Privacy Policy

INNKEEPER’S LODGE: GENERAL PRIVACY POLICY

We take your privacy seriously and we respect your privacy and data protection rights.  This privacy notice aims to give you information on how we collect and process your personal data through your use of our websites , and our services, including any data you may provide through our websites  and our services when you sign up to receive news, offers, promotions and updates, book a room, take part in a competition, complete a survey, provide feedback, or otherwise purchase a product or service (such as buying a gift card).

Please take time to read this privacy notice in full, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you understand and are happy with how we collect and process your personal data.  This privacy notice supplements the other notices and is not intended to override them.

We sometimes collect and process Sensitive Data (such as your health information, race, ethnicity) and Children’s Data.  See sections 6 and 7 of this privacy notice for details.  Except where set out to the contrary in another of our privacy notices (for example, our Candidate Privacy Notice for job applications), we do not collect or process any information about criminal convictions and offences. 

Inn Keeper’s Lodge is part of Mitchells & Butlers, a group made up of different legal entities, brands and outlets (the Group).  Details of the Group can be found at www.mbplc.com. 

This privacy notice is issued for Inn Keeper’s Lodge by Mitchells & Butlers Leisure Retail Limited (company number 01001181 with its registered office at 27 Fleet Street, Birmingham B3 1JP) on behalf of the Group, so when we refer to “we”, “us” or “our” in this privacy notice, we are referring to the relevant company within the Group that is responsible for processing your data.  Mitchells & Butlers Leisure Retail Limited is the controller and is responsible for the Inn Keeper’s Lodge brand’s websites and this service.

We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy notice.  If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details below:

Our full details are:

Data Protection Officer

data.protection@mbplc.com

27 Fleet Street, Birmingham B3 1JP

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns).  However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.

We will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address.  Otherwise, please look out for the flags on our websites and materials that indicates we have changed this privacy notice. If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes.

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

Our websites and/or the service 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. When you leave our website and/or service, we encourage you to read the privacy notice of every website, plug-in and/or application that you visit.

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  We may process different kinds of personal data about you, which we have categorised as follows:

Identity Data: including your name, username (or similar unique identification numbers that we may apply to you), email address, marital status, title, date of birth and gender, job title and employer.
Contact Data: including your billing address, delivery address, email address and telephone number(s).
Financial Data: including payment card details.
Transaction Data: including the details of the products and services purchased and the date, time and location of sale and your purchasing activity (including vouchers and coupons activity).
Technical Data: including information we collect through your use of our websites, where you came to our website from and where you went when you left our website, how often you visit and use our websites, technical information about the devices you use to access our websites (including your device’s unique identifying codes (e.g. its “MAC” address), relevant IP address, operating system and version, web browser and version, and geographic location).
Profile Data: including your username and password, purchases, orders or bookings made by you, your reason for staying with us, your interests, your preferences, your feedback, your survey responses, your social media content (where this is in the public domain including posts and comments, pictures and video footage) and profile information and insight from organisations that already hold information on you (such as credit reference agencies, travel agencies, booking intermediaries, and ‘customer insight companies’ who give us their views on your household, your status, as well as your possible preferences and behaviours).
Usage Data: including information about how you use our website, products and services (such as details of bookings).
Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties, your communication preferences and information on what you view, click on and access in and through our marketing emails or text messages.
Sensitive Data: including information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data (see section 6).
Children’s Data: including names, ages and dietary requirements of children when they stay with us at one of our venues which is booked by an adult and Sensitive Data relating to children where this is provided by you (see section 7).  We do not knowingly process any other data relating to children. 

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.

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 provide you with products 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.

In certain situations we have to collect Sensitive Data about you.  Under data protection law this is known as “special category” data and includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data. 

When do we process Sensitive Data?  We only collect and process Sensitive Data where you provide such information to us in the following situations:

As part of any feedback and/or complaints which you raise with us, for example where you believe you have suffered a health issue following a visit to us (for example, suspected food poisoning or another health and safety incident), or where you believe we have been discriminatory against you (for example, discrimination based on race or sexual orientation).  When you provide details of what happened, this may include giving us Sensitive Data.  We are allowed to process this Sensitive Data (together with any other relevant information), to investigate, address and resolve your issue and to administer any possible legal claims or out-of-court procedures. We may process Sensitive Data relating to children in the situations set out in Section 7.   

Where you are applying for a job with us.  In this situation, we can process your Sensitive Data because it is necessary for carrying out our obligations and rights related to employment law and your working capacity; this is covered in a separate Candidate Privacy Policy which is displayed when you apply for job, and a copy of it can be provided by emailing data.protection@mbplc.com.  We do not routinely collect and process Sensitive Data in any other situations.  If we do, we will obtain your explicit consent.

