Who we are

Blair Castle Estate Limited (we/us) is a company registered in Scotland under company registration number SC156776 and having its registered office address at Atholl Estates Office, Blair Atholl, Pitlochry, Perthshire PH18 5TH.

We do not have a Data Protection Officer.

Interpretation

In this document, the following definitions shall apply:

Personal Data means any information relating to an identified or identifiable person to which this notice relates
Controller means a person or organisation which determines the purposes and means of the processing of Personal Data
Processor means a person or organisation which processes Personal Data on behalf of a Controller
Data Subject the person to whom Personal Data relate
Special Categories of Personal Data Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Guidance on the General Data Protection Regulation is available from the office of the Information Commissioner at https://ico.org.uk/

References in this document to ‘the Estate’ are to Blair Castle and the surrounding estate owned by us in Pitlochry, Perthshire, Scotland.

Scope of this document

This Privacy Notice takes effect from August 2018. It is directed to all persons whose Personal Data we process other than our employees, workers and volunteers. It applies to Personal Data collected by whatever means including without limit through our websites. It sets out information about how we collect Personal Data, the categories of Personal Data we collect, the purpose for which we process Personal Data, the legal basis for this processing, our legitimate interests in processing, how we share Personal Data and the rights of Data Subjects whose Personal Data we process.

More detailed information may be made available to some Data Subjects during the process of collection of their Personal Data which adds to or prevails over the general information in this Privacy Notice.

Updates to this document

This Privacy Notice may be updated from time to time. Please check this page for the latest version of our Privacy Notice each time you provide Personal Data to us.

Our status

We are the Controller in relation to all Personal Data which we collect.

How we collect Personal Data

We collect Personal Data in the following main ways:

  • In website contact forms at our websites available at: .atholl-estates.co.uk, .blair-castle.co.uk and .blairhorsetrials.co.uk
  • Automatically during the use of our websites, including through the use of cookie identifiers
  • In emails and hard copy correspondence sent to us
  • By taking notes during telephone calls
  • In paper forms (such as application forms, contact forms, guest registration forms and event entry forms)
  • Using video surveillance cameras at selected locations on the Estate
  • From third parties, for example during pre-contract enquiries in connection with tenancy applications, from publically available sources
  • By taking photographs, e.g. of people who compete in the Blair Horse Trials

We use Google Analytics and AddThis at our websites. This means that our websites automatically collect online identifiers such as IP addresses together with additional information which may include browser type, device type, date and time of visit and keywords used to find our websites.

Categories of Data Subject

We collect Personal Data in relation to the following main categories of Data Subject:

  • Visitors to and other users of the Estate
  • Visitors to our websites
  • Guests in our accommodation
  • Tenants
  • Members of the Atholl Highlanders
  • Competitors and officials in horse trials and other competitive events and emergency contacts of competitors
  • Representatives of corporate sponsors, customers and suppliers
  • The officers of our company
  • Members of the public who make enquiries

Types of Personal Data we Process

We process the following main types of Personal Data:

  • Name, title, date of birth, passport information, gun licence information, gender, sports club membership number, vehicle registration (Identity Data)
  • Address, email addresses and telephone number (Contact Data)
  • Marketing preferences (Marketing Data)
  • Details of bookings and use of the Estate’s services, records of sales and purchases of goods and services (Supply Data)
  • Photographs, e.g. for use in our websites and marketing collateral, other than large crowd images which do not contain Personal Data (Photographic Data)
  • CCTV footage (Surveillance Data)
  • Competition entries and results (Event Data)
  • Game records (Sporting Data)
  • Height and weight of pony trekking customers (Physiological Data)
  • Payment card and bank account information (Financial Data)
  • The nationality of guests in our accommodation and the numbers and places of issue of the passports of guests who are not Commonwealth citizens, British protected persons nor citizens of the Republic of Ireland as well as the next destination of such persons and their address there if known (Registration Data)
  • Personal Data relating to the assessment of tenancy applications, including number of dependants, credit history, previous residential addresses, place of work, income and outgoings (Tenancy Data)
  • Service history in relation members of the Atholl Highlands (Regimental Data)
  • Online identifiers such as internet protocol addresses and associated online data collected through our use of Google Analytics and AddThis (Online Data)

We may from time to time process information relating to non-workers who are injured on the Estate (Incident Data). This Personal Data falls within the Special Categories of Personal Data. We do not process Personal Data relating to criminal convictions.

We do not process Personal Data relating to children except where their Personal Data is captured by our CCTV monitoring systems or where their Personal Data is collected in connection with their participation in our competitive events (which Personal Data comprises or may comprise name, address, date of birth and photographs).

