OUR PRIVACY POLICY
Coombe is committed to protecting your personal information. This is data that can be used to identify you. Your personal data is yours, and we want you to be confident that we are using it responsibly, and that you can tell us to stop using it if you want.
This privacy policy gives you detailed information on why and when we collect your personal information, how we use it, how we keep it secure and how you can let us know if you would like us to change how we manage it.
Coombe Farm Studios is a small-scale centre for creativity, it is a partnership between Lara Lloyd, Paul Riley and Tina Riley. VAT registration 259 1265 90. Coombe Farm Studios is the Data Controller of your personal information.
Contact details for Coombe Farm studios
Coombe Farm Studios, Dittisham, Dartmouth, Devon TQ6 0JA
We are the data controller for your personal data and we will ensure it is used and stored in accordance with the Data Protection Act (1998) , the Privacy and Electronic Communication Regulations (2003) and as of the 25th May 2018, the EU General Data Protection Regulation (EU 2016/679)
If you have questions regarding your information or its use, or for full statemen of our privacy policy, please contact our Data Protection Manger by email at lara@coombefarmstudios.com or by post using the details above.
This policy may change from time to time – for example, to take into account changes at Coombe or to reflect changes in regulation or legislation. It was last updated on 7th April 2020.
Updates to this policy will be posted on this page – please check back from time to time. We may also inform you of any changes by email where appropriate.
Further information on data protection regulations and laws can be found here https://ico.org.uk/for-the-public
WHY WE COLLECT PERSONAL INFORMATION
We only collect and process personal data when its necessary to carry out our business aims for example the delivery of our courses.
We may collect and process personal data to:
· Provide a service you have requested (e.g. to attend a course)
· Offer you a personalised experience of Coombe
· Inform you of events or updates if you have asked for this
· Contact you if we need to obtain or provide additional information (e.g. changes to course schedules or materials)
· Keep a record of business-related communications
· Understand our audiences and their preferences better so we can engage them in deeper and more meaningful way, and also use this insight to help our case for support when submitting and evaluating funding applications.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We may collect and retain information which provides information about you that can identify you.
The type of personal data that we collect and how it is used depends on where and when it is gathered.
Information provided by you:
When you make a financial transaction with us, e.g. when you book onto a course or purchase something from our shop.
We also keep a record of your interactions with us in our database e.g. what courses you have attended, what purchases you have made from our shop, when you have had an active membership, any projects you may have participated in or supported e.g. Producer Farm or Associate Artist Scheme and whether you have received, opened or clicked through any emails we may have sent.
We may collect your name and prefix, gender, email address, contact phone number(s), payment card details, delivery address(s), billing address, dietary requirements and access requirements and ask you where you heard about us. We will not hold payment information for any longer than it takes to process your transaction.
When you ask to subscribe to our email newsletter we will collect your email address
When you make a donation to Coombe we may collect your email address, gender, contact phone(s), payment details, billing address, gift aid declaration status, and details of the donation given and any specific purpose for the donation.
When you send an email to Coombe, we will keep your email address for correspondence.
We collect information from feedback forms, both hard copy and online.
Job-related information, if you apply to work for Coombe.
When you visit our website:
We may collect the following information:
Automatically populated IP address: a public IP address is a unique number which allows a computer, a group of computers or another internet connected device to browse the internet.
The logfile records the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version.
This information is collected to help diagnose and manage the website, to audit the geographical make-up of visitors, and to establish how they arrived at the website.
This is not an exhaustive list and we may retain different types of information for different individuals base on the service we are providing. For information on how long we retain your data for, refer to the ‘how we protect data’ section of this policy.
Information we obtain independently from you:
Your information may be shared with us by independent organisations – for example when we work in partnership on a project i.e. an exhibition with our sister gallery, Coombe Gallery Dartmouth, or Producer Farm. These organisations will only share information if you have indicated your consent and/or if it is required to complete a contract or booking.
HOW WE COLLECT PERSONAL INFORMATION
Generally, we collect your information when you decide to interact with us. Here are the ways we collect personal data:
When you book a course directly with Coombe on our website, over the phone or by post.
When you take part in a project or attend an exhibition in person
When you complete feedback and send it back to us
When you sign into our visitor book
When you post something about Coombe or one of the artists that we work with on social media (e.g. Twitter, Facebook or Instagram). We may record the post for us in publicity or for evaluation purposes. We may also collect and track anonymised data on our social media audiences to better understand the groups of people who engage with us online. We use this to ensure we engage with audiences and groups of people who are new to us.
When you send an email to us
When you write to us by post
When you give information to us in person (e.g. if you ask a member of staff to send our newsletter or inform them of dietary requirements).
If you buy items from our shop
If you make a donation to Coombe
If you attend a fundraising event
When you visit our website we use cookies to help make your experience of it better, and to understand how people interact with it. When you visit the website Coombe’s web server automatically records your public internet protocol (IP) address and generates a log fil.
Via publicly available information such as: Google, Companies House, Charities Commission, Donor Boards, Information published in articles/newspapers.
We may collect any of this information from a person acting on your behalf such as a personal assistant or family member.
We may from time to time email you for further information if we are required to update our records or for particular purposes. We will always tell you how we will use any further information received from you.
If you are under 18, please ensure that you obtain your parent/guardian’s consent before you provide personal data to Coombe. Users without such consent are not allowed to provide Coombe with their personal information.
You are entitled to choose not to give us certain information, although this may limit the level of personalisation that we are able to offer.
