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 terms ‘Personal Data’, ‘Controller’, ‘Processor’, ‘Data Subject’ and ‘special categories of Personal Data’ have the meanings given to those terms in European Parliament and Council Regulation 2016/679 (the General Data Protection Regulation or GDPR) which is available at: https://bit.ly/2KWndzE.

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 25 May 2018. It is directed to all natural 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
  • Using website cookies
  • 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
  • By taking photographs, e.g. of people who compete in the Blair Horse Trials

We do not purchase databases of Personal Data from third parties.

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
  • Users of our websites
  • Guests in our accommodation
  • Tenants
  • Members of the Atholl Highlanders
  • Blair Horse Trials competitors and officials
  • 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:

  • Names
  • Addresses, email addresses and telephone numbers
  • Marketing preferences
  • Details of bookings and use of the Estate’s services
  • Photographs, e.g. for use in our websites and marketing collateral
  • CCTV footage
  • Competition entries and placings
  • Vehicle registrations
  • Details of tenants’ occupations
  • Sports clubs membership numbers
  • Dates of birth, former names and occupations of our company officers
  • Payment card information
  • The nationality of guests in our accommodation
  • The numbers and places of issue of the passports of guests in our accommodation 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
  • Personal Data relating to the assessment of tenancy applications, including number of dependants, credit history, previous residential addresses, place of work, income and outgoings

We process the following types of data which may constitute Personal Data (Website Technical Data):

  • IP addresses, internet log information and details of visitor behaviour patterns

We process the following ‘special categories of Personal Data’:

  • Health information relating to persons who are injured on the Estate
  • Information about food allergies

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 the Blair Horse Trials (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 the Blair Horse Trials.

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 administer our business(es)
  • To perform contracts with Data Subjects
  • To comply with legal obligations (for example, under the Companies Act 2006, GDPR, health and safety legislation and under The Immigration (Hotel Records) Order 1972)
  • For archiving and historical research purposes
  • To defend legal claims
  • To detect and prevent fraud
  • To protect the security of our property, our employees and visitors to the Estate
  • To market and develop our business
  • To complete corporate reorganisations and disposals of assets and undertakings

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 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.

We use the Google Analytics and AddThis website tools for collecting analytical information about use of our websites and to facilitate social media engagement, respectively. This involves a transfer of Website Technical Data to Google and Oracle as the providers of these tools, who process the information for the purposes set out in their privacy notices available at the following URLs:

https://policies.google.com/privacy/partners

http://www.addthis.com/privacy/privacy-policy

We are not responsible for processing by Google or Oracle.

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 requirement (for example under the Companies Act 2006, GDPR, health and safety legislation and under The Immigration (Hotel Records) Order 1972) and where this applies, legal compliance is the legal basis for our processing.

If there is no legal requirement for us to process your Personal Data but 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 the legal basis for all necessary forms of processing.

We process email addresses for the purposes of sending electronic marketing communications on the basis of consent.

In all other cases, we process your Personal Data on the basis of our legitimate interest. The nature of our legitimate interest in each case will depend upon the purpose of the processing, as follows:

Purpose Legitimate interest
To administer our business Carrying out our general corporate operations, including: record-keeping, credit control, management and administration, developing and improving our products, services, websites and business processes, safeguarding our assets and legal interests, undertaking due diligence prior to entering into contractual relationships
To defend legal claims Safeguarding our assets
For archiving and historical research purposes The maintenance of sporting and historical records
To detect and prevent fraud Identifying and preventing unlawful financial transactions
To protect the security of our property, our employees and visitors to the Estate Preventing loss or damage to property and injury to individuals on the Estate
To market and develop our business Direct marketing
To complete corporate reorganisations and disposals of our assets and undertakings Ensuring the continuation of business as usual following a reorganisation or sale of any of our undertakings

Special categories of Personal Data

We process special categories of Personal Data relating to accidents for the purpose of complying with employment legislation and to defend against legal claims.

We process special categories of Personal Data relating to food allergies to protect the vital interests of the Data Subjects affected.

Retention periods

Our Personal Data retention policy is as follows:

Type of Personal Data Retention period
Name, email address and marketing preferences within our marketing lists 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)
Information relating to contracts Seven years after termination or expiry of the contract
Horse Trials entry information and placings May be retained for an indefinite period solely for archiving and historical research purposes
Membership information relating to the Atholl Highlanders May be retained for an indefinite period solely for archiving and historical research purposes
Personal Data we are required to process to comply with a legal obligation The period which is required by law
CCTV One week, unless the footage is or may be required to be used as evidence
Emails Maximum of seven years but emails may be deleted any time after sending or receipt if they are not material business records
Other Personal Data Seven years or such earlier time as we may determine to be appropriate in individual cases

 

Transfers outside of the European Economic Area (EEA)

Save as set out below, we do not transfer Personal Data outside of the EEA.

We transfer Website Technical Data (to the extent that this is Personal Data) to:

  • Countries outside of the EEA, on the basis of specific contractual clauses which have been
    approved by the European Commission which give Personal Data the same protection it has
    in EEA; and
  • To providers of IT services in the United States which are part of the Privacy Shield, which
    requires them to provide similar protection to Personal Data shared between the EEA and the
    US as it has in the EEA.

Recipients of Personal Data

We transfer or may transfer Personal Data:

  • To service providers (acting as Processors) based in the United Kingdom who provide IT administration services. Such service providers include without limit providers of booking, ticketing and payment processing services.
  • To service providers, sub-contractors and insurers where there is a business need for them to receive the Personal Data.
  • To our auditors and professional advisers (acting as Processors or joint Controllers), including lawyers, bankers and insurance companies who provide auditing or consultancy, banking, legal, insurance and accounting services.
  • To successors in title to any assets or undertakings with which the Personal Data is associated (acting as Controllers).
  • To public bodies, regulators or law enforcement agencies where this is required by law (acting as Controllers).
  • Relating to participants in the Blair Horse Trials to British Showjumping, British Eventing and other sports governing bodies.
  • In the form of photographs of visitors, festival goers, members of the Atholl Highlanders and competitors and officials in the Blair Horse Trials (including children) to the public by publishing images on our website and in our newsletter or other marketing collateral.
  • Including names and event entries and results in relation to the Atholl Highlanders and competitors and officials in the Blair Horse Trials (including children) to the public in event programmes, on our website and in our newsletter and other marketing collateral. This information may appear with photographs.

We transfer or may transfer Website Technical Data to Google and Oracle in connection with our use of the Google Analytics and AddThis web tools.

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. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use on our websites
and why.

Cookie name Retention period
_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.

 

Please note we only use cookies to enhance the functionality on the websites and do not use cookies to attempt to identify you for the purposes of processing your data in any way. We do not believe that our use of cookies involves the processing of Personal Data by us. However, we are required to obtain consent to the placement of cookies under The Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended). When you visit our website you are presented with a cookie control message (bottom right corner). You can control cookies in this area. Web browsers also offer control over cookies through the browser settings, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

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].