When the provision of Personal Data is a statutory requirement or a requirement necessary to enter into a contract

If you are aged over 16 years and are a guest in our accommodation, you are required by law to provide us with your full name and nationality upon arrival.

If you are not a Commonwealth citizen, British protected person nor a citizen of the Republic of Ireland you are additionally required by law, on arrival, to provide us with the number and place of issue of your passport (or other document establishing your identity and nationality) and before you leave, your next destination and if known, your full address there.

It is a requirement before entering into a tenancy agreement with us to provide the information requested in our tenancy application form.

It is a requirement before entering into any contract with us (except for admission to the Estate as a day visitor) to provide us with your name and address and if payment is required at the time the contract is entered into, your payment card information. We also require a date of birth from junior competitors in horse trials and other events.

You must in some circumstances produce your original firearms licence. More details will be provided at the time that you make a booking with us.

If you do not provide us with your Personal Data in the above circumstances, we will be unable to provide our services to you.

Purpose of processing

We collect Personal Data for the following main purposes:

  • To provide our goods and services and to organise events
  • To obtain supplies of goods and services
  • To process payments
  • To keep our accounts and tax records, manage complaints, undertake credit control and other management, record-keeping and administrative purposes
  • To comply with The Immigration (Hotel Records) Order 1972
  • To comply with Reporting of Injury, Disease and Dangerous Occurrences Regulations 2013
  • To comply with legal obligations generally, including under companies, taxation and data protection laws and where we are required to disclose data by a law enforcement agency
  • For historical research purposes
  • To defend against legal claims (including prospective legal claims)
  • To detect and prevent fraud
  • To protect the security and safety of our property, our employees and visitors to the Estate
  • To promote our events and businesses
  • To complete corporate reorganisations and disposals of assets and undertakings
  • To measure the effectiveness of our websites and to connect our websites with social media services

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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact information at the end of this document.

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.

The purposes for which Google and Oracle use information collected at our websites are described in their privacy notices at the following links:

https://policies.google.com/privacy/partners
http://www.addthis.com/privacy/privacy-policy

Personal Data collected during our use of AddThis may be used by Oracle and its customers for targeted online advertising. You can exercise your right not to receive this advertising at http://www.youronlinechoices.com/uk/your-ad-choices.

Lawful basis for processing

We only process Personal Data where we have a lawful basis for doing so.

Personal Data other than Special Categories of Personal Data

In some cases we will be required to process your Personal Data in order to comply with a legal obligation (for example under companies legislation, taxation legislation, data protection laws and under The Immigration (Hotel Records) Order 1972). Where this applies, we rely upon compliance with a legal obligation as one of the legal bases for processing your Personal Data. If it is necessary for us to process your Personal Data in order to comply with a contract between us, performance of the contract will be one of the legal bases for processing your Personal Data.

We process email addresses for the purposes of sending electronic marketing communications on the basis of consent where consent has been requested and obtained.

By using our website you consent to the setting of the cookies referred to later in this Privacy Notice and to the processing of your Personal Data by Oracle and Oracle Marketing and Data Cloud Customers in accordance with the AddThis privacy policy (available at: http://www.addthis.com/privacy/privacy-policy). We may request your consent to other forms of processing, such as the inclusion of Photographic Data on our website or in our marketing collateral, and where we do, consent is the legal basis for the processing covered by the consent. Where we are processing your Personal Data on the basis of consent, you can withdraw your consent at any time and if you do so we will cease processing your Personal Data unless there is another lawful basis for us to do so.

Where we are not relying upon consent, we process your Personal Data on the basis of our legitimate interest (in addition to any other legal bases which are available to us). Our legitimate interests in each case will depend upon the purpose of the processing, and may be any of the following:

  • Providing our goods, services and events
  • Obtaining supplies of goods and services
  • Processing payments
  • Keeping our accounts and tax records, managing complaints, credit control and carrying out other management, record-keeping and administrative activities
  • Preserving castle and Estate records for historical research purposes
  • Recording evidence which may be used to defend against legal claims (including prospective legal claims)
  • The detection and prevention of fraud
  • Protecting the security and safety of our property, our employees and visitors to the Estate
  • Monitoring the use of our websites and the impact of marketing campaigns
  • Completing corporate reorganisations and disposals of assets and undertakings
  • Promoting our events and businesses

Special Categories of Personal Data

We process Incident Data for the purpose of complying with social security law and on the basis of our legitimate interest in defending against legal claims and prospective legal claims.

