Privacy & Cookie Policy

How we collect, use, and protect your personal information

This privacy and cookie policy explains how Old Town Newbury ("we", "us", "our") collects, uses, and protects your personal information when you visit our website at oldtownnewbury.com (the "Site"). We are committed to ensuring that your privacy is protected.

1. Information We Collect

We may collect the following information:

Information you provide to us

  • Name, email address, phone number, and postcode when you register for an account
  • Information submitted through our contact form or other forms on the Site
  • Any correspondence you send to us

Information collected automatically

  • IP address, browser type, operating system, and device information
  • Pages visited, time spent on pages, and navigation paths
  • Referring website addresses

2. How We Use Your Information

We use the information we collect for the following purposes:

  • To provide access to the Data Room and other restricted areas of the Site
  • To respond to your enquiries and correspondence
  • To send you updates about the Old Town Newbury development, where you have opted in to receive these
  • To improve the Site and understand how visitors use it
  • To comply with legal obligations

3. Legal Basis for Processing

Under the UK General Data Protection Regulation (UK GDPR), we process your personal data on the following bases:

  • Consent — where you have given clear consent for us to process your personal data for a specific purpose, such as registering for an account or subscribing to updates
  • Legitimate interests — where processing is necessary for our legitimate interests, such as improving the Site and understanding how it is used, provided these interests do not override your rights
  • Legal obligation — where we need to process your data to comply with the law

4. Data Sharing

We do not sell, trade, or rent your personal information to third parties. We may share your information with:

  • Service providers who assist in operating the Site (e.g. hosting, email, analytics), under appropriate data processing agreements
  • Professional advisers and consultants involved in the Old Town Newbury development
  • Law enforcement or regulatory bodies where required by law

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Account data is retained for as long as your account remains active. If you request deletion of your account, we will remove your personal data within 30 days, except where we are required to retain it for legal or regulatory purposes.

6. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

  • Right of access — you can request a copy of the personal data we hold about you
  • Right to rectification — you can ask us to correct inaccurate or incomplete data
  • Right to erasure — you can request deletion of your personal data
  • Right to restrict processing — you can ask us to limit how we use your data
  • Right to data portability — you can request your data in a structured, machine-readable format
  • Right to object — you can object to processing based on legitimate interests
  • Right to withdraw consent — where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, please contact us using the details in Section 10 below. We will respond to your request within one month.

7. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encrypted connections (HTTPS), secure password storage, and access controls limiting who can view your information.

8. Cookies

Cookies are small text files placed on your device when you visit a website. We use cookies to ensure the Site functions correctly and to understand how visitors interact with it.

Essential Cookies

These cookies are necessary for the Site to function and cannot be switched off. They include:

  • payload-token — Keeps you signed in to your account. Expires when you log out or after 2 hours of inactivity.
  • Session cookies — Maintain your browsing session as you navigate between pages.

Analytics Cookies

We use PostHog to collect anonymous usage data to help us understand how visitors use the Site and to improve the user experience. PostHog cookies include:

  • ph_phc_* — A unique identifier used to track anonymous usage patterns across sessions.

Analytics data is collected on a self-hosted instance and is not shared with third parties.

Third-Party Cookies

If you sign in using Google or Facebook, those services may set their own cookies in accordance with their respective privacy policies. We do not control these cookies.

Managing Cookies

You can control and delete cookies through your browser settings. Please note that disabling essential cookies may prevent you from using certain features of the Site, such as signing in to your account.

9. Changes to This Policy

We may update this policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

This policy was last updated on 11 March 2026.

10. Contact Us

If you have any questions about this privacy and cookie policy, or wish to exercise your data protection rights, please contact us:

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk if you believe your data protection rights have not been respected.