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Real London Pub Company Privacy Statement and GDPR Policy
Real London Pub Company takes customer privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data
Our personal information handling policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.
1. What information do we collect?
We collect and process personal data about you when you visit or arrange to visit one of our pubs. We collect and processes a range of information about you. This may include:
your name, contact details, including email address and telephone number,
credit or bank card details
• closed circuit television footage (CCTV)
2. How do we use this information and what is the legal basis for this use?
We process the personal data listed in paragraph 1 above for the following purposes:
• as required to make a reservation to use a venue at the guest request
• to process a ‘customer not present’ transaction in the event of a pre or post visit payment or deposit.
• to comply with Premises License conditions relating to the requirement of CCTV
• with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
• with your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
• we may use information you provide to personalise our communications to you in accordance with our legitimate interests;
• we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
3. With whom and where will we share your personal data?
• We may share your personal data with the below third parties:
• NHS Test and Trace or NHS Scotland Test and Protect in connection with the collection of contact details at our pubs for COVID-19 contact tracing purposes;
• Emergency services/contacts
• Local Authorities where appropriate Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
4. How long will you keep my personal data?
We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is
reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
• booking information may be kept for a maximum of 24 months
• e-mail correspondence may be kept for maximum of 5 years
• credit or bank card details are stored for a maximum of 12 months and dealt with in accordance with PCI/DSS regulations
• CCTV footage is kept for 28 days, only longer when downloaded for a specific reason and dealt with in accordance with the code of practice provided by the information commissioners office – available at www.ico.org.uk
5. Where is my data stored?
The personal data that we collect from you may be transferred to, and stored outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the third country's data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Locations for data storage include;
• Real London Pubs Company by hardcopy and on CPU
• CPU at Venue
• Physical diary at Venue
CCTV DVR at Venue
6. What are my rights in relation to my personal data?
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us. Where you have consented to us using your personal data, you can withdraw that consent at any time. If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it. You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you. Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine-readable format. If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don't have a good reason to continue to use it; or (d) if we haven't handled your personal data in accordance with our obligations.
7. Where can I find more information about Real London Pub Company’s handling of my data?
Should you have any queries regarding this Privacy Notice, about our processing of your personal data or wish to exercise your rights you can contact us using this email email@example.com If you are not happy with our response, you can contact the Information Commissioner's Office: https://ico.org.uk/