Caprice Restaurants Privacy Policy Your data is incredibly important to you and to us. Caprice Holdings uses and stores your data for fulfilling a contract with you to manage your event or private dining, and/or for marketing with your consent. You may withdraw consent for marketing at any time. Who Are We? We are Caprice Holdings Ltd and our sister brands are Troia (UK) Restaurants Ltd trading as: The Ivy Collection, The Ivy Asia, Harry’s Dolce Vita, Harry’s Bar James Street, Brasserie of Light and Birley Club Group. This privacy notice has been adopted by each of Caprice Holdings Ltd, Troia (UK) Restaurants Ltd and Birley Club Group (collectively “Restaurant Group”, “we”, “us, “our”). CH Acquisition Ltd is your data controller in relation to locations including J Sheekey, J Sheekey Atlantic Bar, 34 Mayfair, Balthazar, Daphne’s, Scott’s, Sexy Fish and The Club at The Ivy. Troia (UK) Restaurants Ltd is your data controller in relation to locations including The Ivy Collection, The Ivy Asia St Paul’s, The Ivy West Street, Harry’s Dolce Vita, Harry’s Bar James Street, Brasserie of Light and Granary Square Brasserie. MBH Group Ltd is your data controller in relation to locations including Annabel’s, Mark’s Club, Harry’s Bar, Bath & Racquets Club and George. For all data protection enquiries for the Caprice Restaurants please contact: marketing@caprice-holdings.co.uk We are committed to ensuring that your privacy is protected and understand the need for protection of all personal information provided by you to us. This privacy notice is to state what personal information we collect about you, why we collect it and what we do with it. If you have any questions about our privacy notice please do get in touch with us by using the details in the ‘How do you contact us’ section. Quick Guide To Contents What personal information do we collect about you? How do we use your personal information? How long do we keep your personal information for? Who do we share your personal information with? What happens if you do not provide us with the information we request? Do we make automated decisions concerning you? Do we transfer your personal information outside the EEA? What are your rights? How do we contact you? How do you contact us? What personal information do we collect about you? Types of personal information We collect and use many different kinds of personal information to provide our dining experiences and services. The personal information we may collect about you is listed below so you can see what we may know about you. Contact Details: Your name, phone number, where you live and how to contact you; Age: Your date of birth and/or age; Demographic data: Your gender, nationality, and preferred language; Communications: What we learn about you from communications and conversations between us including reservations and information necessary to fulfil your special requests; Usage: Usage data about how you use our products and services; Technical: Details on the devices and technology you use; Financial: Your credit card details, billing address, and bank account information; Contractual data: Details about any products or services that we may provide for you; CCTV: Information provided through CCTV recordings at our restaurants. Providing personal data belonging to others. If you provide the personal information of anyone other than yourself (e.g. your family members or friends), you are responsible for informing that person that we are collecting their personal information and for ensuring that you have valid permission to provide such personal information to us. If you are a minor under 16 years of age, please obtain consent from your parent or guardian before you submit any personal information to us. If you are a parent or guardian of a minor and you have reason to believe your child or ward has provided us with their personal information without your prior consent, please contact us to request for erasure of their personal data or for the minor to be unsubscribed from our mailing lists. Where we collect your personal information from Generally, we collect and process your information in the following ways: Information you give us When you make a reservation at Caprice restaurants; When you purchase gift vouchers; When you visit or make transactions in the establishments that we own or manage; When you respond to our promotions, or subscribe to our mailing lists; When you participate in competitions, contests or games organised by us; When you attend events or functions organised by us, or conducted at our establishments, for example, property launches, private dining, ticketed events and hosted events, promotional and marketing events and other social events; When you use our services (or express an interest in doing so) including services and transactions in respect of properties that we own or manage; When you communicate with us by telephone, email, via our website or through other communication channels, for example, through social media platforms; When you visit our websites, or register a user account with our websites or mobile applications; When we seek information about you and receive your personal data in connection with your relationship with us; and When you submit your personal data to us for any other reason. Information we collect automatically when you use our services Payment and transaction data. Profile and usage data. This includes: your IP address; the security details you create and use to connect to our services; your settings and marketing choices; data we gather from devices you use to connect to our online services; and data we gather from cookies we use and other internet tracking software whilst you are using our website or mobile device applications. [For more information please refer to our cookie policy [set out below].] Information we receive from third parties Our business partners such as tour operators, booking agencies, reservation systems and third parties providing advertising, marketing and promotional services to us; Social networks; Event organiser for private dining; Family members or friends who provide your personal information to us on your behalf; and/or Public agencies or other public sources. Security When your images are captured by us via CCTV cameras while you are within the restaurants, or when photographs or videos of you are taken when you attend events or functions organised by us. How do we use your personal information? We collect and process your personal information for several purposes. The law states that for each purpose we must explain to you what legal grounds we are using to justify our processing. Where we process your personal information, we will have one of more of the following reasons: To provide a requested service or carry out a contract with you; Where we