Privacy Policy

Privacy Policy

Your personal information

This privacy policy explains how we collect and process your personal information.  Personal information, or personal information, means any information about an individual from which that person can be identified.  This includes information that you tell us, what we learn from you and the choices you make about the marketing you want us to send to you. This policy explains how we do this, what your rights are and how the law protects you.

We do not knowingly collect data relating to children.

Changes to data protection law

The law in relation to data protection is changing on the 25 May 2018 when the General Data Protection Regulation comes into force in the United Kingdom and across Europe.

This privacy policy tells you about most of your rights under the new law.

There may be changes which we will be required to make to this privacy policy after the 25 May 2018 – we will post a copy of the amended policy on our website and will notify you any significant change to this policy.  We may need to ask you to agree to the changes, or refresh your consent to us using your personal information.

Who we are and how you can contact us

We are The City Pub Group Plc.  Our registered office is at Essel House,2nd Floor, 29 Foley Street, London W1W 7TH.

You can contact us by email at [email protected] or by calling us on 020 7559 5106.  If you need to you can write to us at Operations Officer, Essel House,2nd Floor, 29 Foley Street, London W1W 7TH.

Our representative for all queries in relation to this policy and your data protection rights is our Operations Officer.

When we refer to our website, we mean our website at http://www.citypubcompany.com together with the websites of each of our pubs which can be found at http://www.citypubcompany.com/.

Where we collect your personal information from

We may collect personal information about you in the following ways:

Data you give to us:

  • Data you give to us when you enquire about, or make, reservations/bookings at any of our pubs, whether in person, by using our website or by using any of our mobile apps
  • When you talk to us on the phone or in one of our pubs
  • When you use our website or mobile device apps (including ourCity Club app)
  • In emails or letters that you send to us
  • If you take part in our competitions or promotions, whether with us or with any of our pubs
  • When you give us feedback

Data we collect when you use our services:

  • Payment and transaction data
  • Profile and usage data, including data we gather from the devices you use to connect to those services such as computers and mobile phones, using cookies (please see our separate cookies policy) and other internet tracking software

Data from third parties we work with:

  • Social networks such as Facebook, Twitter and Instagram
  • Third party booking organisations with which we have agreements relating to introductions and referrals and other promotional activities
  • When we acquire another company or business, the personal information that that company or business holds will be acquired by us.

Data we collect about you

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

Identity data– name, username, marital status, title, photographic id, photographs, date of birth and gender

Contact data– billing address, delivery address, email address or telephone numbers

Financial data– bank account and payment card details

Transaction data– details about payments to and from you and other details of bookings, reservations, products and services you have purchased from us

Technical data– internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or apps

Profile data– your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses

Professional data– including your employer, job title and key worker identification

Usage data– information about how you use our website, products and services

Marketing and communications data– your preferences in receiving marketing from us and our third parties and your communication preferences

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal information in law as this data does notdirectly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

How we use your personal information

Your privacy is protected by law.

We are only allowed to use personal information about you if we have a legal basis to do so, and we are required to tell you what that legal basis is. We have set out in the table below: the personal information which we collect from you, how we use it, and the legal ground on which we rely when we use the personal information.

In some circumstances we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is.  A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable.  If we are relying on our legitimate interests, we have set that out in the table below.   

Who we share your personal information with

We may share your personal information with any of the following organisations, for the purposes of providing the services which you have requested from us:

  • Our group companies, including The City Pub Company (West) Limited
  • Third party booking organisations with which we have agreements relating to introductions and referrals and other promotional activities
  • Direct marketing companies who help us manage our electronic communications with you
  • Third party organisations that provide applications/functionality, data processing or IT services to us. For example we use third parties to help provide, run and manage our customer loyalty schemes and our internal IT systems, manage payments on our behalf, email marketing campaigns and customer analytics. These include providers of IT services, cloud-based software as services providers, data analysis, security and storage services

You can find details of how these third parties use your personal information by looking at their privacy policies, all of which should be available on the relevant websites, or on request.

We require all organisations who we share your data with to respect the security of your personal information and to treat it in accordance with the law.  We do not allow any of our service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

