Privacy Policy

Park Home & Holiday Park Association (PHHPA)

The Park Home & Holiday Park Association, known as PHHPA, is operated by Ninja Business Limited, company number 16471587.

This Privacy Policy explains how we collect, use, store and protect personal information when individuals and organisations interact with PHHPA, including through www.phhpa.org, PHHPA Park Standards, Approved Park applications, training, Managed Park Support, park acquisition enquiries, investment and capital-partner enquiries, consultancy and other PHHPA services.

We process personal information in accordance with applicable UK data-protection legislation, including the UK General Data Protection Regulation, the Data Protection Act 2018 and the Data (Use and Access) Act 2025.

1. Who Is Responsible for Your Data

Ninja Business Limited is the legal entity responsible for the operation and administration of PHHPA and is generally the data controller for personal information collected through PHHPA.

Our contact details are provided at the end of this policy.

Where another organisation independently determines how and why personal information is processed, that organisation may act as a separate data controller and will be responsible for its own privacy obligations.

2. Information We May Collect

Depending upon how you interact with PHHPA, we may collect information including your name, telephone number, email address, postal address, business details, job title and professional contact information.

Where you apply for PHHPA Approved Park Status or Managed Park Support, we may collect information relating to the park, its ownership and management, operating procedures, staff, documentation, customer processes, commercial activities and other information reasonably necessary to assess or deliver the service.

Where you contact us regarding the sale, acquisition, development or investment in a park, information may include details relating to ownership, shareholders or directors, property interests, transaction history, financial or commercial information, investment preferences and information required for appropriate due diligence.

We may also collect payment and invoicing records, correspondence, meeting notes, application information, website usage data, IP addresses, device and browser information, marketing preferences and records of interactions with PHHPA.

We do not normally seek special-category personal information unless there is a legitimate and lawful reason to do so.

Full payment-card details are not stored by PHHPA where payments are processed through an independent payment provider.

3. Where We Obtain Information

Most personal information is provided directly by you when you contact us, submit an application, complete a form, purchase a service, attend training, enter discussions with us or otherwise communicate with PHHPA.

We may also receive information from professional advisers, park owners, investors, business partners, transaction counterparties, referrals or publicly available business and professional sources.

Where personal information is obtained from another source, UK data-protection law requires appropriate privacy information to be provided within the applicable timescale.

4. How We Use Personal Information

We may process personal information to respond to enquiries, provide services, administer training, assess applications for PHHPA Approved Park Status, conduct Park Standards reviews and deliver Managed Park Support.

We may also use information to assess park acquisition, development, sale, management or partnership opportunities; undertake appropriate commercial and transaction due diligence; communicate with relevant professional advisers and capital partners; manage contractual relationships; issue invoices and process payments; maintain business records; protect the PHHPA brand; prevent fraud; improve our websites and services; and comply with legal obligations.

Where appropriate, PHHPA may also use professional contact information to communicate relevant industry, commercial or PHHPA information.

5. Our Lawful Bases

The lawful basis we use depends upon the particular activity.

We may process personal information because it is necessary to perform a contract with you or to take steps requested by you before entering into a contract.

We may rely upon our legitimate interests where processing is reasonably necessary to operate PHHPA, assess commercial opportunities, manage relationships, protect our business, communicate with professional contacts or improve our services, provided those interests do not override an individual’s rights and freedoms.

We may process information where necessary to comply with a legal obligation.

Where consent is the appropriate basis, including for certain marketing activities, you may withdraw that consent at any time.

The ICO requires organisations to identify their processing purposes and corresponding lawful bases clearly within their privacy information.

6. Approved Parks and PHHPA Standards

Where a park applies for or holds PHHPA Approved Park Status, we may process personal information relating to owners, directors, management personnel and other individuals involved in the operation of the park.

Information may be used to assess compliance with PHHPA Park Standards, undertake reviews, investigate concerns or complaints and administer the approved relationship.

Where a park receives Approved Park Status, the park’s business name, location, approval status and other appropriate business information may be publicly identified by PHHPA.

We will not intentionally publish private personal information unless there is a lawful reason or appropriate permission to do so.

7. Acquisitions, Investments and Commercial Transactions

PHHPA may process personal information in connection with proposed park acquisitions, disposals, investments, developments, joint ventures, management arrangements and other commercial transactions.

Information may be shared with relevant solicitors, accountants, surveyors, lenders, investors, family offices, private-equity or venture-capital relationships, professional advisers and other transaction participants where reasonably necessary to evaluate or progress an opportunity.

