I. Name and address of the data controller

Brinklake Ltd is the data controller responsible for processing personal data under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection legislation.

Brinklake Ltd
Company number: 06783001

15 Wingbury Courtyard,
Leighton Road,
Wingrave,
HP22 4LW,
United Kingdom

Phone: 01296 688500
E-Mail: sales@brinklake.co.uk

Registered office address:

c/o Roberts Accountancy & Tax Ltd
11 Chartmoor Road,
Leighton Buzzard,
LU7 4WG,
United Kingdom

II. Contact for data protection issues

If you have any questions regarding data protection, please contact us by e-mail at sales@brinklake.co.uk

1. Scope of the processing of personal data
We process personal data only where necessary for the provision of our website, content and services. The processing of personal data of our users is regularly only carried out with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by legal regulations.

2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6(1)(a) of the UK General Data Protection Regulation (UK GDPR) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6(1)(b) UK GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Where the processing of personal data is necessary to comply with a legal obligation to which Brinklake Ltd is subject, Art. 6(1)(c) UK GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Art. 6(1)(d) UK GDPR serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6(1)(f) UK GDPR serves as the legal basis for the processing.

3. Data deletion and storage period
Personal data will be deleted or restricted as soon as the purpose of the storage no longer applies. Storage may also take place where required or permitted under applicable UK laws or regulatory requirements to which Brinklake Ltd is subject. Data will also be restricted or deleted if a storage period prescribed by the aforementioned standards expires, unless the continued retention of the data is necessary for the conclusion or fulfilment of a contract.

1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

• (1) Information about the type of browser and the version used.
• (2) The user’s operating system
• (3) The Internet service provider of the user
• (4) The IP address of the user
• (5) Date and time of access
• (6) Websites from which the user’s system accesses our website
• (7) Websites that are accessed by the user’s system via our website.

This data is also stored in our system log files. Log file data is not combined with other personal data that would enable the identification of individual users.

2. Legal basis for the data processing
The legal basis for the temporary storage of data is Art. 6(1)(f) UK GDPR.

3. Purpose of the data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

4. Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

5. Right to object
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. As this processing is necessary for the operation of the website, users cannot opt out of this processing.

a) Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored by the internet browser on the user’s computer system. When a user visits a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is visited again.

We use cookies to make our website more user-friendly. Some elements of our website require that the accessing browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

You can change the decision as to which cookies you wish to allow or reject here:

b) Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6(1)(f) UK GDPR.

c) Purpose of the data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

We require cookies for the following applications:

• Saving the settings of allowed and restricted Cookies
• Showing the website in the chosen language

The user data collected through technically necessary cookies is not used to create user profiles.

These purposes also constitute our legitimate interest in processing the personal data in accordance with Art. 6(1)(f) UK GDPR.

d) Duration of storage and cookie management
Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

1. Description and scope of data processing
Our website contains a contact form which can be used to contact us electronically. If a user takes advantage of this option, the data entered in the contact form is transmitted to us and stored. These data are:

• Subject of the enquiry
• Name
• Telephone number
• Date for callback
• Time for callback
• E-mail address
• Message

For the processing of the data, your consent is obtained during the sending process and reference is made to this data protection declaration.

Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored.

In this context, the data will not be passed on to third parties. The data is used exclusively for handling the enquiry.

2. Legal basis for data processing
The legal basis for the processing of data is Art. 6(1)(a) UK GDPR if the user has given their consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6(1)(f) UK GDPR. If the e-mail contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6(1)(b) UK GDPR.

3. Purpose of the data processing
The processing of the personal data from the contact form serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data submitted via the contact form and by e-mail, this is the case once the relevant enquiry has been concluded.

The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.

5. Right to object
The user may withdraw their consent to the processing of personal data at any time. If a user contacts us by e-mail, they may object to the storage of their personal data at any time, in which case the enquiry cannot be continued.

You may withdraw your consent or object to the storage of your personal data at any time by contacting us via e-mail or telephone.

All personal data stored in the course of contacting us will be deleted in this case.

1. Scope of the processing of personal data
This website uses Google Analytics, a web analytics service provided by Google LLC. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, where IP anonymisation is enabled, Google will truncate your IP address before further processing. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

2. Legal basis for the processing of personal data
The legal basis for the processing of users’ personal data is Art. 6 (1)(f) UK GDPR.

3. Purpose of the data processing
The processing of users’ personal data enables us to analyse the surfing behaviour of our users. By evaluating the data obtained, we are able to compile information on the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. These purposes are also our legitimate interest in processing the data in accordance with Art. 6(1)(f) UK GDPR. By anonymising the IP address, the interest of users in the protection of their personal data is adequately taken into account.

4. Duration of storage
The data is deleted as soon as it is no longer required for our recording purposes.

5. Right to object
Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link:

Google Analytics Opt-out Browser Add-on

Alternatively, you can use the following link to adjust the cookie settings for this website for this browser:

This website uses the Wordfence security plugin to protect against unauthorised access, malicious activity, and other security threats. The service is provided by Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA.

Where required, a UK GDPR-compliant data processing agreement has been concluded with the provider.

Further information about how Defiant processes personal data can be found in the provider’s privacy policy: 
https://www.wordfence.com/privacy-policy/

It may happen that third-party content, such as videos from YouTube, maps from Google Maps, RSS feeds or graphics from other websites, are integrated on our website. This always requires that the providers of this content are aware of your IP address, as without the IP address they would not be able to send the content to your browser. The IP address is thus required for the display of this content. We endeavour to only use content whose respective providers only use the IP address to deliver the content.

