Privacy Policy

Introduction:

This privacy policy is our Data Protection Policy and, along with any referenced documents, provides a comprehensive explanation of the personal data we may collect from you during your interactions with us.  It also details information on how we comply with the data protection law principles, how we process data, guidelines and procedures for ensuring that data subjects can exercise their rights and outlines our procedures for protecting your data.

We encourage you to carefully review this privacy policy to gain a thorough understanding of how we manage your personal information and our commitment to its security.  We understand that the amount of information presented here may appear extensive, but we believe it is essential for you to be well-informed about your rights and how we utilise your data.

The sections that follow are designed to address any questions you may have.  However, if you require further clarification, please do not hesitate to contact us.

Periodically, we may need to update this notice.  Rest assured we will notify you of any significant changes. You are also welcome to revisit and review this policy at any time. The date of our most recent update can be found at the bottom of the page.

The Manor & Ashbury Resorts:

The Manor House Hotel (Okehampton) Ltd own and operate The Manor Resort and The Ashbury Resort and are situated in Devon.  Our establishments specialise in Sport, Craft, Spa and Golf Breaks for individuals, families, groups and organisations.

For simplicity throughout this notice, ‘we’ and ‘us’ means The Manor & Ashbury Resorts.

We are legally obligated to safeguard personal information gathered in compliance with privacy laws, including but not limited to the General Data Protection Regulation (GDPR), the Data Protection Act 2018 (DPA) and the Privacy and Electronic Communications Regulations 2003 (PECR)

For the purpose of the DPA and PECR, we are the data controller and are located at The Manor Resort, Fowley Cross, Okehampton, DEVON. EX20 4NA.

If you have any queries relating to this policy you may write to us at this address or email: admin@manorashbury.co.uk.  Alternatively call the Resorts on 01837 53053.

The types of Personal Data that we collect:

  • Your Full Name
  • Your Address and Postcode
  • Your email address
  • Telephone Number
  • Age and DOB (including additional guests)
  • Your Gender
  • Additional guest names
  • Internet or other electronic network activity information, including information regarding your interaction with our websites, applications, or advertisements.
  • Online identifiers such as IP address and session ID’s.
  • Booking reference or unique identifiers
  • Health & Medical information, (where required, for example if voluntarily provided at booking to ensure the correct accommodation is booked, to enable participation in an activity or treatment).
  • Financial information (eg. bank/credit/debit details) These will be collected directly by a third-party payment provider and tokenised. We will never retain your complete payment card number in our records.
  • Images or footage captured by Photography or CCTV
  • Vehicle Information
  • Audio voice recording
  • Research information
  • Competition Data. This information is exclusively utilised for the specific competition’s objectives and is subject to the terms and conditions of that competition, which will be communicated to you upon your entry into the competition.
  • We may also collect publicly available information from social networking sites such as Facebook, Twitter, YouTube, Instagram, and Snapchat, for example likes, shares, tweets and posts about The Manor & Ashbury Resorts. This information is provided to us by a third party and used at an aggregate level for analysis purposes.

How we collect your Data and what we use your Data for:

Most of the personal information we process is provided to us directly by you for any of the following reasons and it is important that you understand the methods and reasons behind our utilisation of the personal data that we gather from you.  This section outlines the various purposes for which we process personal data and identifies the specific types of person data require for each purpose.

