Privacy Policy for Visitor Contact Tracking

Please note, this Privacy Policy relates to information collected when using our Visitor Tracking system to register a visit to a venue. This is separate to the information collected when using our website (see Website Privacy Policy).

Who we are

Our website address is:

freedom20 is a trading name of Jeremy Place Ltd, The Maltings, Locks Hill, Rochford. SS4 1BB

What personal information we collect and why we collect it


To meet the UK Government advice on maintaining records of customers and visitors to support NHS Test and Trace we collect the following personal information in relation to a visit to a venue:

  • The name of the customer or visitor. If the visit comprises a group of people, we record the name of the ‘lead member’ of the group.
  • A contact number for each customer or visitor, or for the lead member of a group of people.
  • The number of people in the group.
  • The name of the venue.
  • The date and time of arrival at the venue.

Technical Information

When you register a visit to a venue, the system will also record the Internet (IP) address of your device used to register the visit.

Who we share your information with

Your information will be shared with your local NHS Test and Trace Service (Test and Trace in England; Test and Protect in Scotland; Test, Trace, Protect in Wales) if there is a need, and only where it is necessary. This will be either:

  • When somebody who has tested positive for COVID-19 has listed the venue that you have visited as a place that they have visited recently. Or,
  • Because the venue has been identified as the location of a potential local outbreak of COVID-19

Your information will also be processed by our SMS Service Provider Esendex (Privacy Statement) to provide you with the confirmation SMS Message. Esendex have a zero-hour retention policy so once the message is sent it is not retained on their systems.

How long we retain your information

To support NHS Test and Trace, we hold records for 21 days. This reflects the incubation period for COVID-19 (which can be up to 14 days) and an additional 7 days to allow time for testing and tracing. After 21 days, this information is securely deleted

Where we hold your information

All of your personal information is stored within the UK and is not transferred to any other territory.


We process your personal information in a manner that ensures appropriate security of the data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

What rights you have over your information

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

  • Right of access: You have the right to obtain from us a copy of the personal information that we hold for you.
  • Right to rectification: You can require us to correct errors in the personal information that we process for you if it is inaccurate, incomplete or out of date.
  • Right to be forgotten: You also have the right at any time to require that we delete the personal information that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal information in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal information

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.

To exercise your rights under the terms of this Privacy Policy, please contact the Data Protection Officer: Jeremy Place 0800 009 6587.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal information, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time.  You  also have the right to contact the Information Commissioner, see

This Privacy Policy was last updated on 24 August 2020.  You may contact us if you wish to review any previous version.

©2020 freedom20


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