heppleclose.net Privacy Policy

Gistelesworde Management Company Limited Privacy Policy

Last Updated: 15/09/2025

This Privacy Policy explains how Gistelesworde Management Company Limited ("we," "us," or "our") collects, uses, and protects your personal data when you use our website, www.heppleclose.net (the "Website").

We are committed to protecting your privacy and handling your personal data in a transparent and responsible manner, in compliance with the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

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1. Who We Are

Gistelesworde Management Company Limited is the data controller responsible for your personal data. Our registered address is Kfh House 5 Compton Road, Wimbledon, London, SW19 7QA.

If you have any questions about this Privacy Policy or our data protection practices, please contact us at:

• Email: management@heppleclose.net

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2. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data: This includes your first name, last name, username, or similar identifier.

• Contact Data: This includes your billing address, delivery address, email address, and telephone numbers.

• Financial Data: This includes payment card details (note: we do not store full payment card details – these are processed securely by our payment processor, KFH).

• Transaction Data: This includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data: This includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.

• Profile Data: This includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.1

   

• Usage Data: This includes information about how you use our Website, products, and services.

   

• Marketing and Communications Data: This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

   

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect information about criminal convictions and offences.

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3. How We Collect Your Data

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

• Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

  • Apply for our products or services.

  • Create an account on our Website.

  • Subscribe to our service or publications.

  • Request marketing to be sent to you.

  • Enter a competition, promotion, or survey.

  • Give us feedback.

• Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for more details.

• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, such as:

  • Technical Data from analytics providers like Google.

  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.4

     

  • Identity and Contact Data from data brokers or aggregators.5

     

  • Identity and Contact Data from publicly available sources such as Companies House 6and the Electoral Register.

     

4. How We Use Your 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:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

• To register you as a new customer:

  • Data Used: Identity, Contact

  • Legal Basis: Performance of a contract with you.

• To process and deliver your order, including:

  • Managing payments, fees, and charges.

  • Collecting and recovering money owed to us.

  • Data Used: Identity, Contact, Financial, Transaction, Marketing and Communications

  • Legal Basis: Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us).

• To manage our relationship with you, including:

  • Notifying you about changes to our terms or privacy policy.

  • Asking you to leave a review or take a survey.

  • Data Used: Identity, Contact, Profile, Marketing and Communications

  • Legal Basis: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

• To enable you to partake in a prize draw, competition, or survey:

  • Data Used: Identity, Contact, Profile, Usage, Marketing and Communications

  • Legal Basis: Performance of a contract with you; Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

• To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data):

  • Data Used: Technical, Identity, Contact

  • Legal Basis: 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); 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:

  • Data Used: Technical, Usage, Profile, Marketing and Communications

  • Legal Basis: 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:

  • Data Used: Technical, Usage

  • Legal Basis: 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:

  • Data Used: Identity, Contact, Technical, Usage, Profile

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

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5. Marketing

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

• Promotional offers from us: We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.

• Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

• Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

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6. Cookies

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 this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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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.

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8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

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9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request the transfer of your personal data to you or a third party.

• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

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.

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 for further information in relation to your request to speed up our response.

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.

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10. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us at management@heppleclose.net

You also 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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11. Changes to the Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on the date at the top of this policy. Any changes we may make in the future will be posted on this page. We encourage you to check back regularly to see any updates or changes to our Privacy Policy.