Privacy Policy

Last updated: 31 July 2026

1. Who We Are

Mr G Collins & Mrs A Collins, trading as Upper Farm Henton (“we”, “us” or “our”), Upper Farm, Henton, Chinnor, Oxfordshire, OX39 4AQ, is the Data Controller responsible for your personal data.

We are committed to protecting your privacy and handling your personal data responsibly, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

If you have any questions about this policy or how we handle your data, please contact us:

By post: Upper Farm, Henton, Chinnor, Oxfordshire, OX39 4AQ
By email: privacy@upperfarmhenton.co.uk

2. What Personal Data We Collect

Depending on how you interact with us, we may collect and hold the following categories of personal data:

Contact and Identity Information

Name and title
Postal address
Email address
Telephone number

Booking and Transaction Information

Details of products or services purchased (holiday lets, fishing sessions, equestrian services)
Booking dates and duration of stay
Number of guests in your party
Special requests or requirements
Correspondence relating to your booking or query

Financial Information

Payment records (amounts paid, dates)

Please note: we do not store credit or debit card details. Card payments are processed directly and securely by our payments provider.

Marketing and Communications

Email newsletter subscription status
Marketing communication preferences

Website Usage Data

Pages visited, time spent on site, referring URL
Cookie identifiers and IP address

See Section 9 for more information about cookies.

User-Generated Content & Public Submissions

Catch Reports: Customer name, details of the catch (e.g., weight, species, date), and any photographs you submit to us.
Guest Reviews: Guest name, your written review, and any voluntary guest or accommodation photographs you choose to share with us.

3. CCTV and Audio Recording

Upper Farm Henton operates CCTV cameras at various locations around the farm, including the main entrance, vehicle approaches, the tackle shop exterior, fishery and the equestrian stables. These operate 24 hours a day and record continuously.

Audio recording operates at the farm entrance, vehicle approach and on all exterior cameras. The equestrian's internal stable cameras record video only, with no audio recording.

We record images and audio for the following purposes:

The prevention and detection of crime, and the protection of visitors, staff, animals and property
Detection of safety-related alarms and events, including fire, smoke, glass-break and other emergency signals, via our external audio-enabled cameras
Traffic safety and incident review on vehicle approaches to the property

Our lawful basis for this processing is legitimate interests — specifically, the safety and security purposes described above. We do not rely on consent for CCTV or audio recording, since visiting or passing through the property does not constitute valid consent to recording under data protection law; instead, we rely on our legitimate interest in protecting people, animals and property, balanced against the privacy of those recorded.

Recordings are retained on a rolling basis until storage capacity is reached, at which point the oldest recordings are automatically overwritten. In practice, this currently provides approximately 60 days of history, after which footage is no longer available, unless a specific recording has been retained for longer because it is needed as evidence of an incident, crime, or legal claim.

CCTV and audio recordings may be shared with:

The police and other law enforcement bodies, where relevant to the prevention or investigation of crime
Insurers and legal advisers, where necessary to support or defend a claim
Livery clients of the equestrian, who are given ongoing live-view-only access to the specific internal camera(s) covering their own horse's stable, for the purpose of animal welfare monitoring. Clients cannot access recorded history, and access is technically restricted so that each client can only view the camera(s) covering their own horse. This access is subject to terms restricting further use or sharing of anything visible on the feed, including other people.

Upper Farm Henton owns and administers the CCTV and audio recording system described in this section, and is the data controller for all cameras within it, including those covering areas occupied by Trinity (Oxfordshire) Limited (tackle shop) and Bethan-May Equestrian (stables). Where recordings cover their own staff and customers, Trinity (Oxfordshire) Limited and Bethan-May Equestrian act as joint controllers alongside Upper Farm Henton, and the parties have agreed in writing how their respective responsibilities — including informing staff, handling access requests, and retention — are divided. Enquiries about recording from a specific area can be directed to Upper Farm Henton in the first instance, or to the relevant business for matters specific to their staff or premises.

Your rights in relation to CCTV and audio recordings — including the right to request a copy of footage in which you appear — are the same as set out in the "Your Rights" section of this policy below, and can be exercised by contacting us at privacy@upperfarmhenton.co.uk.

4. How and Why We Use Your Personal Data

We process your personal data under the following lawful bases:

a) Contract Performance

To fulfil bookings, reservations, and service agreements — including processing payments, confirming reservations, and managing your stay or session. Without this data we cannot provide the services you have booked.

b) Legal Obligation

To comply with our legal obligations, including HMRC record-keeping requirements and VAT obligations.

c) Legitimate Interests

We process some data on the basis of our legitimate business interests, where those interests are not overridden by your rights. This includes:

Customer service and handling queries
Fraud prevention and security
Improving our services based on customer feedback
Retaining records in case of legal disputes during the applicable limitation period

d) Consent

We rely on your explicit, freely given consent to publish specific user-generated content on our public website. You provide this consent when you voluntarily submit content to us via our online submission forms.

