This is privacy notice of Elite Pubs. 

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you. 

1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOUR PERSONAL DATA WITH
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
11. QUERIES, REQUESTS OR CONCERNS

What is the purpose of this privacy notice? 

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including, but not limited to, any data you may provide through this website when you make a reservation, sign up to our newsletter, purchase a gift voucher or event ticket, or take part in a competition. 

This website is not intended for children, and we do not knowingly collect data relating to children. 

You must read this privacy notice together with any other privacy 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 privacy notice supplements the other notices and is not intended to override them. 

Data controller(s) 

Elite Pubs is made up of different legal entities, details of which can be found in our Terms of Use. This privacy notice is issued on behalf of the Elite Pubs Group so when we mention “Elite Pubs”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Elite Pubs Group responsible for processing your data. For all data matters contact our Data Protection Officer at dataprotection@elitepubs.com. 

Heritage Taverns Ltd, Elite Pubs (Kent) Ltd and The Greathouse Partnership are the controllers and responsible for this website. 

Third-party links outside of our control 

This 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.  

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office. 

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

• Identity Data includes first name, last name, date of birth, recruitment records; 
• Contact Data includes email address, telephone number, billing address, delivery address; 
• Financial Data includes payment card details; 
• Transaction Data includes details about payments to and from you, other details of products and services you have purchased from us; 
• Profile Data includes your bookings made by you, your interests, preferences, feedback; 

• Marketing and Communications Data includes your preferences in receiving marketing from us, your communication preferences, feedback; 
• Usage Data includes information about how you use our website, products and services 
• Technical Data includes IP address, browser type and version, location, operating system and platform, other technology on the advices you use to access this website. 

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. 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.  

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 your 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 provide you with goods or services). In this case, we may have to cancel a product or 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:  

• Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you: 

• • Make a reservation; 
  • Purchase a gift voucher or event ticket; 
  • Apply for a job; 
  • Enter a competition; 
  • Order a takeaway; 
  • Subscribe to our email marketing. 

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.  
  • Technical Data from analytics providers [such as Google based outside the EU]; 
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as Stripe, AirBnB, Local, GiftPro based outside the EU, and Booking.com based inside the EU]. 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• Performance of Contract this means 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.

• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service and the 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing dataprotection@elitepubs.com. 
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

Purposes for which we use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.  

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us  dataprotection@elitepubs.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.  

Marketing  

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 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. 

You will receive marketing communications from us if you have opted in to request information from us and, in each case, you have not opted out of receiving that marketing. 

Opting out 

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 dataprotection@elitepubs.com at any time.  

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 or service purchase. 

Cookies 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  

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 our Data Protection Officer at dataprotection@elitepubs.com.  

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 may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

• Internal Third Parties  
• External Third Parties Service for example: 

• • Providers acting as processors based in the United Kingdom who provide IT and system administration services; 
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services; 
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. 
• 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. 

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

We share your personal data within the Elite Pubs Group. This may involve transferring your data outside the European Economic Area (EEA). 

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. 

Whenever we transfer your data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards. 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 have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

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

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. 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us at dataprotection@elitepubs.com. 

In some circumstances you can ask us to delete your data: see Your legal rights 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. 

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:  

• The right to request a copy of the personal data which we hold about you; 
• The right to request that we correct any personal data if it is found to be inaccurate or out of date; 
• The right to request your personal data is erased where it is no longer necessary to retain such data; 
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;  
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);  
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing; 
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).  

If you wish to exercise any of the rights set out above, please contact dataprotection@elitepubs.com. 

No fee required – with some exceptions 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

This version was last updated on 10.09.2021. 

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current. 

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer at dataprotection@elitepubs.com. 

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.