Within the website, YouTube videos of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, are used in particular. Google’s privacy policy can be found at https://www.google.com/policies/privacy/, opt-out options for Google’s data use can be found at: https://adssettings.google.com/. Where possible, the YouTube videos are used in extended data protection mode, whereby user data is only transmitted to YouTube when the videos are played.

We use the map service Google Maps. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”). Google Maps is used in the interest of an attractive presentation of our online offers and to make it easy to find the places we indicate on the website. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) UK GDPR.

To use Google Maps, your IP address must be processed. The information is usually transferred to a Google server in the USA and stored there. Brinklake Ltd has no control over this data transmission.

The data processing is carried out regardless of whether Google provides a user account via which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want your data to be associated with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or the needs-based design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide personalised advertising and to inform other users about your activities on our website. You have the right to refuse the creation of these user profiles, and to exercise this right you must contact Google.

Further information on the purpose and scope of data collection and processing can be found in the provider’s privacy policy. There you will also find further information on your rights in this regard and setting options for protecting your privacy:
https://policies.google.com/privacy

You can change the decision as to which external media you wish to allow here:

If your personal data is processed, you are a data subject within the meaning of the UK GDPR and you have the following rights in relation to the processing of your personal data by the data controller:

1. Right of access
You may request confirmation from the data controller as to whether personal data concerning you is being processed by us.

If there is such processing, you may request information from the data controller about the following:

• (1) the purposes for which the personal data are processed;
• (2) the categories of personal data which are processed;
• (3) the recipients or categories of recipients to whom your personal data has been or may be disclosed;
• (4) the period for which your personal data will be stored or, if specific information on this is not possible, criteria for determining the storage period;
• (5) the existence of a right to rectify or erase personal data concerning you, a right to have processing restricted by the controller or a right to object to such processing;
• (6) the right to lodge a complaint with the Information Commissioner’s Office (ICO);
• (7) any available information on the origin of the data if the personal data are not collected from the data subject;

You have the right to request information on whether the personal data concerning you are transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 of the UK GDPR in connection with the transfer.

2. Right to rectification
You have the right to request the rectification or completion of inaccurate or incomplete personal data. The data controller shall carry out the rectification without undue delay.

3. Right to restriction of processing
You may request the restriction of the processing of personal data concerning you under the following conditions:

• (1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
• (2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
• (3) the data controller no longer needs the personal data for the purposes of the processing, but you need it for the assertion, exercise or defence of legal claims; or
• (4) if you have objected to the processing pursuant to Art. 21(1) UK GDPR and it is not yet clear whether the controller’s legitimate grounds override your grounds.

Where the processing of personal data relating to you has been restricted, such data may only be processed – apart from being stored – with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest under applicable law.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the data controller before the restriction is lifted.

4. Right to erasure
a) Obligation to delete
You may request the data controller erase your personal data without undue delay, and the data controller is obliged to erase such data without undue delay, if one of the following reasons applies:

• (1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
• (2) You withdraw your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) UK GDPR and there is no other legal basis for the processing.
• (3) You object to the processing pursuant to Art. 21(1) of the UK GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) of the UK GDPR.
• (4) The personal data concerning you have been processed unlawfully.
• (5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under applicable law to which the controller is subject.
• (6) The personal data concerning you has been collected in relation to information society services offered pursuant to Art. 8(1) of the UK GDPR.

b) Information to third parties
If the data controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17(1) of the UK GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested them to erase all links to, or copies or replications of, that personal data.

c) Exceptions
The right to erasure does not apply insofar as the processing is necessary

• (1) for the exercise of the right to freedom of expression and information;
• (2) for compliance with a legal obligation which requires processing under applicable law to which the data controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
• (3) for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) of the UK GDPR;
• (4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) UK GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
• (5) to assert, exercise or defend legal claims.

5. Right to notification
If you have asserted the right to rectification, erasure or restriction of processing against the data controller, the data controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right against the data controller to be informed about these recipients.

6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the data controller in a structured, common and machine-readable format. You also have the right to transfer this data to another data controller without hindrance from the original data controller, provided that

• (1) the processing is based on consent pursuant to Art. 6(1)(a) UK GDPR or Art. 9(2)(a) UK GDPR or on a contract pursuant to Art. 6(1)(b) UK GDPR and
• (2) the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from one data controller to another data controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

7. Right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) UK GDPR; this also applies to profiling based on these provisions.

The data controller shall no longer process the personal data relating to you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

In connection with the use of information society services, you may exercise your right to object by automated means using technical specifications where appropriate.

8. Right to withdraw consent
You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

9. Automated decision-making in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• (1) is necessary for the conclusion or performance of a contract between you and the data controller,
• (2) is permissible on the basis of applicable law to which the data controller is subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests; or
• (3) is made with your express consent.

However, these decisions must not be based on special categories of personal data pursuant to Art. 9(1) of the UK GDPR, unless Article 9(2)(a) or (g) of the UK GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take reasonable measures to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the data controller, to express their point of view and contest the decision.

10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular with the Information Commissioner’s Office (ICO) or the relevant supervisory authority in the jurisdiction where the alleged infringement occurred, if you consider that the processing of personal data concerning you infringes the UK GDPR.

The supervisory authority will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 UK GDPR.

XI. Updates to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time to ensure it remains compliant with applicable legal requirements and reflects any changes to our services.

Any updates will be published on this page and will take effect upon publication. We encourage users to review this Privacy Policy periodically to stay informed about how we protect personal data.