While we don’t really like the idea of collecting your data, it is unavoidable and inevitable in the modern world. We collect data principally when we take bookings and use it to contact customers about those bookings if we need to. We can also use it to contact you about what’s going on in our pubs, but only if you want us to, of course. We do this in line with legal guidance and in compliance with GDPR.
We treat your privacy as we’d like others to treat our own; any of your details we record, or are given, are kept safely and securely such that they can’t be used by any third parties. We will never sell or rent out customer information to anybody, it will only ever be used by us.
We have set out further details of how we store and use your data below. As we grow we might need to change or update elements of this policy, which we reserve the right to do without notice, so if you are concerned please revisit this page from time to time. If you want to contact us about anything you see here or feel we are not abiding by this policy, please send us an email to firstname.lastname@example.org.
Pubs Limited is a family-owned company based in the North West of England. We have four pubs, a couple of holiday cottages and our head office is located at our registered address:
Registered Company Number: 02671691
ICO Registration Number: ZA646197
When Personal Information May Be Collected
Most of the information collected comes from when you make a booking with us, use our websites or contact us directly. However the full list includes:
Data you give to us:
- When you speak to members of staff in the pubs;
- When you sign up to one of our newsletters or any other marketing;
- When you take part in any special offers;
- When you apply for a job with us;
- When you fill in any forms or give us feedback;
- When you contact us directly;
- When you use our websites;
- When you make a booking with us, whether it’s for a table or a stay in one of our cottages;
- When you order food, drink or stays in our accommodation and when you pay for those things (transaction data).
Data from third parties:
- Social media networks, like Instagram and Facebook;
- Agents working on our behalf, such as accommodation booking platforms or recruitment agents;
- Google analytics (which collects information about how visitors use our websites and online profiles);
- Public information sources.
What Personal Data Could Be Collected?
We only collect data that we need to facilitate your booking, payment or voluntary participation in marketing. We may collect, use, store and transfer different kinds of personal data about you, including:
- Identity data– e.g. name, title, date of birth.
- Contact data– e.g. phone number, email address, location, postcode, email address or telephone numbers.
- Transaction data – details of the things you purchase from us, including date and time of the transaction or booking and the amount spent in relation to the transaction.
- Marketing preferences– collection of your consent for us to send you newsletters or other marketing communications, including any special offers. We may start giving customers little gifts on their birthdays, so this would be covered too. You can always change your mind or opt-out; just follow the ‘Preferences’ link at the bottom of our emails, or contact us at email@example.com.
Data collected automatically:
Through using our websites, viewing or interacting with our social media accounts, booking accommodation online or applying for a job with us online we may collect some data automatically. We do not explicitly choose to collect it; it is handled by the third parties we work with and the host we use in the case of our own websites. This data includes:
- Technical data– e.g. IP address, network, browser type and version, type of device, data usage, time zone setting and location, browser plug-in types and versions, operating system and other device data;
- Profile data– e.g. orders or bookings made by you, your preferences and interests, feedback and survey responses;
- Employment data– e.g. details of your qualifications, CV, employment history and current circumstances, job title, contact information of your employer(s) and details of referees;
- Usage data– information about how you use our websites.
How Your Personal Information May Be Used
We may use your personal data for any of these purposes:
- To help with any of your bookings or enquiries and to notify you of any issues (we don’t envisage any but may contact you should one ever occur);
- To improve what we offer you through better understanding our customers;
- To communicate any special offers, upcoming events and other news to you;
- To allow us to carry out targeted marketing that’s more likely to be relevant to you;
- To facilitate personalisation, segmentation and profiling, based on location, preferences, interests, and past engagement with us (including purchases or bookings);
- To compile reports and to allow us to understand the effectiveness of our digital systems.
When processing your personal information, we will always consider any potential impact on you and your rights under data protection law. We will not use your personal data for anything where the impact on you overrides our interests.
Who Your Personal Information Is Shared With
We will never sell or rent out your personal details to any third party. We only share your data with third parties where it is necessary to provide you with our services and in these cases it is done automatically. For example, when you book a table in one of our pubs, your personal information is entered into our booking system which is hosted by Zonal (a large, professional technology outfit). This means that your data resides securely with Zonal on our behalf.
We only share your data with third parties in the following circumstances:
- To fulfil your bookings or orders;
- To verify your identity;
- To authorise payments and any other transactions authorised by you;
- To deliver marketing on behalf of Pubs Limited;
- To maintain the accuracy of your records and manage them if necessary;
- To deal with complaints and improve customer service;
- If Pubs Limited were ever acquired by a third party, in which case personal data held by us would be transferred;
- To meet legal obligations, for example if requested by the authorities for the purposes of national security, taxation or criminal investigations.
