Privacy Policy

Last updated: 4 August 2026

1. Who we are

This website is operated on behalf of Fernclyffe House, Royal Tunbridge Wells, Kent.

Our website address is:

Home

For questions about this privacy policy or the personal information we hold, contact:

enquiries@fernclyffe.com

For the purposes of UK data-protection law, the operators of Fernclyffe House are the data controllers for information processed through the public website and the House Portal.

Where information is processed through the Fernclyffe Investment Capital Limited Company Portal, Fernclyffe Investment Capital Limited is the relevant data controller.

2. Information we collect

Depending upon how you use the website, we may collect:

• Your name, email address and WordPress username.
• Your account role and the private portal areas you are authorised to access.
• Login dates, IP addresses, browser information and security-event records.
• Password-reset requests and related technical information.
• Documents, photographs and other files uploaded by authorised portal administrators.
• Information contained in documents stored within the House Portal or Company Portal.
• Emails and other correspondence sent to enquiries@fernclyffe.com.
• Technical information required to operate, protect and maintain the website.

We do not currently provide public commenting, public registration, advertising or marketing mailing lists.

3. How we use personal information

We use personal information to:

• Operate and maintain the public website.
• Create and manage authorised user accounts.
• Authenticate users and control access to the House and Company portals.
• Store, organise and make private documents available to authorised users.
• Respond to enquiries.
• Detect unauthorised access, misuse, malware and other security threats.
• Maintain backups and recover the website or its documents following a technical problem.
• Meet legal, regulatory, accounting and company-record obligations where applicable.

4. Our lawful bases

Under UK data-protection law, we rely on one or more of the following lawful bases:

Legitimate interests

We have legitimate interests in:

• Operating and securing the website.
• Protecting Fernclyffe House and its associated records.
• Controlling access to private family and company information.
• Responding to legitimate enquiries.
• Maintaining an accurate historical and property archive.

We balance these interests against the rights and reasonable expectations of the people concerned.

Contract

Where access is provided as part of a directorship, shareholding, employment, professional engagement or other agreed relationship, some processing may be necessary to administer that relationship.

Legal obligation

Some company, accounting, tax, property, planning or regulatory records may need to be retained to comply with legal obligations.

Consent

Where we specifically ask for consent, it may be withdrawn at any time by contacting us. Withdrawal does not affect processing that took place before consent was withdrawn.

5. User accounts and private portals

The website includes two restricted areas:

• Fernclyffe House Portal
• Fernclyffe Investment Capital Limited Company Portal

Access is limited according to assigned user roles.

Account administrators can see account details, assign or remove access and administer documents within their authorised area.

Users must keep their login details confidential and should notify us promptly if they believe their account has been accessed without permission.

Portal administrators may upload files including PDF documents, Word documents, spreadsheets and images. These files may contain personal or confidential information. Administrators should only upload information that is appropriate, necessary and lawfully held.

Standard portal users can view documents within the area for which they have permission but cannot upload documents unless they have been given an administrator role.

6. Media and uploaded files

Files uploaded to a private portal may contain metadata, including the name of the person who created the document, dates, device information or location information embedded in photographs.

Before uploading an image, users should remove unnecessary GPS or other sensitive metadata.

Private portal files are intended only for authorised users. They must not be downloaded, copied or disclosed outside the authorised group unless there is a legitimate reason and appropriate permission.

7. Cookies

The website uses cookies that are necessary for WordPress authentication, account security and administration.

When you visit the WordPress login page, WordPress may set a temporary cookie to determine whether your browser accepts cookies. It contains no personal information and is removed when you close your browser.

When you log in, WordPress sets cookies that:

• Keep you signed in.
• Identify your authenticated session.
• Remember administrative display preferences.
• Support account and website security.

Standard WordPress login cookies normally last for two days. Selecting Remember Me may extend the login period to two weeks. Logging out removes the authentication cookies. WordPress also uses cookies for administrative screen preferences.

The website does not currently use advertising cookies or marketing-tracking cookies.

We should review this statement if analytics, embedded maps, social-media feeds, advertising or other third-party services are added. PECR applies to cookies and other technologies that store information on, or access information from, a visitor’s device. Non-essential technologies normally require appropriate information and consent.

8. External links and media

The website contains links to external services, including Google Maps.

Following an external link takes you to another organisation’s website. That organisation may collect information, use cookies or monitor how you interact with its service. Its own privacy policy will apply.

The Fernclyffe directions video is currently hosted directly on this website rather than embedded from a public video-sharing platform.

We are not responsible for the privacy practices of external websites.