  • When you create an account with us, we will manage and administer your account and provide you with the relevant services
  • When you make a reservation for a break with us, we will process your information to complete your break and transmit service notifications related to your trip.
  • When you use our online Booking System to manage your break and additional services.
  • When you engage with us on social media.
  • When you download or install one of our applications.
  • When you voluntarily contact us with a query, a comment or make a complaint we will ensure your query is appropriately dealt with.
  • When you voluntarily participate in prize draw or competition, we will manage your data to facilitate your entry into the competition and execute activities associated with the competition.  This includes informing you if you have won a prize and using your information to get in touch if you should emerge as a winner.
  • When you schedule an appointment or attend an event organised by a third-party supplier, we will handle your data to the extent necessary to achieve our objectives and deliver the service to the third-party provider and their attendees or participants.
  • We may utilise your contact information from time to time to request your participation in surveys aimed at enhancing our offerings.  This data is employed for the purpose of analysing insights and information, which aids us in refining our services and offerings.  It also contributes to shaping our marketing and promotional endeavours and facilities personalised marketing tailored to your own preferences.
  • Periodically, we may engage research panels to perform market research on our behalf, which might entail gathering personal data for research purposes.  In cases where third-party research firms collect this personal data it may be subject to separate privacy policies.
  • Occasionally, we may utilise anonymised data for specific objectives, such as generating reports or gaining insights into your preferences and dislikes regarding services. This data is employed to ensure the effectiveness of our advertising efforts. When utilised for these purposes, the data does not allow for the identification of you or any other individual.
  • Subject to your consent, we will utilise your personal data, preferences, and transaction details to keep you informed via email, web, text or telephone regarding relevant products and services. This may include customised special offers, discounts, promotions, events, competitions and so on.  You have the freedom to opt out at any time.
  • If you fill in any forms eg. booking an activity or when going to a spa we will process your data to enable us to fulfil the service booked and to ensure the health and safety of our guests and team members.
  • In the event of an accident or incident at either of our Resorts, we may gather specific data from you to ensure that we can provide assistance to those affected and adhere to our health and safety protocols.
  • Occasionally, we may receive requests from television and other media companies to conduct filming or photography at our hotels.  Additionally, we produce our own promotional films and photographs at the Manor & Ashbury Resorts throughout the year.
  • Data collection from 3rd Parties for the purposes of mailing promotions.
  • In order to safeguard our customers, facilities, assets, and partners against criminal activities and to ensure constant health and safety measures, we maintain CCTV systems on our facilities and parking areas.  These systems capture images, and in some cases audio, for security purposes, as we do so based on our legitimate business interests.
  • To process payments and to prevent fraudulent transactions we may use third-party fraud protection services (i.e., 3D-Secure services) by which said third-party may receive your personal information to perform the fraud protection services.
  • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. The Legal basis for our use of this information is in our Legitimate Interests to ensure the safety of our guests and employees.  We may also use the footage to exercise and defend our legal rights.
  • We may be obligated to adhere to our contractual or legal commitments to disclose data to law enforcement and other authorities.  For instance, when presented with a court order or requirement to share data with government agencies, law enforcement bodies, or a court of law such as HM Revenue or DWP (Department for Work and Pensions).

 

Our Legal basis for using your data:

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing data are:

  • Consent

In certain situations, we have the option to gather and handle your data based on your explicit consent.  This occurs, for instance, when you indicate your desire to receive updates and promotional offers from us by checking a designated box.

  • Contractual Obligations

In specific situations, we may collect and process your personal information to fulfil our contractual obligations.  For instance, when you make a reservation with us, we will gather your personal data to facilitate the booking process and maintain communication with you regarding the details of your reservation.

You are able to remove your consent at any time by emailing admin@manorashbury.co.uk or writing to The Manor & Ashbury Resorts, Fowley Cross, Okehampton, DEVON. EX20 4NA

  • Legal Obligation

The Manor & Ashbury resorts may share personal information if compelled by legal obligations.  This could involve sharing information about individuals engaged in fraudulent or criminal activities with law enforcement agencies, aiming to safeguard the well-being and security of individuals and property, seek legal remedies, mitigate harm, or respond to emergencies

  • Legitimate Interest

In certain situations, we may need your data to advance our legitimate interests, which align with reasonable expectations within the scope of our business operations and do not significantly infringe upon your rights, freedom or interests.

For instance, we will utilise your reservation history to deliver personalised offers or make them accessible to you, but we will request your consent before sending any marketing materials.  Additionally, we may combine the booking histories of our customers to detect trends, ensuring our ability to meet demand and innovate new services.

Responses from The Manor & Ashbury Resorts surveys may also be used to identify trends and provide personalised offers to you.

We may also use your address to send you direct marketing information by post containing information about news and services that we think might be of interest to you.  Additionally, we may reach out to you for market research purposes.

In specific situations, when you make a booking with us and choose not to opt out of our email communications, we will utilise your personal data, preferences, and booking details to keep you informed through email, web, text and telephone about relevant news and services.  This may include customised offers, discount, promotions, and contests, and is referred to as a ‘Soft Opt-in.’