As well as Zonal, mentioned above, these are the main third parties we work with who may hold your data on our behalf. It is not necessarily an exhaustive list and we may add more as we go along, too:
- Airship – an email communications platform (which is owned by Zonal);
- Airbnb, Cottages.Com, Booking.Com and Queensborough Group – platforms that deal with accommodation bookings, management and payments processing;
- Indeed and Monster – jobs boards that will hold personal data about you if you apply for a job with us via those platforms.
- Google and Dropbox – cloud storage providers that we use.
Other third parties we may need to share personal data with, though we do not expect to, include:
- Professional advisers or service providers (e.g. lawyers, bankers, auditors or insurers) who provide legal, banking, insurance and accounting services;
- HM Revenue & Customs, regulators or other authorities who may require reporting of processing activities in certain circumstances.
- Any entity to whom the law requires us to disclose data in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court, or in connection with legal proceedings.
Third Party Links
Our website might contain links to third party websites, plug-ins or applications. Clicking through those links or enabling those connections may allow third parties to collect or share data about you. We do not control these external websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit if it concerns you.
It is possible that third parties we work with may transfer data outside the European Economic Area (EEA) when processing or storing it, particularly if they make use of subprocessors. In these cases the third party is required to state the name and location of the entity/entities, the services they provide, security and privacy information and the safeguards in place for transferring data outside the EEA.
We have appropriate security measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. We also limit access to all personal data to those employees, contractors or third parties who need access to it to perform their function. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
How Long May We Keep Your Personal Data For?
We may keep your personal information for as long as you are our customer.
After you stop being a customer, because you have stopped regularly using our pubs or services, we may keep your personal information for up to 6 years for one of the following reasons:
- To respond to any questions or complaints we receive from you;
- To maintain our records;
- To comply with laws applicable to us.
However, we may keep your personal data for longer than 6 years if we need to fulfil contractual obligations to you, if the law requires us to maintain it for a longer period or if you have not withdrawn your consent.
We can only use your personal information to send you marketing messages if we have your consent to do so.
We may tell you about what is happening at our pubs, any upcoming events or offers and other news in a number of ways, principally by email, but only if you have previously agreed to receive these communications.
We may also contact you to hear your views on how we are doing, so may send you a short form or questionnaire. If we do so, you always have the choice whether to provide feedback or not.
You can ask us to stop sending you marketing messages at any time. You can either contact us at firstname.lastname@example.org or click the ‘Preferences’ link found at the bottom of our emails. Where you opt out of marketing messages, this will not apply to personal data given to us as a result of you buying things from us, or any other transaction between you and us.
You have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data. This allows you to receive a copy of the personal data we hold about you and to check we are processing it correctly;
- Request correction of the personal datathat we hold about you, though we may need to verify the accuracy of any new data you give us;
- Request erasure of your personal data.You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request, if applicable;
- Object to processing of your personal datawhere there is something about your situation which makes you feel the processing of your personal data impacts on your fundamental rights and freedoms. You can also object to the processing of your personal data for direct marketing purposes;
- Request restriction of processing of your personal data.You can ask us to suspend the processing of your personal data: (a) if you want us to establish the accuracy of it; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- Request the transfer of your personal data to you or a third party.We will provide you, or a third party you have chosen, your personal data. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to fulfil a contract with you;
- Withdraw consent at any timewhere we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. If this is the case we will let you know at the time you withdraw your consent.
If you wish to exercise any of these rights, please contact us at email@example.com.
No fee usually required
You will not have to pay a fee to access your personal data or to exercise any of the other rights set out above. However we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively we may refuse to comply with your request in these circumstances.
What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or to exercise any of your other rights. This is to make sure personal data is not disclosed to any person who does not have rights to receive it. We may also contact you to ask for further information in order to speed up our response.
Time limit to respond:
We endeavour to respond to all legitimate requests within one month. If your request is complex or you have made several requests, it may take us longer.
If you are unhappy about how we have used your personal information, please let us know by contacting firstname.lastname@example.org so that we can put things right.
If you are not satisfied with our response, or believe we are not processing your data in accordance with the law, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their contact details can be found at www.ico.org.uk. We would always prefer to deal with your complaint directly so would be grateful if you contacted us first.