Our websites are not intended for persons under the age of 13 and we do not knowingly collect data relating to children. If you are under the age of 13, you must ask your parent or guardian to assist you in using the websites.
If you input any personal data of a third party (for example details of any other people in your party), you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
WHO ARE WE?
This website is operated by Ennismore International Management Limited, a company registered in England and Wales under registration number 08102206 with its registered address at 4th Floor, 159 St John St, Clerkenwell, London, EC1V 4QJ.
WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
The Ennismore entity ultimately responsible for the processing of your personal data, as data controller, will depend on which member of the Ennismore group you are interacting with. Ennismore International Management Limited, as joint data controller, acts as the primary point of contact on behalf of each member of the Ennismore group in respect of the personal data which is processed about you. Each joint controller shall have access to and jointly decide the purpose and/or means for which the personal data is processed. For further details, please contact us.
Depending on the nature of your interaction with us, we may collect, use, store and transfer the following kinds of personal data about you:
- Identity Data includes first name, last name, date of birth, marital status and title.
- Contact Data includes billing 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 and services you have purchased from us.
- Technical Dataincludes 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 this website.
- Profile Data includes your social media channels, interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes 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 data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We own all right, title and interest in Aggregated Data. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Other than specific information that you might provide to us in connection with our provision of services to you (such as in relation to your or a member of your party’s physical, health or dietary requirements) we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to fulfil your reservation). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
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 online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– make a reservation;
– attend an event at one of our venues;
– receive any services from us;
– use our Wifi service at one of our venues;
– subscribe to our service or publications;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:
Technical Data from the following parties:
– analytics providers;
– advertising networks; and
– search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services used by you in relation to your use of our website or at any of our venues.
- Identity and Contact Data from data brokers or aggregators.
We also use CCTV surveillance in order to prevent our services and facilities from being used for illegal purposes and to protect our employees and customers. Personal data in this context may be processed by Ennismore and its vendors for these purposes.
Use of personal data under applicable data protection laws must be justified under one of a number of legal ‘grounds’. We are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds which justify our use of your information:
Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent in relation to any such use, and may withdraw your consent by notifying us).
Legitimate Interest: the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract: processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation: processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you or a third party.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified (where appropriate) what our legitimate interests are.
|Purpose / Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To process and deliver your booking, reservation or membership including:(a) Managing payments, fees and charges|
(b) Collecting and recover money owed to us
|(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Necessary to comply with a legal obligation(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation (to prevent fraud)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Technical|
|Necessary for our legitimate interests (to 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||(a) Identity|
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our services and grow our business) Consent, where we are sending you third party marketing|
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
You will receive marketing communications from us including newsletters and marketing emails relating to our services, if (i) you have requested information from us, (ii) used our services, or (iii) provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data for marketing purposes with any company outside the Ennismore group.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We have used and will continue to use reasonable endeavours to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state of the art protection measures.
We take security seriously and take precautions to keep your personal information secure. We have put in place appropriate physical, electronic, and managerial procedures to safeguard the information we collect. however, we have no control over the privacy of any communications while it is in transit to us. We therefore recommend that you not include confidential, proprietary, or sensitive information in any such communications.
In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If such a notification is appropriate, we will endeavour to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties (as set out in the Glossary). Legal basis: legitimate interests (to operate the business and provide related services)
- External Third Parties (as set out in the Glossary). Legal basis: legitimate interests (to operate the business and provide related services)
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. Legal basis: legitimate interests (to operate the business and provide related services)
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes (except as may be permitted by law for compliance purposes) and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Since we operate internationally, it may be necessary to transfer personal data to another company within the Ennismore group or another recipient (such as partners and third-party service providers) in a country outside of the country where it was originally collected or outside of your country of residence or nationality. For many of our business purposes we use cloud-based services. Therefore, for technical and organizational reasons, it may be necessary that your personal data is transferred to servers located countries outside of the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- 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 data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- With your express consent or as otherwise lawfully permitted by the applicable data protection laws.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the ‘Your Legal Rights’ section of the Glossary below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- Right to complain.
PROCEDURE AND TIMING TO EXERCISE RIGHTS
You may contact us at firstname.lastname@example.org to exercise these rights. We will ask you for information in order that you can identify yourself.
Requests will be responded to within one month. We are entitled to extend this term by another two months if the complexity of the situation requires it and we shall notify you if the period is extended. If your request is manifestly unfounded or excessive we may either charge you a fee or refuse to process your request. With respect to access requests we may also charge you for extra copies. If we decide not to honour your request or answer your query, we will explain our reasons for doing so in our reply.
INTERNAL THIRD PARTIES
Any Ennismore group company providing intragroup services, including marketing, finance, IT, system administration, HR services and leadership reporting.
EXTERNAL THIRD PARTIES
- Service providers acting as processors who provide IT, system administration, analytics, marketing, booking and other business services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to 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 successfully 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (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 to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, 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. We will advise you if this is the case at the time you withdraw your consent.
- Right to complain. You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see ico.org.uk). Although we encourage our customers to engage with us first in the event they have any concerns or complaints.