Sensitive Information:

Typically, we don’t gather sensitive personal details during the reservation process.  Nevertheless, if you choose to share any unique requests related to your booking such as those related to medical, dietary or religious preferences, we’ll make a record of them to ensure that we can accommodate your needs to the best of our ability.  We will not process this data for any other purpose.

When you book onsite activities (including, but not limited to sports, outdoor activities and spa treatments) we ask for information about your health including any pre-existing conditions relevant to the activity, as well as contact details of emergency contacts.

The information is collected for the following purposes:

  • To provide the activities and treatments you want and to ensure you can safely take part
  • To ensure we are able to contact someone in an emergency

This data is gathered for the following reasons:

  • To deliver the activities and treatments of your choice while ensuring your safety during participation.
  • To ensure that we have a means of contacting someone in case of an emergency.

Who we share your personal data with:

We occasionally disclose your personal information to trusted third parties.  Below is the protocol we adhere to when dealing with these organisations to safeguard your data and protect your privacy:

  • We provide them only with the data necessary for carrying out their designated service.
  • They are permitted to employ your data solely for the precise purposes specified in our contractual agreement with them.
  • They may only use your data for the exact purposes we specify in our contract with them.
  • We ensure that suitable due diligence measures are implemented to safeguard the security of your data.
  • We maintain a close collaboration with them to ensure that your privacy is consistently respected and protected.
  • In the event of discontinuing their services, any of your data retained by them with be either deleted, returned, or rendered anonymous.

Examples of the kind of third parties we may work with are:

  • Third party suppliers who help us manage our customer data
  • Information technology providers who help us to manage our IT systems and ensure that they are secure and protected from fraud and abuse; Direct marketing companies who help us manage our electronic and postal communications with you.
  • Technology solutions providers who help us show you advertising.
  • Direct marketing companies who help us manage our electronic and postal communications with you.
  • Data Insight and Market research agencies, who may send surveys on our behalf
  • Auditors and other professional advisors who help us manage our processes and improve accuracy of our data
  • Social Media platforms to show you services that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Policy for details.
  • Payment service providers that enable us to fulfil transactions with you.
  • Third-party fraud protection services (i.e., 3D-Secure services) by which said third-party may receive your personal information to perform fraud protection services. Activity providers.
  • To handle fraud-related matters, we may exchange information concerning fraudulent or potentially fraudulent activities within our facilities or systems.  This may involve sharing data about individuals with law enforcement bodies.
  • Partnerships we work with to bring certain services or breaks to our guests.
  • There might be circumstances where we are obligated to reveal your personal data in compliance with legal mandates or to safeguard and uphold our rights or those of any third party.
  • Periodically, we may consider expanding, downsizing or selling our business, and as a result, may disclose data to potential buyers of our business or assets.  In such instances, your personal data will, as applicable, be transferred to the new owner or controlling body, subject to the terms of this Privacy Notice.
  • Activity and event providers – In cases where you are participating in an event organised by a third party at our Resorts, we may share booking particulars with them to facilitate efficient event planning. Our legal basis for the sharing of this data is our contractual obligation to our partners.

Combining your information for customised marketing purposes:

We want to bring you news and promotional offers tailored to your specific interests. We will use your email address to send you email marketing (including our newsletters and information about new services and competitions when you sign up to receive them from us.)

You can opt out of receiving marketing emails whenever you wish by following the provided instructions or unsubscribe link within any of the messages, we send you or, by adjusting your preferences.  If you opt out of email marketing, we will continue to send you service communications from time to time such as information about your reservations, and updates to our policies.

We may use information obtained as part of our surveys to enrich our marketing data. If this is the case, we will make that clear to you setting out our lawful basis for our processing.

We may use basic demographic information provided to personalise our targeted advertising.

We and other third parties may also use cookies to assist in targeted advertising. You can find more about this in our cookies policy below

We also promote our content and features through third-party platforms, such as social media sites like Facebook. Typically, this process involves sending a hashed or encrypted identifier to the third-party platform, which is then cross-referenced with their records to determine whether you are also a use of their platform.  If you are identified as a user, it enables us to deliver promotions and content features that we believe will be of interest to you.