Where appropriate, information will be shared subject to confidentiality arrangements and only to the extent reasonably required for the proposed transaction.

Submission of an opportunity to PHHPA does not mean personal or commercial information will automatically be circulated to third parties.

8. Marketing and Communications

We may send information about PHHPA services, events, industry developments or opportunities where we have a lawful basis to do so.

Where consent is required, we will request it.

Where UK law permits business-to-business communications on another lawful basis, we may rely upon legitimate interests subject to the individual’s rights and applicable electronic-marketing rules.

You may unsubscribe from marketing communications at any time.

We do not sell or rent personal information to third parties for their unrelated marketing purposes.

9. Who We May Share Information With

Where necessary, information may be shared with payment providers; website, cloud, CRM and technology providers; accountants, solicitors and other professional advisers; insurers; consultants and contractors working with PHHPA; prospective transaction or capital partners; funding providers; government, regulatory or law-enforcement bodies where legally required; and other organisations where disclosure is reasonably necessary for a legitimate transaction or service.

Service providers acting on our behalf are expected to process information appropriately and securely.

10. International Data Transfers

Some technology, cloud, CRM, communications or service providers may process information outside the United Kingdom.

Where personal information is transferred internationally, we will take reasonable steps to ensure that an appropriate lawful transfer mechanism or recognised safeguard applies.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, accounting, contractual, tax, insurance or dispute-resolution requirements.

Different records may therefore be retained for different periods.

Commercial, contractual and transaction records may be retained after a relationship ends where reasonably necessary to establish, exercise or defend legal rights.

Accounting and payment records will be retained for the periods required under applicable law.

ICO guidance requires organisations either to state retention periods or explain the criteria they use to determine them.

12. Data Security

We use appropriate technical and organisational measures designed to protect personal information against accidental loss, unauthorised access, alteration, disclosure or misuse.

Access to information is restricted where appropriate to individuals and service providers who require it for legitimate business purposes.

No internet-based system can provide an absolute guarantee of security, but we take reasonable measures proportionate to the information being processed.

13. Automated Systems and AI

PHHPA may use technology, automation, CRM systems and artificial intelligence to support administrative activities, communications, analysis and business processes.

We do not intend to make decisions producing legal or similarly significant effects upon individuals solely through automated processing without the safeguards required by law.

Where the use of automated decision-making requires specific disclosure under data-protection law, appropriate information will be provided.

14. Your Data-Protection Rights

Depending upon the circumstances and lawful basis involved, you may have rights to access your personal information, correct inaccurate information, request erasure, restrict certain processing, object to processing, receive certain information in a portable format and withdraw consent where consent is relied upon.

You have the right to object to processing in circumstances provided by data-protection law, including the right to object to direct marketing.

The exact rights available may depend upon why and how the information is being processed. The ICO specifically requires privacy notices to explain available rights and to bring the right to object clearly to people’s attention.

15. Data-Protection Complaints

If you have concerns about how PHHPA uses your personal information, please contact us first so that we can investigate.

Under the Data (Use and Access) Act 2025 requirements now in force, organisations must provide an appropriate route for data-protection complaints, acknowledge a complaint within 30 days and communicate the outcome without undue delay.

You also have the right to raise a complaint with the UK’s data-protection regulator, the Information Commissioner’s Office / Information Commission, where appropriate.

16. Cookies and Website Analytics

PHHPA websites may use cookies and similar technologies for security, functionality, analytics, performance and, where applicable, marketing.

Where consent is legally required for a particular cookie or technology, it will be requested through our cookie-management system.

Further information should be provided within the PHHPA Cookie Policy or cookie settings.

17. Links and Third-Party Services

Our website may contain links to websites or services operated by third parties.

PHHPA is not responsible for the privacy practices of independent third-party websites, and visitors should review the relevant privacy information before providing personal information to them.

18. Changes to This Privacy Policy

We may update this Privacy Policy where our services, technology, commercial activities or legal obligations change.

The current version will be published on the PHHPA website.

Where we introduce a materially different use of existing personal information, we will provide appropriate information before beginning that processing where required by law.

Contact

Park Home & Holiday Park Association (PHHPA)
Operated by Ninja Business Limited
Company Number: 16471587

33 Robjohns Road
Chelmsford
Essex
CM1 3AG

Website: www.phhpa.org
Email: brad@phhpa.org

For privacy requests or data-protection complaints, contact PHHPA using the details above.