Privacy Policy

1. Introduction

Aberfoss Limited, including its subsidiary businesses Hunt Bespoke Kitchens and Interiors Limited and Beechwood Frames Limited, (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below. We generally use the lawful bases of contractual obligation or legitimate interest to process data.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Credit Reference Agencies or Companies House).

Where we receive personal data that relates to an individual from a third party, we either request that this third party inform the individual of the necessary information regarding the use of their data, or inform the individual beforehand that we are obtaining third party information. Where necessary, reference may be made to this privacy statement.

2. Security

We take the security of all the data we hold seriously. Staff that handle personal data are trained on data protection, confidentiality and security.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

Information you provide to us is stored on secure servers, which are generally locally hosted (see section 6). We may also store hard copies of your personal information, and where we do, we ensure that this information is kept in a secure location within our buildings.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3. Data that we hold

3.1 Commercial Services

We provide services to individuals as well as businesses. The exact data held will depend on the services to be provided.

Where we engage with individuals, we may collect and process personal data in order to satisfy a contractual obligation. We request that individuals only provide the personal data that is required for us to fulfil our contractual obligation.

Where we are legally permitted to do so, we notify companies we work with if we receive a request for a data subject to exercise their rights under GDPR, or if we are served with information from a supervisory authority.

3.1.1 Why do we process data?

Where data is collected for commercial services, it is used for a number of purposes, as follows. Our subsidiary companies have detailed policies outlining their specific processing arrangements, and these policies are available on the companies’ websites or on request using the contact details at section 9 below:

  • Providing services to our clients. Data is processed in order to provide the service detailed in contract between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur.
  • Client management. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the right collection of services is being provided to our clients.
  • Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, administering relationships with third-party service providers, and maintaining internal operating processes.
  • Regulatory. In order to undertake our commercial services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include the verification of identity of individuals.

3.1.2 What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service. We will collect data from the following categories:

  • Name (including title)
  • Home address
  • Phone number
  • Date of birth
  • Email address
  • The date and time you used our services
  • The pages you visited on our website and how long you visited us for
  • Your IP address
  • The internet browser and devices you are using
  • Cookie, Pixels or Beacon information (for more information please see our Cookie Policy)
  • The website address from which you accessed our website
  • Details of any transactions between you and us
  • Voice recordings of calls you make to our customer service centre (for more information please see our Call Recording Policy)
  • Any information within correspondence you send to us

When you engage with us in a business context, we may also collect

  • Your job title
  • Company contact details (including email addresses)
  • Company details

3.1.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may also keep data for longer in order to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it. We will periodically review this data, to ensure that it is still relevant and necessary.

Our subsidiary companies have detailed policies outlining their specific data retention arrangements, and these policies are available on the companies’ websites or on request using the contact details at section 9 below

3.2 Our people

We collect personal data for our people as part of the administration, management and promotion of our business activities.

Our staff handbook explains further how personal data is held for our staff.

3.2.1 What data to we hold?

Where an individual applies to work for Aberfoss Limited or one of its subsidiaries, personal data is collected through the application process. We collect information including name, contact details, NI number and passport information, medical information, next of kin details, and biometric information for security passes.

There are a number of purposes this personal data.

  • Employment. We process an applicant’s personal data in order to assess their potential employment at Aberfoss Limited or one of its subsidiaries.
  • Administration and management. We may also use this personal data in order to make informed management decisions and for administration purposes.

3.2.2 How long do we hold data for?

Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of six months where those purposes no longer become necessary. Personal information about employees is held for the duration of their employment and for a period of up to six years after their employment ceases. Personal data is minimized on termination of employment to only include data that may be needed for the necessary purposes such as providing references, analysis of employment statistics, and responding to any employment tribunal claims.

3.3 Suppliers

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide services to our clients.

3.3.1 Why do we process data?

  • Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
  • Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
  • Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:

- managing our relationship with suppliers;

- developing our businesses and services (such as identifying client needs and improvements in service delivery);

- maintaining and using IT systems;

- administering and managing our website, systems and applications.

  • Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.
  • Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations.  We need to keep certain records to show we comply with those obligations and those records may contain personal data.

3.3.2 What data do we hold?

We will hold names, contacts’ names, and contact details of suppliers, as well as transactional information.

3.3.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

3.4 People Who Visit Our Showrooms, Workshops and Offices

Personal data is collected when individuals visit our Showrooms and Offices via CCTV. We have security in place at our offices, for the physical security of client information and for the benefit of our staff.

Signs confirm that CCTV is in operation. The images are held securely and only accessed when needed when investigating an incident.

In order to hold and process the visitor details on CCTV, we believe it is a legitimate business interest that visitors’ data are captured and controlled in this way.

3.4.1 Why do we process data?

CCTV and building access controls may require customers to our showrooms and offices to sign in and keep a record of visitors. This is retained in case of theft or other incident and to protect the staff and information in the office.

3.4.2 What data do we hold?

Personal data that may be stored on CCTV will be footage of those visiting our sites. Our visitor book may include name, business, times and car registration.

3.4.3 How long do we hold data for?

Visitor records are accessed on a need to know basis only. CCTV recordings are typically overwritten after a short period of time unless an issue requiring investigation is brought to our attention.

4. People who use our website

When people visit our websites, personal data is collected both through automated tracking and interactions with various forms on the website or apps (collectively referred to as the websites).

Personal data may also be collected when individuals correspond with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribes to our services, makes an enquiry, enters a competition, promotion or survey, applies to work for an Aberfoss business or reports a problem with our websites.

When individuals visit our websites, certain personal data may be automatically collected. We work closely with third parties who may collect data on our behalf (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current customers, business contacts or become customers in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose detailed in section 3.1.

If you continue to browse and use this website, you are agreeing to comply with, and be bound by the following terms and conditions of use, which together with our privacy policy govern Aberfoss Limited and its subsidiaries with you in relation to this website. If you disagree with any part of these terms and conditions, Splease exit our website.

This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice which forms part of these terms and conditions.

4.1.1 Why do we process data?

There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include:

  • Administration. To administer our sites and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that a website is presented well for individuals and is optimised appropriately.
  • Functionality. In order to allow individuals to use some functionality of our websites, certain personal data must be entered in order for features to work as intended.
  • Security. In order to keep our sites safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
  • Promotion and development of our offerings. Some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.

4.1.2 What data do we hold?

The data that we hold depends on what data was entered and for what purpose.

Where data was entered in order to engage with functionality of our website, that personal data may include their name, address, email address and phone number, financial and credit card information.

Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

4.1.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

5. Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards. More detailed information about specific third parties is available in published privacy statements for our subsidiary businesses.

Personal data held by us may be transferred to:

  • Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.
  • Third party organisations that otherwise assist us in providing goods, services or information
  • Other businesses within Aberfoss Limited, its subsidiary businesses and their franchise operations
  • Law enforcement or regulatory agencies or those required by law or regulations

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

6. Locations of processing

Where possible the personal data we hold resides within the EU but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. The servers powering and facilitating our cloud infrastructure are generally located in secure data centres within the European Economic Area, and personal data may be stored in any one of them. We do use email marketing software supported and hosted in the United States. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully.  Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

7. Individual’s Rights

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

  • Individuals may request access to their personal data held by us as a data controller.
  • Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
  • Individuals may request that we erase their personal data
  • Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.  
  • Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.  
  • Individuals may request information about, or human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please send an email to mail@huntbespokekitchens.com  

8. Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to mail@huntbespokekitchens.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner's Office (ICO). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

9. Data Controller and contact information

The data controller for Aberfoss Limited and its subsidiary businesses is Aberfoss Limited.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection, Aberfoss Limited, care of Hunt Bespoke Kitchens and Interiors Limited, High Street, Bloxham, Oxfordshire, OX15 4LT

10. Changes to our privacy statement

Updates to this privacy statement will appear on this website.  This privacy statement was last updated on 12th April 2023