Privacy Notice
Updated 30/06/2020
Introduction
Where the words “we”, “us” or “our” are used in this document, they are all references to The Thatched Tavern, a company incorporated in England and Wales (under company registration number 06852039) and whose registered office is at Cheapside Road, Ascot, SL57QG
We are registered as a data controller with the United Kingdom Information Commissioner’s Office (ICO) under registration number ZA773027
We treat your information very carefully and we have written this document to help you understand what information we collect, who has access to it and for what purposes.
If you are in the process of creating an account with or have already done so, you should read this document in connection with our Terms of Service which set out additional rights and obligations that you have in relation to your use of our apps and services.
We summarise below:
- The types of information about you that we might process;
- How and why we process it;
- Who we share it with;
- How long we process it for;
- Your rights in relation to the information we hold about you; and
- What to do if you have any questions or complaints.
You can ask us to stop processing your information at any time by emailing us at [email protected] (although, as some types of information processing and sharing are essential to the provision of our services or certain aspects of those services, if you do ask us to stop processing your information we may not be able to provide some of the services or continue to provide the services in the same way). However, even if you do ask us to stop, we may have other lawful grounds for processing your information (for example, to comply with our statutory or regulatory duties or the orders of a court).
We encourage you to read this policy in more detail to understand more about how your information is used.
1. How do we collect information about you?
We collect information about you when you register to open an account with us, use our app or services, make transactions using our app or services and when you contact us.
2. What information do we collect?
2.1 We may process the following types of information about you:
(A) Information that may be used to identify you. This might include your name, email address, mobile phone number, and any other data you use to set up your account, to login or to use our services;
(B) Information about how you transact using our app or services. This might include the account id, the goods or services you purchase, the rewards and gifts you earn and redeem (and when and where you do so), the transaction ID, the price paid or discount given, the location and time of the transaction, and the outcome of that transaction. It might also include information about prize draws and promotions you participate in;
(C) Your Personal Preferences. Information about your use of our app and services including location, preferences, and notification settings;
(D) Your Device Information. Information that we obtain from your device or browser when you connect to the website or use our app (such as IP address, operating system and device identifiers). This also includes the use of cookies which we may place on your browser or device to help collect this information, or improve your experience on our website. For more information on cookies, please see our Cookie Policy;
(E) Your Payment Information. Small amounts of information about your payment card (the last four digits of the card number, the card type and the expiry date); and
(F) Surveys. Information that you have opted to provide to us in response to customer research and satisfaction surveys.
3. What do we use your information for?
3.1 We use your information to:
(A) Provide our services. For this purpose, we might use your information to identify you, information about your use of our apps and services, information about your preferences and information about your device and networks. This might include doing things like:
- Processing your app logins
- Processing pre order transactions that you initiate using our services;
- Processing in store transactions that you initiate by identifying at a point of sale;
- Processing your loyalty rewards and redemptions
- Communicating with you about your orders or purchases, our services, your account with us and to provide support where you contact us;
- Communicating with you about any prize draw, reward or offer programmes you participate in using our services;
- Recommending things we think you’ll like such as other products or outlets (where you have switched on your location settings);
- Providing electronic receipts;
(B) Improve our services. To do this we might use information like your location and information about your use of our services. This might include doing things like:
- Measuring the performance of our app and services;
- Conducting statistical analysis about how you and other users of our services make use of those services. We might do this to make improvements to our services or to develop new services, but we will not share statistical analyses about you individually with anyone else;
- Providing software updates so that they deliver improved features and functionality (to our services better) or fixing bugs in our software;
- Personalising parts of the service to your tastes and preferences, including the places where you like to shop and the goods you like to buy;
(C) Communicate with you about marketing or promotional campaigns (but only where you have told us you want to receive these communications and you have not told us to stop sending you messages). To do this we might use data for the means of identifying you and ensuring you are who you say you are, your preferences, your device and network and information about your use of our services. This might include:
- Sending you messages about sales, promotions or prize draws offered by us;
- Personalising parts of the service to your tastes and preferences, including the places you like to shop and the goods you like to buy;
- Creating personalised promotions based on your purchasing preferences and behaviour;
(D) Business, regulatory and legal purposes, like:
- Obtaining and maintaining insurance policies;
- Dealing with any requests you make or content you submit;
- Getting in touch if we need to tell you about something, like a change to our policies or issues with our apps or services;
- Managing risk (for instance, by assessing payment and funding risks, identifying, preventing, detecting or tackling fraud, money laundering and other crime and carrying out regulatory checks);
- Complying with any court order or applicable law, regulation or governmental request (e.g. tax authorities) and to protect our rights or property, or the security or integrity of our business or services.
4. How do we protect your information?
4.1 We store personal data about you at our own premises and with the assistance of third-party service providers. We use third party service providers to perform a number of functions on our behalf including to host our platform, to send messaging on our behalf, to provide technical support services and to process transactions for the purchase of goods and services
4.2 Your personal data may be processed outside the European Economic Area (EEA) by our staff or the staff of our third-party service providers. Such staff may be engaged in, among other things, the provision of your support services. We will only transfer your personal data to a country that the European Commission has decided is a country which ensures an adequate level of protection or if we have otherwise provided for other appropriate safeguards to legitimise such data transfers.