Children need particular protection where their data is collected and processed.  We may collect and process Children’s Data in certain situations as described below. 

When do we process Children’s Data?  We only collect and process Children’s Data in the following situations:

For enquiring about, and booking a stay with us.  When you fill out forms relating to the event you may choose to provide us with children’s names, ages and dietary requirements.

Where you believe you have suffered a health issue following a visit to one of our venues (for example, suspected food poisoning or another health and safety incident), or where you believe we have been discriminatory against you (for example, discrimination based on race or sexual orientation) where children have been involved in these situations.  Again, you might provide us with children’s names, ages and health information.

We are allowed to process Children’s Data where it is required for our legitimate interests (offering and providing accommodation for children as part of a booking/stay with an adult in our venues, dealing with feedback and complaints, understanding how customers interact websites, providing safe and secure use of our online facilities) or whenever required to comply with a legal obligation; and, in any of these situations, where the processing is necessary.

Alternatively, or in addition, we may process Children’s Data on the basis of consent, given or authorised by the holder of parental responsibility (and in these circumstances we will always make reasonable efforts to verify such consent).

We do, from time to time, process personal data about you in an automated way to evaluate certain personal aspects about you, including to enable us to analyse and make predictions about your interests and how you are likely to interact with our Group.  This is commonly referred to as profiling and it is our way of providing you with a more bespoke customer experience based on how we think you engage with us and our Group.

The personal data about you that we may process for profiling purposes includes your Identity Data, your Contact Data and your Profile Data.   We do not process personal data about you for profiling purposes that consists of Special Category Personal Data.  We process your personal data for profiling purposes for our legitimate interests as set out below:

How We Profile and the Logic We Use

We may collect your personal data from several sources, including directly from you, which we then combine in order to create a view of your interactions with our group of companies.  Once we have this record, we match multiple variables that are unique to you (such as name, email, postcode and/or mobile number) to create an overall matched record.  We then clean the record by comparing it with certain third-party reference files (such as the Post Office Address File, the Bereavement Register and email validation) to try to ensure that the record is as accurate as possible.

Once the record is cleaned, we may add the record to our customer database and we start to build a behavioural profile about you, which details the brands that you do, or do not, engage with.  We also infer a visit to a particular brand location so that we can gain a better understanding of how far you might travel to visit a particular brand of ours.  In addition, we apply our algorithms or scoring models to the record to indicate how likely it will be that you will visit a particular brand in the future.  We then segment our overall database to create a customer base for each brand to determine those customers with a high likelihood to visit a brand and those who are unlikely to visit a brand.  Your record may be in more than one segmented element of the database, for example, you may be high likelihood for 3 of our brands and low likelihood for 2 of our brands within your catchment area.

As well as looking at how you interact with our brands, we may also apply demographic profiles (provided to us by a third party supplier of demographic data) to your record using your postcode. These profiles are trends based on a nationally representative sample. This enables us to understand your likely profile such as age, home and financial situation as well as your attitudes to family, home life, matters such as dining, media consumption or your purchasing behaviour.   

Finally, to ensure that you get the most relevant communications from us, we may use the above variables (if you have agreed to us sending you certain communications) to select an appropriate communication for you to receive, as well as ensuring the you receive the right content or offer.   For example, our profiling will help us determine whether you may be more interested in a family message and offer as opposed to a champagne promotion. We enhance this information with data we have regarding the communications and promotions that you have (or have not) engaged with in the past.

Significance and Consequence of the Profiling

The profiling we do enables us to better understand how you interact, or may interact, with our brands.  It enables us to provide you with the most relevant information (such as vouchers and offers where you have agreed to receive these) and to determine whether a particular brand or outlet should be more tailored to those people who do, or who are likely to, visit it.  The profiling also helps us to improve our services and the offerings of our brands depending on the demographic of existing or future visitors.]

We use different methods to collect personal data from and about you including through:

Direct Interactions: you may give us your Identity, Contact, Financial, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you purchase our products or services, book a room, create an account with us, subscribe to our services, news, offers, promotions and updates or groups, request marketing to be sent to you, enter a competition or promotion, complete a survey or give us feedback.
Social Media Interactions: our website and services may allow you to interact with them by using your social media applications.  This interaction may result in us collecting some of your social media content (including posts and comments, pictures and video footage), but only where this content is in the public domain and/or where this content has been sent by you to us in a private message via social media; and also your Technical, Profile and Marketing and Communications Data.
Automated Technologies: as you interact with our website and our services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [link] for further details.
Other Third Parties or Publicly Available Sources: we may receive personal data about you from various third parties and public sources as set out below:

Technical Data from analytics providers such as Google, advertising networks and search information providers.
Marketing and Communications Data and Technical Data from online advertising data providers such as Google based outside the EEA.
Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data and Marketing and Communications Data from third party affiliate sites such as Vouchercloud and Vouchercode based in the EEA.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Profile Data and Marketing and Communications Data from social media providers such as Facebook based inside and outside of the EEA

We only process your personal data when allowed to do so by law.  Most commonly, we will process your personal data:

With your consent and please note that you have the right to withdraw your consent at any time by contacting us.
Where we need to perform a contract we are about to enter into, or have entered into, with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

The below table sets out how we process your personal data.  Please contact us if you would like further information about the specific basis for processing.