HOW WE USE PERSONAL INFORMATION
We may use personal data in the following ways:
In the normal course of running our business, and to provide a service or carry out a contract with you:
To fulfil course, shop, donation and membership requests
To process payments. Please note that Coombe does not store any credit card or other payment information once the transaction has been completed.
To provide the best possible customer service and to help us with internal administration.
To contact you with important information relating to your booking or purchase, such as confirming your order, reminding you of an upcoming payment deadline or for letting you know about any changes to the course or details such as materials lists or travel arrangements.
Where we have your consent:
To share your details with other arts organisations with whom we are in collaboration with Coombe. These organisations may contact you to let you know how they collected your data and to check that you are still happy to hear from them e.g. Coombe Gallery Dartmouth. You will always be able to opt out of their communications by contacting them directly.
To contact you regarding fundraising events or other fundraising activity.
Where we have a justifiable reason (including legal obligation and legitimate interest):
To continue to send you updates via email about what’s on, offers and news or about supporting us
To analyse and continually improve the services we offer including our courses, website, projects and shop.
To understand your interests and preferences so that we can contact you with information that is relevant to you.
To help us adapt our marketing communications so that they’re more relevant to you.
To use your anonymised details to show you advertising on social media platforms like Facebook or via their third party advertising that may appear on other websites you visit.
To classify Coombe’s audience into groups or segments, using booking and publicly available information. These segments e.g. ceramics or painting, help us to understand our audiences better and ensure we’re engaging with each group in the most relevant and welcome way possible.
To undertake research: we may contact you to ask you to participate in consumer either via an online or telephone survey or in person. You are under no obligation to participate in research and, should you provide any further information, Coombe will inform you how this will be used.
To keep our database accurate and relevant, for example, using National Change of Address.
To detect and reduce fraud and credit risk.
Legal compliance:
If we are required by law or requested by the police or regulatory or government authority investigating potentially illegal activities to provide information concerning your activities whilst using the network we will do so. We may also disclose personal data to appropriate third parties to assist in anti-fraud checks and investigations.
HOW WE MANAGE PERSONAL DATA AND KEEP IT ACCURATE
Coombe will never share, sell, rent or trade your personal information to any third parties for marketing purposes without your prior consent.
We will ask you for your consent to share personal information with like-minded organisations or individuals e.g. artists whose courses you have attended or where we have collaborated with organisations on projects or exhibitions.
Some of our service providers may have access to your data in order to perform services on our behalf – payment processing is a good example of this. We make sure anyone who provides a service for Coombe enters into an agreement with us and meets our standards for data security. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing.
There may be other instances when we are obliged to share personal data (e.g. if required to do so by the ‘know your donor’ court order) or when requested by the police or a regulatory or government authority investigating illegal activities.
We will keep your information only for as long as is reasonably necessary for the purposes set out in this privacy notice and to fulfil our legal obligations. We will not keep more information than we need. The retention period will vary according to the purpose, e.g. if attending a course, we will typically keep your data for up to ten years from the date of your last transaction. For further information about how long we will keep your information, please contact Coombe’s Data Protection manager using the contact details outlined in this notice.
From time to time we may screen our database against recognised data hygiene files such as the National Change of Address file to clean our database or correct inaccurate data. We may also update inaccurate data if the information is available.
If you ask us to update your personal information we will do so.
If you ask us to change how we process your personal data e.g. to stop sending direct marketing communications to you, or to remove your details from our database) we will keep the minimum amount of information to confirm your identity and the nature of your request.
HOW WE PROTECT PERSONAL DATA
Coombe is committed to protecting the personal information you entrust to us.
Personal data stored by us is kept on servers and computers in secure environments. These include Microsoft Sharepoint, Google Documents, Asana, Dropbox and work computers. All storage and data processing applications and the machines used to host them are password protected.
Only employees approved contractors/developers appointed by Coombe and who need the information are to perform a specific job are granted access to personally identifiable information.
In processing personal information as described in this document, some personal data may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of the computer servers used to host Coombe’s website or file system are located in a country outside the EEA. If Coombe transfers your personal information outside of the EEA in this way, w will take steps to ensure that your privacy rights continue to be protected as outlined in this privacy notice.
Coombe may transfer your data to the USA to organisations such as Microsoft or Google. The USA has weaker data protection laws than that of the EEA and therefore we will ensure that only organisations who are part of the EU privacy shield initiative will handle your personal information. More details on this certification can be found at www.privacyshield.gov/welcome
Please note: Coombe is not responsible for the privacy notices and practices of other websites even if accessed using links from www.coombefarmstudios.com and we recommend that you check the policy of each website you visit and contact its owner or Data Protection Manager if you have any concerns or questions.
Despite all our precautions, no data transmission over the internet is 100% secure. This means we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention to the fact that you do so at your own risk.
YOUR CHOICES
Personal data is your data and we want to make sure you feel in control of it.
We want it to be easy for you to access and amend the persona information that we hold on you, or request that we stop contacting you.
You can contact us by phoning, emailing, or writing.
Every email we send to you will include details on how to unsubscribe from future communications.
At any time you have the right to ask Coombe to amend or stop how it uses your personal information, including for marketing purposes.
If you would like to see what information we hold about you, you can request full details of personal information we hold about you under the Data Protection Regulation, by contacting Coombe’s Data Protection Manager. Please send a description of the information you would like to see, together with proof of your identity to Coombe’s Data Protection Manager.
You have the right to have any of your personal data that is held by us corrected. If you have any concern about the accuracy of your personal data, please let us know.
If you would like us to remove the personal information we hold about you, please contact us.
You have the right to lodge a complaint with the supervisory authority, The Information Commissioner’s Office – www.ioc.org.uk