Privacy Policy

When we talk about Hawthorn & Kent we mean Hawthorn & Kent Limited, registered number 15382963, of 39 The Cobalt Building, 1600 Eureka Park, Lower Pemberton, Ashford, Kent TN25 4BF (“us”, “we”, “our”).

We are a leading provider of premium photography solutions and souvenirs for visitor attractions and events in the United Kingdom. We own and operate the www.hawthornandkent.com website and offer systems and solutions for clients across the UK (known as “Venues”) to optimise their guest operations and drive additional revenue. 

This Privacy Policy outlines our commitment to data security and responsible use of personal information collected through our services. It explains the types of data we collect, and how we store, protect and process it. 

We offer reliable and proven instant photo solutions with on-site printing and digital platforms for locations across the UK (known collectively as ‘Venues’). We work closely with our photography solution partner, who is data owner, controller and processor for clients of Venues utilising our photo solutions. For further information on how they manage data please visit www.gophoto.com. 

We also offer a Front of House ordering system to facilitate seamlined customer ordering and payment. For this product we work closely with our partner, who is data owner, controller and processor for clients of Venues utilising the Front of House Ordering software. For further information on how they manage data please visit www.orbitalsound.com.

We may collect information from our clients through our services, and this policy applies to individuals who interact with us through the following channels: 

• Our services: including our website (www.hawthornandkent.com)

• Social Media: Interactions with us on social media platforms and other online and offline channels

Personal Data

“Personal Data” refers to any information that identifies or can be used to identify an individual. This may include but is not limited to, your name, email address, phone number, and other contact details submitted to us.  

Acceptance: By using our Services, you acknowledge and agree to the terms of this Privacy Policy. If you do not agree to this policy, please refrain from using our Services.

Changes to this Policy: We reserve the right to update this Privacy Policy periodically. We will notify users of any significant changes by posting the revised policy on our website.

Data Subjects:

• Customer Personnel: For individuals employed by our clients (e.g., attraction staff), collected data may encompass name, email address, job title, work location, phone number, and communication logs (emails, phone records, transcripts).

• General Inquiries: Individuals contacting us through our website may voluntarily provide personal information.

What data do collect we about you?

We have set out below the different types of personal data that you provide directly to us, or which we collect from you when we interact. We also wanted to let you know why we use this data and the different legal grounds which allow us to do so.  You don’t have to give us any of this data but if you don’t, you may not receive our optimal overall client experience.  But that is your choice – and we respect that.

You may provide us with the following types of personal data when you directly interact with us (through our websites, via social media or otherwise):

• Contact - first name, surname,country of residence, email address, telephone numbers and address

• Profile – your preferences for marketing, other website preferences, your contact history

We may also collect the following types of personal data from you when you use our websites (using Cookies or other tracking technologies):

• Technical – browser type, device information, IP address, hardware type, network and software identifiers, operating system and system configuration

• Usage – information about how you use our websites, including time spent on page, click-throughs, download errors, browsing patterns

Why do we use your data and what are our legal grounds?

The table below sets out how we use your personal data and our lawful basis for doing so. In addition to these purposes, please note that we also anonymise and aggregate personal data (so that it does not personally identify you) and use it for testing our internal systems, carrying out research and general data analysis. Because this is not personally identifiable, we can use this for any purposes.

Sharing your data

 Hawthorn & Kent does not sell, rent or lease personal data. Data sharing is limited to:

• Internal Sharing: Within our corporate structure, including employees and affiliates.

• Customer Sharing: With our clients (Venues) for purposes related to visitor experience and service delivery

• Legal and Regulatory Compliance: With law enforcement agencies, government authorities or legal entities as required by law or to protect our interests.

We do not pass your personal data to any third parties for the purpose of third-party marketing. If in the future we want to do this, we will ask for your permission if you have not given it already, and will only do so if you have consented.

However, we do need to share your data with the following third parties as an essential part of being able to provide our services to you (in accordance with the purposes set out above). In each case, we will only ever share the minimum amount of information required, and ensure that the relevant third parties are subject to suitable obligations in respect of confidentiality and security:

• Our partners, who provide the systems and products we deliver

• Payment service providers and our delivery companies

• Our professional service providers, such as marketing agencies, advertising partners and website hosts and our professional advisors

• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud

• Companies approved by you, such as social media sites (if you choose to link your accounts to us)

 In addition to the above, we may also need to share your personal data with third parties if we are legally obliged to.