We may also use Facebook’s business tools to facilitate the transfer of specific data to Facebook.  This assists us in assessing the effectiveness of our marketing efforts.

Facebook acts as a data processor when it provides matching, measurement, and analytics services to us when using Facebooks business tools.

Facebook also acts independently as a data controller when it combines our user Event Data with the Event Data from other advertisers to improve and refine its ad targeting algorithm to help it deliver more personalised ads to its users. Further information about how Facebook processes your personal data, including the legal basis Facebook Ireland relies on and the ways to exercise your rights under GDPR against Facebook Ireland, can be found in Facebook Ireland’s Data Policy at https://www.facebook.com/about/privacy . More information about the security measures that Facebook uses can be found here: https://www.facebook.com/legal/terms/data_security_terms.

We use our legitimate interests as the legal foundation for processing your personal information when it comes to customising the promotion our content on third-party party platforms.  This approach ensures that our marketing communications will be more relevant, and our campaigns will effectively target the appropriate audiences.  You have the option to discontinue receiving this form of marketing on other platforms at any time by adjusting your preferences within the ‘Privacy settings’ section of your Account Settings.  We will handle your request promptly, although you may still encounter our promoted messages while your request is being handled.

Our content may be featured on third-party websites solely based on your actions on these platforms.  For instance, if you’ve expressed interest in our brand or its content on Facebook, you might encounter our content there.  Likewise, if someone in your social network (eg. a Facebook friend) engages with our brand or content, it may show up in your News Feed.  These branded messages are managed by the third-party platform, but you might have the option to modify your preferences to prevent such messages from appearing in the futures.  For instance, you can tailor your Facebook News Feed using the ‘News Feed Preferences’ features.

If you download our App, a portion of the messages we send, such as marketing communications, content suggestions and updates about new content or features, might be delivered via push notifications.  These are alerts that appear on your mobile device’s screen.  You have the option to decide if you want to receive push notifications from the App by adjusting your device settings.

For Android users, push notifications are automatically enabled on your device, and you will need to disable them if you prefer not to receive them.  Apple device users, on the other hand, will be prompted during device set up to decide whether they wish to receive push notifications, and you can make your selection at that time.  If you change your mind, you can modify your preferences at any moment within your device settings.

Transfers and Data Sharing:

The company takes proportionate and effective measures to protect personal data held and processed by us at all times, however we recognise the high-risk nature of disclosing and transferring personal data and as such, place an even higher priority on the production and security of data being transferred.  Data transferred within the UK and EU are deemed less of a risk than a third county or an international organisation, due to the data protection laws covering the former and the strict regulations applicable to all EU Member states.

Where data is being transferred for a legal and necessary purpose, we use a process that ensures such data is encrypted and where possible is also subject to our data minimisation tools.

How long we keep your personal data

Whenever we gather or handle your personal information, we will retain it only for the duration required to fulfil the original purpose of its collection.  The length of this retention period will be determined by any applicable business or legal obligations.

In order to establish the suitable timeframe for retaining personal information, we take into account several factors, including the quantity and type of personal data, the potential risks associated with unauthorised use or disclosure, the objectives of processing the date, whether those objects can be accomplished through alternative methods, and any relevant requirements.

At the conclusion of this retention period, your data will either be entirely deleted or rendered anonymous.  For instance, it may be aggregated with other data to ensure it can be utilised in a non-identifiable manner for statistical and business planning.

If you require additional information, please don’t hesitate to get in touch with us using the contact information provided.

Cookie Policy

Cookies and other tracking technologies

We use cookies and comparable technologies, such as pixel tags or links, to remember when you visit our websites and enhance your online interaction according to your preferences.  These tools aid us in understanding how you, and other users, navigate our websites, view our services and respond to our advertisement.  Cookies and other similar technologies serve the following purposes:

  • Tailor direct marketing and enhance our overall service offering
  • Tailor our website to be relevant to you
  • Track how you use our website
  • Track which of our advertisements drive you to our website
  • Track emails we send to you
  • Connect your Manor & Ashbury Resorts login details to your other information so that we can identify you as an individual
  • Remember your log in information when you return to the websites

Additionally, we use your personal data to customise the marketing communications we send you and to personalise the things you see when you log into the account facilities.  This can include service-related emails regarding items in your car or marketing communications highlighting produces aligned with your browsing history.

