Please note that, for the purposes of this Policy, EPGL means Enterprise Property Group Limited and its directly or indirectly held subsidiaries, Enterprise Heritage Limited (“EHL”), Enterprise Retirement Living Limited (“ERL”), Boughton Hall Management Limited (“BHML”) and Red House Ripon Management Limited (“RHRML”), the latter two being the management companies responsible for ERL’s current retirement villages.
The personal data referred to may be obtained electronically (by direct email, or emails/registrations sent through EPGL’s websites) or other means (for example, business cards, reservation forms, telephone calls, letters, orders, contracts, etc).
Under The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) (“the GDPR”), EPGL is both the Data Controller and Data Processor in respect of such information. EPGL’s Data Protection Officer is Wendy Fleckney, who can be contacted by email on firstname.lastname@example.org, by phone on 01223 835995, or by post at Enterprise Property Group Limited, Scutches Barn, 17 High Street, Whittlesford, Cambridge, CB22 4LT.
EPGL, ERL, BHML and RHRML are registered with the Information Commissioner’s Office under the Data Protection Act. Our registration numbers are ZA285249, ZA187832, ZA187838 and ZA263188 respectively.
We only collect, use, store and share (where appropriate) personal data that is relevant and necessary for the purposes of our relationship with you, and this will vary depending on that relationship. We do not keep it for any longer than required, plus an applicable retention period, but again these timescales will differ according to the nature of our association (see Section 8 below).
The categories of personal data could include all or some of the following:
We may also collect, store and use information about you that falls into special categories of more sensitive personal data. This includes information about (where applicable):
The categories marked with an asterisk generally relate only to our customers who purchase a new-build or pre-owned retirement property and subsequently live in ERL’s retirement villages. This information is required to enable the respective management companies to fulfil their obligations to those customers.
We only collect and use personal information about you when the law allows us to do so. This means we will use your information only for the specific purpose(s) it was given or obtained, for example to:
Less commonly, we may also use personal information about you where:
Unless you have specifically registered for, and consented to receive, information in relation to one or more of our developments, your details will not be entered on a central database and not used for marketing purposes.
Where it has been necessary for you to provide us with consent to use your data, you may withdraw this consent at any time (see Section 7 below).
You also have certain other rights in relation to your personal data, again see Section 7 below.
We process your information electronically and/or manually, and may contact you by email, telephone, text message or in writing, depending on the contact details you have provided and, where applicable, the means by which you have given your explicit consent to be contacted.
We create and maintain various electronic and hard copy files in order to record essential information to enable us to conduct our relationship with and obligations to you. These files will vary according to that relationship and those obligations. The information contained in these files is kept secure.
We never, under any circumstances, sell personal data that we hold. However, where it is necessary and applicable (and it complies with data protection legislation), or is legally required, we may share personal information about you with:
We have not in the past had cause to transfer personal data to another country, but should the need arise, we will do so in accordance with data protection legislation.
Individuals have a right to make a subject access request to gain access to personal information that any organisation holds about them.
If you make a subject access request of us in respect of any information we hold about you, we will:
If you would like to make a subject access request, please contact our Data Protection Officer, who will explain the process and timescales.
There is no charge to provide this information, except in exceptional circumstances (for example, if the request is manifestly unfounded or excessive, or if you request further copies of the data already supplied; in these cases the charge will be based on the administrative costs incurred).
Under data protection legislation, individuals have certain rights regarding how their personal data is used and kept safe. You have the right to:
You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.
If you require your record to be removed or amended, please contact our Data Protection Officer.
The length of time we retain information once our relationship with you has come to an end is:
Notwithstanding the above timescales, you are at liberty to ask us to delete your information at any time (see Section 7 above). If there are any consequences arising from your doing so, we will explain this at the time.
We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of your personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance by contacting our Data Protection Officer. We will do everything possible to resolve any issue to everyone’s mutual satisfaction.
You are also at liberty to make a complaint to the Information Commissioner’s Office (“ICO”), but we would urge you to pursue the route above first before escalating the matter in this way if it cannot be settled between us. The contact details for the ICO are:
If you have any other questions or matters to raise in relation to this Policy not covered by the above, please contact our Data Protection Officer.
You are not required to provide any personal information on the public areas of our websites. However, you may choose to do so by completing a registration form and providing us with information about yourself, such as your name and address, so that we can respond to requests for information. You can unsubscribe from emails and further contact at any time on request, when we will delete any details we hold on you. Email marketing circulars will contain an Unsubscribe option which you can click on to have your details removed. Alternatively, please contact our Data Protection Officer by direct email, telephone or post.
We know that people have concerns about cookies, but we believe that the benefit that you and ERL gain from their proper use is worthwhile.
You can delete the files that contain cookies – those files are stored as part of your internet browser. If you wish to restrict or block the cookies which are set by EPGL’s websites, or indeed any other website, or if you wish to receive notification of cookie placement requests or decline cookies completely, you can do this through your browser settings. The Help function within your browser should tell you how. Please be aware that declining or denying cookies may prevent you from being able to use the website to its highest capability.
Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies. For information on how to do this on the browser of your mobile device you will need to refer to your manual.
This is a list of the main cookies set by EPGL’s websites, and what each is used for:
|Cookie name||Used for||Cookie expires||Definition|
|__utma||Metrics: Google||2 years||www.erl.co.uk uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of our website and compile reports on user activity.
Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
|__utmb||Metrics: Google||30 mins|
|__utmc||Metrics: Google||End of session|
|__utmz||Metrics: Google||6 months|