Catch Reports: We process and publicly display your name, the details of your catch, and any accompanying photographs to showcase angling success and monitor fishery trends.
Guest Reviews: We process and publicly display your first name, the first letter of your surname, your written review text, and any voluntary accommodation or estate photographs you choose to share to help prospective guests.

Withdrawing your consent: Because this processing is based entirely on your consent, you have the absolute right to change your mind. If you want a catch report or a review removed from our website, simply email privacy@upperfarmhenton.co.uk with a link or description of the post, and we will take it down promptly (normally within 72 hours).

5. How Long We Keep Your Data

We will not keep your personal data for longer than is necessary for the purposes for which it was collected. Our standard retention periods are:

Booking and financial records: 6 years from the date of the transaction or stay, in line with HMRC record-keeping requirements and the Limitation Act 1980.
General enquiry correspondence (where no booking was made): 2 years from the date of last contact.
Marketing data (where consent was given): until you withdraw your consent or we determine the data is no longer current, with a review no less than every 3 years.
Website analytics and cookie data: in line with the retention periods set by our analytics provider (typically 13–26 months).

After the applicable retention period, your data will be securely deleted or anonymised.

6. Who We Share Your Data With

We do not sell your personal data. We may share it with the following categories of third parties, only where necessary and always under confidentiality obligations:

Payment processors: to securely process card transactions.
Booking and property management systems: to manage reservations (e.g. Eviivo Suite, Wix, iBookfishing).
Email marketing providers: to send newsletters and communications to subscribers.
IT and website service providers: to maintain and operate our website and systems.
Feedback and review platforms: to invite customers to leave reviews.
Legal and professional advisers: where necessary to defend or pursue legal claims.
Regulatory authorities, law enforcement, or the courts: where we are required to do so by law.

If we sell or transfer part or all of our business, your data may be transferred to the prospective buyer under appropriate confidentiality terms.

7. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details in Section 1.

Right of Access

You may request a copy of the personal data we hold about you (a “Subject Access Request”). We will respond within one month. There is no charge for this.

Right to Rectification

If any data we hold about you is inaccurate or incomplete, you have the right to ask us to correct it.

Right to Erasure (“Right to Be Forgotten”)

You may ask us to delete your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw your consent. Please note that we may be required to retain certain data for legal or financial compliance purposes (see Section 4), in which case we will inform you.

Right to Restrict Processing

In certain circumstances, you may ask us to limit how we use your data (for example, while a complaint is being investigated).

Right to Data Portability

Where processing is based on your consent or a contract and is carried out by automated means, you may request a copy of your data in a commonly used, machine-readable format.

Right to Object

You have the right to object to processing based on our legitimate interests, and to the use of your data for direct marketing (including profiling for marketing purposes). We will stop processing your data for marketing purposes immediately on receipt of such a request.

Opting Out of Marketing

You may unsubscribe from email marketing at any time by:

Clicking the “Unsubscribe” link at the bottom of any marketing email
Emailing us at privacy@upperfarmhenton.co.uk
Writing to us at the address in Section 1

Right to Complain

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the UK’s data protection regulator:

Information Commissioner’s Office (ICO)

Website: www.ico.org.uk
Helpline: 0303 123 1113
Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would, however, welcome the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

8. Data Storage and Security

Your personal data is stored on secure systems managed by us or on our behalf by reputable service providers. We implement appropriate technical and organisational security measures including:

Username and password authentication with two-factor authentication where available
Data encryption in transit and at rest where appropriate
Access controls limiting who can view your data

Please be aware that no method of internet transmission is completely secure. Whilst we take all reasonable steps to protect your data, we cannot guarantee absolute security of data transmitted to our website.

9. Cookies

Our website (www.upperfarmhenton.co.uk) uses cookies — small text files stored on your device — to help the site function and to understand how it is used.

Types of cookies we use:

Essential cookies: required for the website to function correctly.
Analytics cookies: help us understand how visitors use our site so we can improve it. This information is aggregated and anonymous.
Marketing cookies: used to deliver relevant advertisements and track the effectiveness of marketing campaigns.

When you first visit our website, you will be asked to consent to non-essential cookies via our cookie banner. You may withdraw or change your consent at any time via the cookie settings link on our website.

You can also control cookies through your browser settings. For more information, visit www.allaboutcookies.org.

10. Third-Party Websites

Our website contains links to third-party websites. We are not responsible for the privacy practices of those sites and we encourage you to read their privacy policies before submitting any personal data to them.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any significant changes will be communicated via our website. The date at the top of this document indicates when it was last updated.

Upper Farm Henton • Upper Farm, Henton, Chinnor, Oxfordshire, OX39 4AQ • privacy@upperfarmhenton.co.uk