Coombe House's Privacy Statement
This document declares the undertakings by Coombe House in relation to its handling of Your Data.
 
Contents
 Data Collection
 Data Security
 Data Use
 Data Disclosure
 Data Retention and Destruction
 Access by You to Your Personal Data
 Information about Data Handling Practices
 Handling of Enquiries, General Concerns and Complaints
 Enforcement
 Changes to These Privacy Undertakings
 Definitions
 
Data Collection
Coombe House undertakes to collect Your Data by means that are:
 fair;
 legal; and
 transparent.
If you visit Coombe House's web-site, your web-browser automatically discloses, and Coombe House's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (such as Coombe House.com). This data may or may not be sufficient to identify you.
If you disclose personal data to Coombe House in conjunction with an identifier such as your name or your credit-card details, Coombe House will collect Your Data. Moreover, any data that becomes available to Coombe House through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, Coombe House undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:
 where Coombe House reasonably considers that the protection of its financial interests requires that it gather YourData from other sources, or from additional sources. This applies in particular where Coombe House has a lending exposure to you, and seeks information about your creditworthiness;
 where Coombe House reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering YourData from other sources. This applies in particular to consumer profile data.
Where Coombe House collects Your Data from sources other than you, it undertakes:
 to do so only by legal means;
 to do so only with your Consent; and
 to declare to you what sources it uses, and under what circumstances.
Coombe House undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
 
Data Security
Coombe House undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Coombe House undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
Coombe House undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Coombe House undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by Coombe House's staff-members and contractors. These include:
 training for staff in relation to privacy;
 access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
 particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
 reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
 declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
 clear communication of policies and sanctions; and
 processes to audit, to investigate and to impose sanctions.
 
Data Use
Use refers to the application of Your Data by any part of Coombe House, or any staff-member or contractor of Coombe House in the course of their work.
Coombe House undertakes to use Your Data only for:
 the purposes for which it was collected;
 such other purposes as are subsequently agreed between Coombe House and You;
 such additional purposes as may be required by law. In these circumstances, Coombe House will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
 such additional purposes as are authorised by law (in particular to protect Coombe House's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Coombe House or have committed a breach of the criminal law).
Coombe House undertakes to use YourData only if it has demonstrable relevance to the particular use to which it is being put.
Coombe House undertakes to use YourData in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
 
Data Disclosure
Disclosure refers to making YourData available to any party other than Coombe House and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
Coombe House undertakes to disclose Your Data only under the following circumstances:
 in the course of business being conducted between You and Coombe House, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, Coombe House undertakes to exercise control over Coombe House's contractors to ensure that their actions are compliant with these Terms;
 in other circumstances that are directly implied by the purpose agreed between You and Coombe House at the time of data collection or subsequently. Where Your Data is disclosed in this way, Coombe House undertakes to exercise control over Coombe House's contractors to ensure that their actions are compliant with these Terms;
 with your consent, or at your request;
 where required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena. In these circumstances, Coombe House will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
 where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Coombe House believes on reasonable grounds that the disclosure of YourData will materially assist in the protection of the life of health of some person), provided that Coombe House will apply due diligence to ensure that the exercise of the permission is justifiable.
In all cases, Coombe House undertakes to disclose only such of Your Data as is necessary in the particular circumstances.
 
Data Retention and Destruction
Subject to the qualifications immediately below, Coombe House undertakes:
 to retain Your Data only as long as is consistent with its purpose; and
 to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.
This undertaking is qualified as follows:
 Your Data may be retained in Coombe House's logs, backups and audit trails within short-term retention cycles that are devised to protect the company's operations. In such cases, Your Data will be destroyed in accordance with those cycles;
 Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Coombe House:
o will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and
o will only retain Your Data while that provision is current, and will then destroy Your Data;
 Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect Coombe House's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Coombe House or have committed a breach of the criminal law). In these circumstances, Coombe House will only retain Your Data while that situation is current, and will then destroy Your Data.
 
Access by You to Your Personal Data
Coombe House undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, Coombe House undertakes to enable access:
 conveniently;
 without unreasonable delay; and
 without cost.
Coombe House undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Coombe House (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, Coombe House undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You undertake:
 not to seek access for frivolous purposes, or unreasonably frequently;
 to accept that deletion of some data may not be consistent with the provision of particular services by Coombe House to you.
 
Information about Data-Handling Practices
Coombe House undertakes to make information available to you about the manner in which Coombe House handles your data:
 in general terms, in a readily accessible manner; and
 in more specific terms, on request.
Where Your Data is disclosed to a contractor, Coombe House undertakes to make information available to you on request about the manner in which Coombe House's contractors handle your data.
Coombe House undertakes to ensure that the information provided is meaningful, and addresses your concerns.
You undertake:
 not to seek such information for frivolous purposes, or unreasonably frequently; and
 to accept that the disclosure of excessive detail may harm the security of Your Data and Coombe House's business processes, and may harm Coombe House's commercial interests.
 
Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about Coombe House's behaviour in relation to these Terms, you undertake:
 to communicate them in the first instance:
o to Coombe House only;
o in sufficient detail;
o through a channel made available by Coombe House for that purpose;
Coombe House undertakes:
 to provide one or more channels for communications to Coombe House, which are convenient to users;
 to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and Coombe House's reference-code for the communication;
 to promptly provide a response to the communication, in an appropriate and meaningful manner.
You further undertake to not pursue Coombe House through any Regulator or the media:
 until and unless Coombe House has had a reasonable opportunity to respond to the initial communication; and
 while Coombe House and you remain are conducting a meaningful dialogue about the matter.
 
Enforcement
Coombe House declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between You and Coombe House, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which Coombe House is domiciled or performed the relevant acts.
If you wish to discover the relevant laws in any particular jurisdiction, Coombe House draws your attention to the following resources:
 WorldLII Privacy Links
 Compilation of [U.S.] State and Federal Privacy Laws, Privacy Journal, Providence RI
 Privacy Law Sourcebook 2004, EPIC, Washington DC
 the Australian Privacy Foundation's pages:
o International Instruments Relating to Privacy Law
o Privacy Laws of Countries of the World
o Privacy Laws of the Commonwealth of Australia
o Privacy Laws of the States and Territories of Australia
 Privacy International
 
Changes to These Privacy Undertakings
Coombe House undertakes:
 not to materially change these Terms in a manner that reduces the protections for Your Data;
 to take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Your Data in a manner that reduces the protections for Your Data;
 where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organisations;
 where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
 to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.
 
Definitions
Coombe House means Coombe House and Cottages.
Your Data means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that Coombe House is capable of correlating with you, using such means as server-logs and cookie-contents.
Your Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.
Consent means your concurrence with an action to be taken by Coombe House. Consent may be express or implicit, but in either case must be informed and freely-given.

 

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