What we use your personal information forWhat personal information we collectOur legal grounds for processingOur legitimate interests (if applicable)
To enable you to submit enquires about, or make, reservations / bookings at any of our pubsIdentity data
Contact data
Profile data
Usage data
Technical data
Marketing and communications data
Professional data
Performance of a contract
Our legitimate interests
Promoting our business and our services, identifying ways to grow our business
Developing our business and informing our marketing strategy
When you register on our website or sign-up to be on our mailing list or receive our newslettersIdentity data
Contact data
Profile data
Usage data
Technical data
Marketing and communications data
Professional data
Our legitimate interestsPromoting our business and our services, identifying ways to grow our business
Developing our business and informing our marketing strategy
To manage payments or collect and recover money owed to and by usIdentity Data
Contact Data
Financial Data
Professional Information
Performance of a contract
Our legitimate interests
Ensuring we can manage payments, fees and charges and to collect and recover money owed to us or by us to our suppliers
To manage our relationship with you, including notifying you about changes to our terms or privacy noticesIdentity
Contact
Transaction
Performance of a contract with you
Necessary to comply with a legal obligation
Our legitimate interests
To keep our records up to date, and ensure that we can notify you about changes to our privacy notices
To enable you to take part in a prize draw, competition or to complete a surveyIdentity data
Contact data
Profile data
Transaction data
Performance of a contract with you
Our legitimate interests
Promoting our business and our services, identifying ways to grow our business
Developing our business and informing our marketing strategy To study how customers use our services and to grow our business
To administer and protect our business and our websiteIdentity Data
Contact Data
Profile Data
Usage Data
Technical Data
Marketing and Communications Data
Professional Information
Necessary to comply with a legal obligation
Our legitimate interests
Ensuring the efficient and secure running of our business, including through office and facilities administration, maintaining information technology services, network and data security, fraud prevention
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youIdentity data
Contact data
Profile data
Usage data
Technical data
Marketing and communications data
Our legitimate interestsPromoting our business and our services, identifying ways to grow our business
To use data analytics to improve our website, apps, products / services, marketing, customer relationships and experiencesTechnical
Usage
Profile
Our legitimate interestsTo define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you, or to invite you to attend marketing or promotional, or other special events, and to manage your attendance at and participation in themIdentity data
Contact data
Profile data
Usage data
Technical data
Marketing and communications data
Professional data
Our legitimate interestsPromoting our business and our services, identifying ways to grow our business
When we use CCTV in our pubsIdentity dataNecessary to comply with a legal obligation
Our legitimate interests
For the prevention of crime and the protection of our customers, staff and supplies
When you join our key workers discount schemeIdentity data
Contact data
Profile data
Professional data
Performance of a contract with you
Our legitimate interests
Promoting our business and our services, identifying ways to grow our business

Third party links

Our website may include links to third party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.

Transferring your personal information outside the EEA

The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside the EEA we have to tell you.

We will only send your data outside the EEA:

(a)  if you have instructed us to do so

(b)  to comply with a legal duty

(c)  to work with our suppliers who help us to run our systems and provide our services

If we do transfer your personal information outside the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA by ensuring at least one of the following safeguards is implemented:

  • we may transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator (including the ICO) of a breach where we are legally required to do so.

How long do we keep your personal information

We will 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 services, we may keep your personal information for as long as necessary to fulfil the purposes we collected it for. This includes the following reasons:

  • To respond to any questions or complaints from you
  • To maintain our records
  • To comply with laws applicable to us
  • For the establishment or defence of legal claims

CCTV recordings are typically overwritten after a short period of time unless an issue requiring investigation is brought to our attention.

Marketing

We may use your personal information to tell you about relevant services and any upcoming offers.

We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.

You can ask us to stop sending you marketing messages at any time – you just need to contact us, or use the opt-out links on any marketing message sent to you.

We will get your express opt-in consent before we share your personal information with any company outside our group of companies for marketing purposes.  You can ask a third party company to stop sending you marketing messages at any time, by adjusting your marketing preferences in relation to that company or by using the opt-out links on any marketing message sent to you.

Where you opt out of receiving marketing messages, this will not apply to personal information provided to us as a result of purchasing our goods or services or any other transaction between you and us.

Your rights

You have certain rights which are set out in the law relating to your personal information.  The most important rights are set out below.

Getting a copy of the information we hold

You can ask us for a copy of the personal information which we hold about you, by writing to us at Operations Officer, City Pub Company, Essel House 2nd Floor, 29 Foley Street, London W1W 7TH or by emailing us at [email protected]   This is known as a data subject access request.

You will not have to pay a fee to access your personal information, unless we believe that your request is clearly unfounded, repetitive or excessive. In such circumstances we can charge a reasonable fee or refuse to comply with your request.

We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month and in that case we will notify you and keep you updated.

Telling us if information we hold is incorrect

You have the right to question any information we hold about you that you think is wrong or incomplete.  Please contact us by email at [email protected] if you want to do this and we will take reasonable steps to check its accuracy and, if necessary, correct it.

Telling us if you want us to stop using your personal information

You have the right to:

  • object to our use of your personal information (known as the right to object); or
  • ask us to delete the personal information (known as the right to erasure); or
  • request the restriction of processing; or
  • ask us to stop using it if there is no need for us to use it (known as the right to be forgotten).

There may be legal reasons why we need to keep or use your data, which we will tell you if you exercise one of the above rights.

Where we rely on our legitimate interest

In cases where we are processing your personal information on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal information.

Withdrawing consent

You can withdraw your consent to us using your personal information at any time.  Please contact us by email at [email protected] if you want to withdraw your consent.  If you withdraw your consent, we may not be able to provide you with certain products or services.

Request a transfer of data

You may ask us to transfer your personal information to a third party.  This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Making a complaint

Please let us know if you are unhappy with how we have used your personal information by contacting us by email at [email protected]

You also have a right to complain to the Information Commissioner’s Office.  You can find their contact details at www.ico.org.uk.  We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.