4.3 Whenever we share your personal data with third parties, we will take all reasonable steps to ensure that your privacy rights continue to be protected under the applicable data protection legislation. By sharing your personal data with us and interacting with the services, you accept the storing, processing and/or transfer described in paragraphs 4.1 and 4.2 above.
4.4 We take reasonable measures, including administrative, technical and physical safeguards, to protect your personal data from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.
4.5 We do not store customer card details, and apply information security practices to keep card data safe as it is in transit through our app.
(A) Whenever you enter your card information into our app, those details are encrypted and passed direct to our payment service providers (“PSP”).
(B) Upon receiving your information, our PSP sends us a token (consisting of random letters and numbers) and small amounts of information about your payment card (the last four digits of the card number, the card type and the expiry date).
(C) The token (not your card details) is then used to effect payments for the products or services you purchase through our app.
(D) To ensure the required level of payment security, we will always use a PCI-DSS Level 1 compliant payment gateway to store, process and transmit your payment card data.
(E) We reserve the right to change our payments gateway at our sole discretion, provided any such payment gateway meets this security compliance level.
5. Who do we share your personal data with and why?
5.1 Transfers to other data controllers
(A) Where you have linked your bank account or debit or credit card to your account with us and given us consent to share your information, we will share information with your bank.
(B) Where we do share your information with the PSP or your bank in this way, they will become a new data controller of your information and will contact you to let you know about this and how they use and protect your information.
(C) The information we share might include:
- Information that can be used to identify you;
- Information about how you transact using our app or services;
- Detailed transaction data;
- Your preferences (but only as they relate to that bank); and
- Where you have raised a support issue or notified us of a complaint about the goods or services you purchase, the nature of the issue or complaint.
(D) As a fraud prevention measure, we may send your full name and postcode to PSPs when you link a debit or credit card to your account with us. We do this to ensure that your personal details match with the cardholder details and that you are the legitimate cardholder.
(E) Where you make payments using our services, we share your data with the PSP and they process your transactions. The PSP may share your information with third parties including regulators, your bank and the operators of the card schemes.
5.2 Third party sourced data. We do not share personal data received from third party sources other than as stated in paragraph 5.1(C) above.
5.3 Financial account information. This information is only held by the payment service provider. We do not hold any sensitive financial information about our customers.
5.4 Network, hardware and web. We will not share any of this type of data with third parties other than when required to comply or assist with court, orders, applicable law or regulatory or criminal enquiries.
5.5 Other uses. We may share your information with third parties, including law enforcement agencies for any of the following:
(A) To fulfil our obligations under our Terms of Service, or as required by applicable law or payment method rules;
(B) To assess financial and insurance risks, risk of fraud, sector risk and credit risk;
(C) In relation to any breach of, or to enforce, the Terms of Service;
(D) To recover debt or in relation to your insolvency;
(E) To develop products, services and our systems;
(F) To detect, investigate and prevent fraud or other crime;
(G) To respond to requests from courts, law enforcement agencies and other governmental or regulatory authorities or agencies; and
(H) To protect our rights, privacy and property, and that of our customers.
5.6 We may also share your information with:
(A) Our service providers. Service providers help us with things like point of sale, payment processing, website hosting, application development, data analysis, information technology and related infrastructure, customer services, email delivery and anti-fraud services. These third parties are authorised to use your information only as necessary to provide their services to us and we take appropriate steps to ensure that third parties protect your information; and
(B) Third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). We shall endeavour to ensure such third parties are bound by confidentiality obligations in relation to such information.
6. How long do we process your information for?
6.1 In most cases we will process your information only for as long as we need to in order to provide the services or until you close your account or ask us to stop processing your information.
6.2 You can ask us to stop processing your information or change the way in which we use it by:
(A) Changing the settings in our app (to effect changes to things like your location, notification or preference settings); or
(B) Otherwise, by:
emailing [email protected]
6.3 There are some exceptions when we may have other lawful grounds for processing your information (for example, to comply with our statutory or regulatory duties or the orders of a court). For example, we might be required to retain your personal data for a longer period (usually up to six years after you close your account or tell us to stop but this may vary depending on where you use the service) in order to comply with applicable law, tax obligations or regulatory requirements. This might apply to information about the transactions you make, when and where you make transactions and the information we hold about you for fraud and other crime prevention purposes. If we do retain your information in this way, we will cease other forms of processing and we will continue to keep your information secure.
7. Your rights
7.1 You can request a copy of the personal data we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out. Please contact us by emailing [email protected] with the subject “Data Subject Access Request”.
7.2 You can correct your personal data by emailing [email protected] with the subject “Data Subject Correction Request”.
7.3 You can restrict our use of and stop processing your personal data by emailing [email protected] with the subject “Data Subject Stop Request”.
7.4 You can request to delete your personal data by emailing [email protected] with the subject “Data Subject Deletion Request”.
7.5 If you have any questions about this document or in relation to how we use your personal data, please contact us by:
(A) emailing [email protected] with;
.
8. Complaints
8.1 If you wish to make a complaint about how we process your information, please contact us by
(A) Emailing [email protected]
8.2 The Information Commissioner’s Office regulates data protection and privacy matters in the UK and you have the right to make a complaint to the Information Commissioner’s Office at any time about the way that we use your information. You can find more details at www.ico.org.uk however we should appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office.
9 Updating our Privacy Notice
9.1 We may update this Privacy Notice from time to time. When we do so, we will post the new version on our website and will ask you to accept the new version when you next use our app.