Privacy policy – Brucan Pubs Ltd

You are reading this privacy policy because you are sharing your personal data with us. This data will be used solely for the purposes of our core business.

Brucan Pubs Ltd is UK based public house/bar/restaurant company. Mention of Brucan Pubs Ltd also encompasses The Star Witley Ltd, t/a The Star Witley.

We take data protection very seriously and understand the importance of protecting your privacy and Personal Information. “Personal Information” is information that identifies you as an individual such as your name, date of birth, email address, phone number.

How do we collect information from you?

We collect and use your Personal Information in accordance with this our Privacy Policy.

The majority of the Personal Information you provide to us freely & directly when you complete our feedback form or make a reservation directly with our company.  We also receive your data indirectly from online booking agents; these companies are responsible for issuing to you their own privacy policy and data processing information.

Employee data is gathered through employment & recruitment processes.

It is not likely that we will ask you for further information or through any other method.

Please do not submit such Personal Information to us if you do not wish us to collect it.

What Personal Information do we collect?

Personal Information we collect about you may include the following:

• General identification and contact information: your name; address; email; IP address; telephone details; gender; marital status; family status; date and place of birth; physical attributes including photos
• Other sensitive information: trade union membership, religious beliefs, political opinions or racial or ethical origin, and criminal record.
• Information enabling us to provide products and services: age, location, whether or not you hold a driving licence that enable identification of job search (for example, post code or job role)
• Employee data; date of birth, passport/ID, full name, address, next of kin details, work history, email, phone number, NI number and any other information required to carry out lawful employment.
• Marketing preferences: enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey
• Payment card information collected and processed following PCI DSS
• CCTV images collected for security purposes only
• Information from Apps: submit comments to the Site, participate in message boards, blogs, send us emails or any other user generated content facility
• Publically available information in relation to professional history: educational background; employment history; skills and experience; professional licenses and affiliations; educational and professional qualifications

What legal basis do we rely on to process your Personal Information?

Consent

Brucan Pubs Ltd processes your data with your own consent in circumstances such as; when you have given your details voluntarily in a feedback/review context or entered into a marketing/promotion setting. When we ask for your consent, it is to store your data on our secure booking/marketing software in order to confirm future bookings or inform you of any company updates. You have the right to withdraw consent at any time.  Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

The processing is necessary to fulfil a contract

For example, contractual requirements such as making reservations or bookings with Brucan Pubs Ltd. or via third party booking sites. Or relating to employees of Brucan Pubs Ltd; we require your personal data to create an employee profile for training, employment & payment purposes.

Legitimate Interest

Brucan Pubs Ltd also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights.

• ensuring the security and integrity of our Services and in ensuring that our Websites and Apps operate effectively;
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers;
• understanding our customers’ behaviour, activities, preferences, and needs;
• improving existing products and services and developing new products and services;
• handling customer contacts, queries, complaints or disputes; and fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

The processing is necessary because of a legal obligation that applies

Brucan Pubs Ltd may process your data to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies

Who do we share your Personal Information with?

Brucan Pubs Ltd may make Personal Information available to:

Our service providers

This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

Governmental authorities and third parties involved in court action

We may share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.

Other third parties

Occasionally, we may share Personal Information with other third parties. We will always do this under contract and in accordance with your instructions.

How we use Personal Information?

We use Personal Information to do some or all of the following:

• Communicate with you as part of our business;
• Send you important information regarding changes to our policies, other terms and conditions, and other administrative information;
• Provide improved quality, training and security and manage other commercial risks; Carry out market research and analysis, including satisfaction surveys;
• Provide marketing information to you
• Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully;
• Facilitate social media sharing functionality;
• Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management;
• Resolve complaints, and handle requests for data access or correction;
• Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);
• Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

International Transfers of Personal Information

Personal Information which you supply to us is stored and kept inside the European Economic Area.

However, due to the nature of our clients and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection. In such situations, we transfer the minimum amount of data necessary, anonymise it where possible and enter legal contracts to aim to ensure these third parties handle your Personal Information in accordance with this Privacy Policy and the European levels of data protection.

How can you manage or delete Personal Information?

You can request to have your profile/details de-activated or delete your data account at any time if this does not conflict with our legal record keeping obligations.

In order to do this you can send an email to our Data Protection Officer (DPO) (see below) with your request. Please do not forget to tell us who you are and what action you wish us to take.

Security

We are committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold.

Our security measures include: -

• encryption of our services and data;
• review our information collection, storage and processing practices, including physical security measures;
• restrict access to personal information to Alpha office employees, contractors and agents who need to know that information in order to process it for us and who are subject to contractual confidentiality and processing obligations. They may be disciplined or their contract terminated if they fail to meet these obligations
• internal policies setting out our data security approach and training for employees.

Your Rights

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Third Party Privacy Practices

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties to which Brucan Pubs Ltd associate.  Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with Brucan Pubs Ltd.

Who to contact about your Personal Information

The data controller responsible for your information is Nick Solomides, nick@brucanpubs.com

If you have any questions about this policy or our use of your Personal Information you can contact us via the website: www.brucanpubs.com or write to the Data Protection Officer, Brucan Pubs Ltd, The Star, Petworth Road, Witley, GU8 5LU. If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office.  Further information, including contact details, are available at https://ico.org.uk.

Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.