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Welcome to the privacy policy of Balcombe Care Homes Limited (the “Company”).
The Company respects your privacy and is committed to protecting your personal data. This privacy
policy will inform you how we look after your personal data and tell you about your privacy rights and
how the law protects you.
Please also use the Glossary below to understand the meaning of some of the terms used in this
privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how the Company collects and processes your
personal data, including any data you may provide through the Company’s website.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy we may provide on specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your data. This privacy policy
supplements other notices and privacy policies and is not intended to override them.


Balcombe Care Homes Limited is the controller and responsible for your personal data (referred to as “Company“, “we“, “us” or “our” in this privacy policy).
We have appointed a data protection officer (“DPO“) who is responsible for overseeing questions in
relation to this privacy policy. If you have any questions about this privacy policy, including any
requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Balcombe Care Homes Limited
Email address:
Postal address: Suite 49 Ocean Village, 4 Ocean Way, Southampton SO14 3JZ
Telephone number: +44 (0)23 80381680

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.

Third-party links 

Our website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When you
leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about

Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
We may collect, use, store and transfer two categories of personal data about you and (where this
applies) your dependents:

“standard personal information” includes:

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any
purpose. Aggregated Data could be derived from your personal data but is not considered personal
data in law as this data will not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

“special category information” includes:

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you,
and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our cookie policy [LINK] for further details.

We may also collect information from:

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

Please see section 10 to find out more about the types of lawful basis that we will rely on to process
your personal data. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we
will get your consent before sending third party direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your standard
personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground
has been set out in the table below.

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Purpose/Activity Lawful basis for processing including basis
of legitimate interest
To register you as a new customer.


Performance of a contract with you.
To process and deliver services to you including:
(a) manage payments, fees and charges;
(b) collect and recover money owed to us.


(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to
recover debts due to us).
To manage our relationship with you which will
(a) notifying you about changes to our terms or
privacy policy;
(b) asking you to leave a review or take a survey.


(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep
our records updated and to study how customers
use our products/services).
To administer and protect our business and
website (including troubleshooting, data analysis,
testing, system maintenance, support, reporting
and hosting of data).
(a) Necessary for our legitimate interests (for
running our business, provision of administration
and IT services, network security, to prevent
fraud and in the context of a business
reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.


To deliver relevant website content and
advertisements to you and measure or
understand the effectiveness of the advertising
we serve to you.


Necessary for our legitimate interests (to study
how customers use our products/services, to
develop them, to grow our business and to
inform our marketing strategy).
To use data analytics to improve our website,
products/services, marketing, customer
relationships and experiences.
Necessary for our legitimate interests (to define
types of customers for our products and services,
to keep our website updated and relevant, to
develop our business and to inform our
marketing strategy).


To make suggestions and recommendations to
you about goods or services that may be of
interest to you.


Necessary for our legitimate interests (to develop
our products/services and grow our business).


We process special category information about you where:


We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of our website may
become inaccessible or not function properly. For more information about the cookies we use, please refer to our website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table
(Purposes for which we will use your personal data) above:

third parties to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instruction

6. International transfers

We do not transfer your personal data outside the European Economic Area (“EEA”).6. International transfers


7. Data security


We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Data retention

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please see the ‘Your Legal Rights’ section below.

If you wish to exercise any of these rights, please contact us

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.

10. Glossary

Lawful Basis

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a

“Comply with a legal obligation” means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties
Other companies in the Balcombe Group (acting as joint controllers or processors).

External Third Parties


You have the right to:
“Request access” to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.

“Request correction” of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us.

“Request erasure” of your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

“Object to processing” of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

“Request restriction of processing” of your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios:

“Request the transfer” of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract with you.

“Withdraw consent at any time” where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.

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