The cookies we use fall under five main categories and you can opt in or opt out of any of these categories any time:

  • Necessary cookies

Necessary cookies, also known as essential cookies, are a type of cookie used in web browsing that is crucial for the basic functioning of a website or online service.  These cookies are typically set in response to specific actions taken by users, such as filling out forms, logging in, or navigating through different pages. Unlike other types of cookies, strictly necessary cookies do not require user consent because they are essential for the website to perform its core functions and, as a result cannot be switched off in our systems. They do not store any personally identifiable information.

  • Performance cookies

These cookies enable us to track and analyse website visits and traffic sources, allowing us to assess and enhance our site’s performance.  They provide insights into which pages receive the most and least traffic and help us understand how visitors navigate through the site.  Importantly, all data collected by these cookies is aggregated and, therefore, anonymous.  This ensures that individual user identities remain protected.  If you choose not to allow these cookies, we will not have the visibility into your site visits, and our ability to monitor and optimise site performance will be limited.

  • Functional Cookies

These cookies empower the website to deliver improved features and customisation options.  They can be established by either us or third-party providers whose services have been integrated into our webpages.  Opting not to permit these cookies could result in some or all of these services not operating as expected.

  • Advertising Cookies

These cookies can be placed on our website by our advertising partners.  Their purpose is to create a profile of your interests, enabling them to display relevant advertisements on other websites.  These cookies do not store your personal information directly but rely on unique identifiers for your browser and internet device.  If you choose not to permit these cookies you may encounter less targeted advertising.

  • Social Media Cookies

These cookies are established by various social media services integrated into our site, allowing you to easily share our content with your friends and networks.  They have the capability to follow your browser activity on other websites, constructing a profile of your interests.  Consequently, this may influence the contact and messages presented to you on other websites you visit.  If you opt not to authorise these cookies, you might not be able to see or use these sharing tools.

How to change your cookie settings:

You are able to adjust your cookie preferences at any moment by selecting ‘manage cookies.’ You can modify the settings by sliding them to either ‘on’ or ‘off’ and subsequently clicking ‘save.’ In some cases, you may need to refresh your page in order to activate some of these adjustments.

Alternatively, the majority of web browsers offer a degree of control over cookies through their settings.  To gain further insights into cookies, including instructions on how to view the cookies that have been set, please visit www.aboutcookies.org or www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

To find information relating to other browsers, visit the browser developer’s website.  To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

For more information about cookies and how to disable them, please visit the Information Commissioner’s webpage about cookies. https://ico.org.uk/for-the-public/

First Party and Third-Party Cookies

Cookies that are established by the website you are currently visiting are referred to as ‘First Party’ cookies. Conversely, cookies set by anyone other than the website owner are termed ‘Third Party’ cookies.  This commonly happens when a website incorporates components from external sources, such as images, social media plugins or advertising content.

You are not obliged to enable all cookies on your computer or device.  You have the option to configure your browser settings to decline specific cookies.  However, it’s important to note that this may impact your website experience in certain instances.  Some of the cookies we utilise play a role in identifying and resolving errors, or they facilities specific features.

You are able to manage your cookie preferences at any time by clicking on the ‘Manage Settings’ located in the footer of this website.

Your data protection rights:

Under data protection law, you have rights including:

  • Your right of access – You have the right to ask us for copies of your personal information.
  • Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.  Please contact us at admin@manorashbury.co.uk, or write to The Manor & Ashbury Resorts, Fowley Cross, Okehampton, DEVON. EX20 4NA.  Alternatively call 01837 53053 if you wish to make a request.

We reserve the right to modify this privacy policy periodically.  Any future alterations will be disclosed on our platform which can be found https://www.manorandashburyresorts.co.uk/info/privacy-policy.

We trust that this Privacy Policy has been informative in setting out the way we manage your personal data and your entitlement to control it.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at admin@manorashbury.co.uk, or write to The Manor & Ashbury Resorts, Fowley Cross, Okehampton, DEVON. EX20 4NA.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Last Reviewed February 2025