9. Who we share information with

We may share information only where necessary with:

• IONOS and other providers that host or maintain the website, database, email or backups.
• WordPress software and approved website-security, backup or administrative service providers.
• Professional advisers, including accountants, solicitors, insurers and property advisers.
• Directors, shareholders, family members or other users who have been authorised to access the relevant private portal.
• Law-enforcement bodies, courts, regulators or public authorities where disclosure is required by law.
• A replacement website or hosting provider where the website is migrated.

We do not sell personal information to advertisers.

When a password reset is requested, the requesting IP address may be included in the password-reset email as a security measure.

10. International transfers

Some technology or support providers may process information outside the United Kingdom.

Where personal information is transferred internationally, we will take reasonable steps to ensure that an appropriate legal safeguard applies, such as a UK adequacy regulation, the UK International Data Transfer Agreement or an approved contractual safeguard.

11. How long we retain information

We retain information only for as long as it is reasonably necessary for the purpose for which it was collected.

Our current retention approach is:

• User accounts: retained while the person requires access and reviewed when their family, company or professional role changes.
• Login and security information: retained for as long as reasonably required to investigate incidents and protect the website.
• House Portal documents: retained while they remain useful for the operation, history, maintenance, ownership or protection of Fernclyffe House.
• Company Portal documents: retained according to their business purpose and any applicable company, accounting, tax or legal retention requirement.
• Enquiry emails: retained while the enquiry is being handled and afterwards only where reasonably necessary.
• Backups: retained according to the website’s current backup cycle and deleted or overwritten when no longer required.

Information may be retained for longer where necessary to establish, exercise or defend legal claims or meet a legal obligation.

12. Security

We use proportionate technical and organisational measures intended to protect the website and private portal information. These include:

• Restricted user accounts and role-based access.
• Password-protected authentication.
• HTTPS encryption.
• Website and database backups.
• Software maintenance and security updates.
• Access restrictions for private portal pages.
• Review and removal of access when it is no longer required.

No online system can be guaranteed to be completely secure. Users should use strong, unique passwords and report suspected unauthorised access immediately.

13. Your data-protection rights

Depending on the circumstances, you may have the right to:

• Be informed about how your information is used.
• Obtain a copy of your personal information.
• Have inaccurate or incomplete information corrected.
• Ask for information to be erased.
• Ask us to restrict how information is used.
• Object to certain processing.
• Receive information in a portable format where the right applies.
• Withdraw consent where processing is based on consent.

These rights are not absolute and legal exceptions may apply. The ICO confirms that the right to erasure, for example, applies only in certain circumstances.

To exercise a right, email:

enquiries@fernclyffe.com

We may need to confirm your identity before completing a request.

14. Complaints

Please contact us first so that we can try to resolve any concern.

You also have the right to complain to the UK supervisory authority:

Information Commissioner’s Office

The ICO’s website provides current contact details and information about making a complaint.

15. Changes to this policy

We may update this policy when the website, private portals, service providers or legal requirements change.

The latest version will always be published on this page with its revision date.

COOKIES

Cookies and similar technologies

Fernclyffe.com uses cookies and similar browser technologies to operate the website, protect user accounts and provide access to the private House and Company portals.

Cookies are small text files stored on your computer, phone or other device when you visit a website.

Strictly necessary cookies

The website uses strictly necessary cookies for purposes including:

• Checking whether your browser accepts cookies.
• Keeping authorised users signed in.
• Authenticating access to the House Portal and Company Portal.
• Protecting user accounts and private documents.
• Remembering WordPress administration and display preferences.
• Supporting the secure operation of the website.

These cookies are required for the website and private portals to function correctly. They cannot normally be disabled through the website itself.

WordPress login cookies generally remain active for up to two days. If a user selects Remember Me, the login may remain active for up to fourteen days. Logging out removes the authentication cookies. WordPress may also retain administration display preferences for longer periods.

Because these cookies are necessary to provide login, authentication and security functions requested by the user, prior consent is not normally required. Visitors must still be given clear information about their use.

Non-essential cookies

Fernclyffe.com does not currently use cookies for:

• Advertising.
• Behavioural marketing.
• Public comment tracking.
• Social-media profiling.
• Third-party audience analytics.

The directions video is hosted directly by Fernclyffe.com. The Google Maps feature is provided as an external link rather than an embedded map, so Google does not set cookies merely because a visitor opens the Directions page.

If analytics, embedded maps, YouTube videos, social-media feeds, advertising or other non-essential services are introduced in future, this policy will be updated. Where required, those technologies will not be activated until the visitor has made an appropriate cookie choice. The ICO states that non-essential storage or access technologies normally require valid consent.

Managing cookies

You can use your browser settings to block or delete cookies. Blocking strictly necessary cookies may prevent you from signing in or using the private portals.

Browser controls vary, so please consult the help information supplied with your browser.

Changes to our use of cookies

We periodically review the cookies and similar technologies used by the website. This section will be updated if the website introduces new functionality or third-party services.