Important information and who we are
Purpose of this Policy
This Policy aims to give you information on how we collect and process your Personal Data through your use of this website, including any data you may provide to us when you use our Wi-Fi services, visit one of our restaurants or bars, subscribe to our newsletter and loyalty scheme or use our website.
It is important that you read this Policy together with any other Policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
The White Brasserie Company Ltd is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this Policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights in relation to your data, please contact the data privacy manager using the details set out below.
Our full details are:
- Full name of legal entity: The White Brasserie Company Ltd
- Name or title of data privacy manager : Rob Trippett
- Email address: firstname.lastname@example.org
- Phone: 020 3166 2727
- Postal address: 106-108 High Street, Teddington, Middlesex, TW11 8JD
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Policy
We keep our Policy under regular review. This version was last updated on [11 May 2018].
what is PERSONALLY IDENTIFIABLE INFORMATION (PII) / Personal Data?
Personal data or PII means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, credit / debit card number, IP address, location data, purchase history (“Personal Data”).
We may collect, use, store and transfer different kinds of Personal Data about you including :
- Identity Data includes first name, last name, username, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- Technical Data includes information about whether you have opened our emails or clicked on any of the links in those emails, internet protocol (IP) address, operating system and platform and other technology on the devices you use to access this website.
- Marketing and Communications Data includes your preferences for receiving marketing from us and our third parties and your communication preference.
We may also collect, use and aggregated data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
PURPOSES FOR WHICH we process PERSONAL data
We will only process your Personal Data, in accordance with applicable law, for the following purposes:
- creating and maintaining your customer account, if you become our registered customer, member of our loyalty scheme (“Frequent Diner”) and/or sign up for our e-newsletters;
- to process and administer your booking requests;
- offering our services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker or send you offers on your birthday.
- obtaining payment from you, if you purchase any of our goods and/or services like our e-gift vouchers and gift cards;
- enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions, as may be required, in order to fulfil your orders or requests;
- resolving any refunds or disputes, if you lawfully exercise your rights or if you wish to dispute any part of our offering;
- sending you personalised marketing communications including offers and discounts, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you. Please note we do not share your Personal Data with those partners;
- ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;
- to help us identify you, for example, when you are using our Wi-Fi services;
- developing and improving our products and services, for example, by reviewing visits to our website and its various subpages, demand for specific goods and services and user comments;
- to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.
How is your Personal Data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- sign up to our newsletter;
- login to our Wi-Fi services;
- enter a competition, promotion or survey;
- give us some feedback; or
- when you visit one of our establishments and use your Frequent Diner card.
Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
- Technical Data from Google Analytics including details about your use of our website, browsing actions and patterns.
- Contact, Technical and Transaction Data from our WiFi provider Wireless Social https://www.wireless-social.com/privacy-policy
- our grounds for processing your Personal Data
Your consent, as the Data Subject, to the processing as specified in this Policy is the primary legal ground for our processing of your Personal Data. However, there may be circumstances where we may also rely on other valid legal grounds for the processing of your Personal Data, such as:
- your request for content, goods or services necessitating steps including processing of your Personal Data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract; and
- legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights; and
- compliance with a legal obligation to which we are subject.
DISCLOSURE OF CUSTOMER INFORMATION
There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
- to our subsidiaries, branches or associated offices;
- to our outsourced service providers or suppliers to facilitate the provision of our services or goods to you, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data or webhosting provider through which your Personal Data may be collected;
- to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;
- subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, please unsubscribe by emailing us at email@example.com or by clicking the unsubscribe link on any of our emails;
- to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company;
- to public authorities where we are required by law to do so; and
- to any other third party where you have provided your consent.
Please note, save as described above we do not rent or trade email lists with other organisations and businesses.
RETENTION OF PERSONAL DATA
Your Personal Data will be retained until your last use or purchase of our services or goods and normally for a period of two years, thereafter unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your Personal Data that is no longer required for the purposes set out in this Policy. The retention of your Personal Data will be subject to periodic review.
We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
DATA SUBJECT RIGHTS
Opting Out. You can ask us to stop sending you marketing messages at any time by contacting us using the contact details above or by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
Changing your Personal Data. You can change the Personal Data that we hold about you at any time by contacting us, using the details set out above, and asking us to update your information.
Data protection law provides data subjects with numerous rights, including the rights to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data. Data subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law.
- Right to make subject access request (SAR). Data subjects may, where permitted by applicable law, request copies of their Personal Data. If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, you may do so by writing to the Data Privacy Manager whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.
- Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data.
- Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your Personal Data is essential.
- Right to object to processing. You may, as permitted by applicable law, request that we stop processing your Personal Data.
- Right to erasure. You may request that we erase your Personal Data and we will comply with your request, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
- Right to data portability. In certain circumstances, you may request that we provide your Personal Data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services.
- Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
This website is not intended for children and we do not knowingly collect data relating to children.
We use closed circuit television (CCTV) at our establishments and the images produced to prevent or detect crime and to provide a safe and secure environment for our staff and guests.
We comply with the Information Commissioner’s Office CCTV Code of Practice to ensure that CCTV is used responsibly and safeguards both trust and confidence in its continued use.
Cameras are situated so that they only capture images relevant to the purposes for which they are installed.
Recorded data will not be retained for longer than is necessary. While retained, the integrity of the recordings will be maintained to ensure their evidential value and to protect the rights of the people whose images have been recorded.
All retained data will be stored securely at all times and permanently deleted after six months unless we are required to retain the data for legal reasons.