have a legal obligation; Where we have a legitimate interest; Where we have your consent. When we have a business or commercial reason of our own to use your personal information, this is called a “legitimate interest”. Where we rely on legitimate interest for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. Here are the legal grounds for processing your personal information that are relevant to us: To provide a requested service or carry out a contract with you. To manage our relationship and communicate with you; To process your payments, if you purchase our products such as gift vouchers, to provide you with order updates and deal with your enquiries; To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise; To administer and manage your account and associated services including updating your records and answering your queries; To manage how we work with other companies that provide services to us and our customers; To exercise our rights set out in agreements and contracts; and Sharing your personal data with certain third-party service suppliers such as payment service providers. Where we have a legal obligation To comply with laws and regulations that apply to us; To establish, defend and enforce our legal rights; and To deal with requests from you to exercise your rights under data protection laws. Where we have a legitimate interest To manage our relationship with you; For internal training and quality assurance purposes;To administer and manage your account and associated services including updating your records; To manage and audit our business operations including accounting; To run our business in an efficient and proper way. This includes managing our financial position, business capability, IT and governance requirements; To develop and carry out marketing activities and to conduct market research and analysis and develop statistics; To study how our customers use products and services from us and other organisations; For security and safety purposes, in connection with the restaurants that we own or manage, or events organised by us or conducted at our restaurants; For compliance with internal policies and procedures, including audit, accounting, risk management and record keeping; For carrying out research and statistical analysis, including development of new products and services or evaluation and improvement of our existing products and services; Where we have your consent To develop and carry out marketing activities such as informing you of our latest activities, activations and promotions; To study how our customers use products and services from us and other organisations; To communicate with you about our products and services; We may also from time to time ask you for your consent for other purposes, which we will explain to you at the time. How long do we keep your personal information for? We will keep your personal information for as long as you are a customer of ours. We may keep your data for up to 3 years after your last interaction with us or where you have made a transaction, your data will be removed 5 years after such transaction. The reasons we may do this are: To respond to a question or complaint, or to show whether we gave you fair treatment. To study customer data as part of our own internal research. To comply with rules that apply to us about keeping records. We may also keep your data for longer if we cannot delete it for legal or regulatory reasons. After this time, we will securely erase your information. Your personal information is important to us and we will make sure your privacy is protected. Who do we share your personal information with? We may share your personal information with other parties in order to provide you with products and services, run our business and comply with rules that apply to us. These include the following: We may share your personal information within the group of restaurants, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible, they will be sold or transferred to third parties. We may share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, social media networks, data management companies, digital agencies, reservation booking platforms, gift voucher solutions providers, CRM software providers and IT consultants carrying out testing and development work on our business technology systems and function co-ordinators. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality. We may also share your personal information to our appointed representatives in connection with a contracted transaction between you and us, including solicitors. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality. We may also share your personal information with the following organisations: Agents and advisers who we use to help run our business, collect what you owe and explore new ways of doing business; Companies that introduce you to us; Companies that we introduce you to; Companies you ask us to share your data with. Where required we may also share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public. Rights What does this mean? 1. The right to object to processing You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities). 2. The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this privacy notice. 3. The right of access You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this privacy notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law. 4. The right to rectification You are entitled to have your information corrected if it’s inaccurate or incomplete. 5. The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. 6. The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. 7. The right to data portability You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. 8. The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator. 9. The right to withdraw consent If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal information for marketing purposes. We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for: baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know. If you have any questions about this privacy notice, or would like to exercise any of your rights, please contact us by writing to us at the address below: marketing@caprice-holdings.co.uk If you are unhappy about any aspect of the way we collect, share or use your personal information, please let us know using the contact details above. How will you know if we change this privacy notice? We may need to make changes to this privacy notice at any time. If we make any material change to how we collect your personal information, or how we use or share it, we will update the privacy notice on our website, and we will inform you of these changes by our normal means of communicating with you, including by email, or by post. 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