Privacy Notice – Website

When Cinnamon Luxury Care processes your personal data, it is required to comply with the Data Protection Act 2018 , the UK GDPR and other laws and regulations governing the processing of personal data (together referred to as the “Data Protection Legislation”).

Your personal data is all the information we hold relating to you as an identified or identifiable natural person (for example, your name, email address, postal address, location data and in some cases opinions that we document about you).

Processing your personal data covers most things we do with it, including collecting, storing, amending, transferring and deleting it.  This Privacy Policy [together with our cookie policy] sets out how we collect personal information from you and how the personal information you provide will be processed by us. By visiting the website at cinnamoncc.com (the “Website”) you are accepting and consenting to the practices described in this Privacy Notice. If you do not consent, please do not submit any personal data to us.

This privacy notice provides information about the personal data we process, why we process it and how we process it.

Who we are

Cinnamon Luxury Care is the brand name used by a number of Care Homes and Retirement Villages run by different companies within the same corporate group. When this privacy notice refers to Cinnamon Luxury Care it means the company that runs a particular Care Home or Retirement Village.

Cinnamon Care Collection Limited (company number 10057697) provides data protection support to all companies within the Cinnamon Luxury Care Group, and provides the Data Protection Officer (DPO) for each of them.

The DPO has day to day responsibility for ensuring that we comply with the Data Protection Legislation and for dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.

You can contact the DPO, or obtain details of the company that runs a particular Care Home or Retirement Village and is the data controller for it, by writing to Cinnamon Care Collection Ltd as below:

Cinnamon Care Collection Limited, 24 Adam & Eve Mews, Kensington, London  W8 6UJ

Or by email to dpo@cinnamoncc.com

What personal data do we process about you?

 You may give us information about you by completing enquiry forms on the website or by requesting via our digital marketing communications that we send you marketing information.  The information you give us may include:

Personal details you provide us with through calls, forms, email or social media enquiries, such as your name, address, telephone numbers and email address. We use the information that you provide so we can respond to your requests and communicate with you.

• Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our helpline
• We use software called Google Analytics to track your visit on our website.  We use this to better understand our customers’ interests and tailor different website and advertising experiences.
• We use software which means, if you call us direct from our website, Facebook page, Google or an advert, we can combine information collected during that call with information about your browsing session. We use this to better understand our customers’ experiences, to tailor the sales experience for all those involved in your becoming one of our residents.
• Information that we receive from other sources. This includes information we receive about you when you use other websites operated by us or other services we provide. This information may include your name, email address, postal address and phone number.

The Website uses cookies to distinguish you from other users of the website. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy https://www.cinnamoncc.com/cookie-policy-uk/

Use made of the information

We may use the information we receive and/or collect about you to:

• Fulfil our obligations under any contract that we have entered into with you or with a Resident that you represent, and to provide you or the relevant Resident with information or services that you or the Resident has requested
• Send you newsletters and marketing information if you have consented to us doing so
• Notify you of products and services that we feel may interest you, or permit third parties to do so if you have provided the appropriate consent
• Monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website

Cinnamon Luxury Care processes personal information for certain legitimate business purposes, which include some or all the following:

• Where the processing enables Cinnamon Luxury Care to enhance, modify, personalise or otherwise improve the website, its services or communications
• To identify and prevent fraud
• To enhance the security of the network and information systems of Cinnamon Luxury Care
• To better understand how people interact with the websites of Cinnamon Luxury Care
• To administer the website and carry out data analysis, troubleshooting and testing; and
• To determine the effectiveness of promotional campaigns and advertising

Where we are processing personal data that we have obtained via the website on the basis of having obtained consent from you, you have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information from us) please let us know by contacting us by emailing hello@cinnamoncc.com. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit.

If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you and providing the details requested or by contacting us by emailing hello@cinnamoncc.com and we will take steps to ensure that this information is deleted as soon as reasonably practicable.

We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.

Third Party Sites

Our website may contain links to third party websites, including websites via which you are able to purchase

products and services. They are provided for your convenience only and we do not check, endorse, approve or agree with such third-party websites nor the products and/or services offered and sold on them. We have no responsibility for the content, product and/or services of the linked websites. Please ensure that you review all terms and conditions of website use and the Privacy Policy of any such third-party websites before use and before you submit any personal data to those websites.

How Safe is your Information?

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorised or unlawful access, processing, accidental loss, destruction and damage.

We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk.

Disclosure of your Information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter with them or you
• Third parties who may wish to contact you in respect of services or products they offer or sell which may be of interest to you, provided we receive your consent to such disclosure; and/or advertisers and advertising networks that require the data to select and serve relevant adverts to you and analytics and search engine providers that assist us in the improvement and optimisation of the website

Please note, we may need to disclose your personal information where we:

• Sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller
• Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
• Need to disclose it to protect our rights, property or the safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction

Wherever possible we ensure that any data necessary to be shared with other organisations remains within the UK or the EEA.  However, some organisations that we may share your personal data with are located in, or run their services from, countries outside of these areas and as a result your personal data may be transferred to countries outside of these areas.

How long will we keep your personal data?

We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements. Your information will be kept securely at all times.

Following the end of the relevant retention period, your files and the personal data covered by the retention period will be permanently deleted or destroyed.

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised the rights which may be available to you below, depending on the grounds on which we process your data. More information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide- to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.

1.  Access to your data

You have the right to ask us to confirm that we process your personal data, as well as having the right to request access to/copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this privacy notice.

We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we will let you know.

2.  Rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it unless we do not feel it is appropriate, in which case we will let you know why. We will also let you know if we need more time to comply with your request.

3.  Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

• Where we no longer need your personal data for the purpose for which we collected it
• Where we have collected your personal data on the grounds of consent and you withdraw that consent
• Where you object to the processing and we do not have any overriding legitimate interests to continue processing the data
• Where we have unlawfully processed your personal data (i.e. we have failed to comply with UK GDPR); and
• Where the personal data has to be deleted to comply with a legal obligation

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we will let you know.

4.  Right to restrict processing

In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we do not have to delete it. This right is available to you:

• If you believe the personal data we hold is not accurate – we will cease processing it until we can verify its accuracy
• If you have objected to us processing the data – we will cease processing it until we have determined whether our legitimate interests override your objection
• If the processing is unlawful; or
• If we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim

5.  Data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:

• Where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
• Where we carry out the processing by automated means

We will respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we will let you know.

6.  Right to object

You are entitled to object to us processing your personal data:

• If the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority
• For direct marketing purposes (including profiling); and/or
• For the purposes of scientific or historical research and statistics

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling, legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

Automated decision making

Automated decision making means making a decision solely by automated means without any human involvement.

We do not carry out any automated decision making using your personal data.

Your right to complain about our processing

If you have a complaint about how we have processed your personal data, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website: https://ico.org.uk/concerns/.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time. Where we make any change to this privacy notice which materially affects your rights and freedoms in respect of personal data we will notify you.

Any questions?

If you have any questions or would like more information about the ways in which we process your data, please contact dpo@cinnamoncc.com