Privacy Policy

1. Who we are

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is the Charles Tunnicliffe Estate (the “Estate”). Contact details for privacy enquiries will be published here once confirmed.

2. What information we collect

Depending on how you contact us, we may process:

• identity and contact details (such as name, organisation, email address and postal address);
• details of your enquiry, including works referenced and the proposed use;
• correspondence and records needed to administer a licensing request; and
• technical information such as IP address and basic server logs where necessary for security and site operation.

We do not currently operate a public online enquiry form. Until that changes, personal data is typically received by email or other direct correspondence.

3. Why we use personal information

We use personal information to:

• respond to enquiries and administer licensing and reproduction requests;
• keep records required for rights administration and accountability;
• protect the security and integrity of our systems; and
• comply with legal obligations.

4. Lawful bases

Depending on the circumstances, we rely on one or more of the following lawful bases under UK GDPR:

• Contract — where processing is necessary to take steps at your request before entering into a contract, or to perform a contract with you;
• Legitimate interests — including administering copyright and responding to professional enquiries, balanced against your rights and freedoms;
• Legal obligation — where we must retain or disclose information to meet a legal requirement; and
• Consent — where we specifically ask for it (for example, optional communications), which you may withdraw at any time.

5. Sharing information

We do not sell personal information. We may share information with:

• family members or advisers involved in Estate decision-making, where necessary;
• professional advisers (such as legal or accounting advisers);
• service providers who host or support our systems under appropriate agreements; and
• authorities where required by law.

6. International transfers

If personal data is transferred outside the UK, we will ensure appropriate safeguards are in place as required by UK data protection law.

7. Retention

We keep personal information only for as long as needed for the purposes set out above, including legal, accounting and rights-administration requirements. Specific retention periods will be documented once operational policy is approved.

8. Your rights

Under UK GDPR you may have the right to access, rectify, erase, restrict or object to certain processing, and the right to data portability, where applicable. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.

9. Cookies

See our Cookie Policy for information about cookies and similar technologies used on this website.

10. Changes

We may update this notice from time to time. The version published on this website is the current version.

Last updated: August 2026 (draft template).