14.2 How to exercise the rights: You can also exercise any of these rights at any time by contacting us using the contact details provided above. 

14.3 Withdrawal of marketing consent: You have a right at any time to withdraw consent to receiving marketing and/or to amend the delivery method we use. To manage your rights and delivery preferences please follow the instructions in our marketing communications, enquiry forms or contact us at the details stated in section 3.3.  Where you opt out of marketing, we may nonetheless retain your information in connection with previous transactions or correspondence for so long as is reasonably necessary in connection with the same. 

14.4 Cookies: You can set your brower to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of our Site(s) may become inaccessible or not function properly.  For more information about the cookies we use, please the Cookie Policy on each of our Site(s). 

14.5 Further information: Please note when you seek to enforce any of your rights, we may need to request specific information from you to help us confirm your identity as a security measure.  We may also contact you to ask you for further information in relation to your request to speed up our response. 

14.5 Fees: 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 could refuse to comply with your request in these circumstances. 

14.6 Timing: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

14.7 Concerns: If you are concerned or have questions about how The Fox handles your personal data please contact us and we will do our best to assist you.  

14.8 Complaints: Please note that you have the right to lodge a complaint with the UK Information Commissioner’s Office, the UK regulator for data protection issues, which may be accessed through the following link https://ico.org.uk/concerns/.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO to please contact us in the first instance.