 Do we send your data outside of the EEA?

The European Economic Area or “EEA” is seen as having good standards when it comes to data privacy. Therefore we try to limit the transfer of any data outside of this region. However, from time to time, we do need to do this – for example, our photography partner and their servers are based in the Netherlands. In cases such as this, we make sure that your data is still treated fairly and lawfully in all respects (including making sure we have a legal ground for the transfer and putting in place all necessary safeguards for such arrangement where the third party is not based in a country which is deemed to have “adequate” data protection laws). 

Analytical Information

Image Insight employs standard analytics tools to gather information about user interactions with our services. These tools, such as Google Analytics, utilise cookies to collect data and are subject to their respective privacy policies.

The collected data is employed to enhance our services and inform operational decisions. This information is aggregated and anonymised, preventing the identification of individual users. Such aggregated data may be shared within our corporate structure for legitimate business purposes.

It is important to note that this aggregated data does not compromise individual privacy as it is impossible to extract personally identifiable information from it.

Seeing adverts for Hawthorn & Kent elsewhere on the web

If you have given the appropriate consent, Hawthorn & Kent targets banners and ads to you when you have left our websites and are on other websites and apps. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like pixels, ad tags and cookies, as well as specific services offered by some sites and social networks.

 For more information, please read our Cookies Policy.

 How we keep your data secure?            

 We implement industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorised access or use or loss of your data. We also make sure that when we are required to share your data with third parties, they are subject to suitable confidentiality and security standards.

Despite these measures, the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.

Links to third party websites

 Our websites have links to third party websites. Once you have used these links to leave our websites we have no control over these third-party websites and are not responsible for the protection of any information which you provide whilst visiting these sites. You should exercise caution and examine the privacy policies and terms of use applicable to the web sites in question.

How long do we store your data?

We will store your data for as long as you have an “active” Hawthorn & Kent client status, or as long as is needed to be able to provide the services to you and/or where you are still happy to hear from us about our latest news, products and services.

After this, we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax or other financial reasons (such as being able to deal with chargebacks), where we need to resolve any disputes with you, or where we need to enforce our terms and conditions). In such circumstances, we will only retain the amount of data strictly necessary for these reasons and otherwise, will remove your data from our systems.

Your rights…

You have various rights under GDPR which entitle you, in certain situations, to:

• ask us for a copy of the personal data we hold about you;

• correct or update your personal data, which you can do by contacting us and we can assist;

• request that we delete your personal data;

• object to the handling of your personal data where we are relying on a legitimate interest (as set out in the above table);

• restrict the processing of your personal data;

• request the transfer of your personal data (or some of it) to a third-party service provider; or

• where you have provided your consent for something, in certain circumstances, you may withdraw this consent (but note that we may continue to use your personal data if we have legal grounds for doing so).

And how to exercise them….

 Please Contact Us if you would like to exercise your rights, which you can do for free. The only time we may be allowed to charge a reasonable fee is where your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Otherwise, we will always respond within one month (unless there is a legal reason to take longer).

We may also need to ask you to confirm your identity before we proceed with your request if it is not clear who is making the request.

If you are concerned about the way we are handling your personal data you may also contact the ICO (Information Commissioner’s Office). However, where possible, we would really appreciate the opportunity to help with your concern in the first instance.
 

Changes to this policy

We may change this policy from time to time, to reflect how we are handling your data and will upload these updates onto our websites. If we make significant changes, we will make sure these are notified to you by email or other suitable method so that you are able to review the changes before you continue to use our services.

 How to contact us

If you would like to discuss anything in this policy, want to exercise your rights or have any issues with the way we are handling your data, please:

Email us: info@hawthorn&Kent.com

Write to us at: Hawthorn & Kent Ltd, 39 The Cobalt Building, 1600 Eureka Park, Lower Pemberton, Ashford, Kent TN25 4BF

Last Updated: 5th January 2025

Policy Lead: Sophie Adams