Retention periods

We will never delete Personal Data where we have a legal obligation to retain it. Subject to this, we will store Personal Data for the periods set out below:

Type of Personal Data Retention period
Identity Data and Contact Data, in each case held for Marketing Purposes, Marketing Data Five years after last use or unsubscribe (we will not send marketing communications to Data Subjects who have unsubscribed but will keep a record of the Data Subject’s opt out)
Photographic Data used for marketing purposes We will remove photographs from our website(s) and will not use this in new marketing collateral if you withdraw your consent
Supply Data and all associated Identity Data and Contact Data (but excluding Personal Data referred to as being stored for longer periods under other headings) For the longest period required by law
Event Data, Regimental Data, Sporting Data, Identity Data and Contact Data relating to tenants, competitors, officials, members of the Atholl Highlands and participants in field sports or which is contained in our accounting ledgers Indefinitely. When retention of this Personal Data ceases to be necessary for other purposes, it may continue to be held for future historical research purposes
Incident Data The longer of the period required by law and 80 years from the date of the incident
Physiological Data We will delete Physiological Data after the relevant trek has safely taken place
Registration Data The period required by law
Surveillance Data 14 days unless the footage is or may be required to be used as evidence due to the occurrence of an incident
Financial Data Card payment details will be deleted or destroyed as soon as they cease to be required. Bank account information will be deleted within the same period as Supply Data
Online Data Google Analytics data will be retained for 26 months
Other Personal Data Seven years or such earlier time as we may determine to be appropriate in individual cases

We do not undertake to hold records for the above periods and they may be deleted or destroyed sooner than indicated above where this is lawful.

Transfers outside of the European Economic Area (EEA)

Transfers of Personal Data to countries outside of the EEA are made on the following bases:

  • Where the European Commission has made a finding of adequacy in relation to the laws of the country to which the Personal Data is to be transferred
  • Under standard contractual clauses which have been approved by the European Commission which give Personal Data the same protection it has in EEA
  • To organisations in the United States of America which are part of the Privacy Shield Framework, which requires them to provide similar protection to Personal Data shared between the EEA and the US as it has in the EEA
  • Where this is necessary to the performance of a contract between us and you or between us and a third party which is in your interests
  • Where this is necessary to protect your vital interests
  • On the basis of your explicit consent where no other lawful basis for the transfer is available

Recipients of Personal Data

We transfer or may transfer Personal Data to the following recipients:

Recipients Categories of Personal Data affected
IT service providers (acting as Processors). Such service providers include without limit providers of booking, ticketing and payment processing services and providers of website analytics services All of the Personal Data we process
Oracle (acting as Controller) through our use of the AddThis website tool Online Data
Auditors and professional advisers, including lawyers, bankers and insurance companies who provide auditing or consultancy, banking, legal, insurance and accounting services (acting as Controllers) All of the Personal Data we process
Other service providers, sub-contractors and insurers where there is a business need for them to receive the Personal Data (acting as processors or controllers) All of the Personal Data we process
Successors in title to any assets or undertakings with which the Personal Data is associated (acting as Controllers) All of the Personal Data we process
Public bodies, taxation authorities, courts, regulators or law enforcement agencies where this is required by law or in connection with the establishment, exercise or defence of legal claims (acting as Controllers) All of the Personal Data we process
Sports governing bodies (acting as Controllers) Event Data and related Identity Data
The public, news organisations Event Data as well as the names of participants, Personal Data relating to the activities of the Atholl Highlands, Photographic Data

Your legal rights

You have the right to:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data 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 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.

Object to processing of your Personal Data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. 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.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complain to complain to the supervisory authority in connection with our processing of your personal data. You can exercise this right by contacting the Office of the Information Commissioner at https://ico.org.uk/.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit.

Cookie name Purpose
_ga, _gat, _gid,
_utma, _utmb, _utmc,
_utmz
These cookies are set and used by Google Analytics to gather information about your visit to our website.
_cfduid Our website uses “Cloudflare”, a performance and security system. This cookie helps it determine trusted visitors to the website.
loc, mus, na_id, na_tc, notice_preferences, ssc, sshs, uid, ups, uvc Our website uses “addthis” which helps us keep track of statistics on shares/likes etc on our news section.
wfvt_xxxxxx, wordfence_verifiedHum an Our website uses “Wordfence”, a security plugin. These cookies help it distinguish between malicious visitors to the website and genuine people.

Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised 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.

Our websites may contain links to other websites of interest. However, once you have used one of these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to the website in question.

Contact us

If you have any questions about our processing of Personal Data or would like to exercise one of your legal rights, please contact the Estate Manager at Atholl Estates Office, Blair Atholl, Pitlochry, Perthshire PH18 5TH or by email to [email protected]