Activity

Personal Data

Basis for Processing

To process and deliver a product or service that you have ordered from us, including:

  • room
  • gift card purchases
  • when we issue a refund
  • to manage the payment, fees and charges
  • to collect and recover money owed to us
  • any other contractual arrangement that we agree to enter into with you

Identity Data

Contact Data

Financial Data

Transaction Data

Children’s Data (only as required for booking/staying with us)

Performance of a contract with you

Necessary for our legitimate interests, being to recover debts due to us or, in the case of Children’s Data, to provide an booking/stay tailored to your child

To process your registration with us including:

  • to receive news, offers, promotions and updates
  • to receive a voucher
  • when you otherwise register as one of our customers

Identity Data

Contact Data

Profile Data

Performance of a contract with you

To tailor our direct marketing to you and to send you direct marketing communications including via:

  • Email
  • SMS

Identity Data

Contact Data

Technical Data

Transaction Data

Usage Data

Profile Data

Marketing and Communications Data

In terms of tailoring our direct marketing, necessary for our legitimate interests, being to develop our business and inform our marketing strategy

In terms of sending direct marketing where you are a customer and have not previously opted out of receiving such direct marketing, as necessary for our legitimate interests, being to offer you relevant products and services related to what we have previously provided to you

In terms of sending direct marking where you are not one of our customers, with your consent given when you sign up to our website or otherwise give your details and provide consent when doing so

To enable you to take part in prize draws, competitions or surveys

Identity Data

Contact Data

Usage Data

Profile Data

Marketing and Communications Data

Performance of a contract with you

Necessary for our legitimate interests, being to study how customers use our products and services, to develop them and grow our business

To understand our customers, matching common information from various sources to build a profile of you; this may include:

  • understanding your habits, where you are from time to time, your personal circumstances and those of your family or household, and the things you may like, dislike and be interested in
  • the ways you interact with us, such as subscribing to news, offers, promotions and updates, booking rooms, completing surveys, entering competitions, browsing website pages, interacting – e.g. by likes and comments – with our social media accounts and reviewing our products and services in public forums
  • creating Aggregated Data

Identity Data

Contact Data

Technical Data

Transaction Data

Usage Data

Profile Data

Marketing and Communications Data

Necessary for our legitimate interests, being to develop our business, products, services, content and advertising campaigns to make these relevant for you, and tracking the effectiveness of our advertising campaigns

To manage our relationship with you, which includes:

  • to notify you about changes to our privacy policy
  • to communicate with you about operational changes to our products, services, websites
  • to gather feedback from you about your experience with us, our websites, and other services and activities from time to time
  • to respond to, deal with and address any questions, suggestions, issues or complaints you have raised and reporting and analysis in respect of these
  • to respond to any social media reviews, posts or other public comments you make about us, our brands, websites, services or other activities

Identity Data

Contact Data

Profile Data

Marketing and Communications Data

Sensitive Data (only as required for dealing with feedback and complaints about specific issues)

Children’s Data (only as required for dealing with feedback and complaints for specific issues)

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and website and offer safe and secure use of our products and services, which includes:

  • the process of anonymising your information so that you are no longer identifiable to us, where we no longer need your data in an identifiable form
  • to provide safe access to our websites
  • to power user security measures and services, such as recognition of your usernames and passwords, as well as reset functions
  • to monitor security measures around our websites, to check they are not being abused or threatened
  • to protect you and our business against potential criminal behaviour, such as fraud
  • to administer troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Identity Data

Contact Data

Technical Data

Usage Data

Profile Data

Marketing and Communications Data

Performance of a contract with you

Necessary for our legitimate interests, being to run our business, ensure network security and prevent potential criminal behaviour

Necessary to comply with a legal obligation

To provide information to legal and regulatory bodies where we are under a legal or regulatory obligation to do so

Identity Data

Contact Data

Technical Data

Transaction Data

Usage Data

Profile Data

Marketing and Communications Data

Sensitive Data

Children’s Data

Necessary to comply with a legal obligation

We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the laws applicable to us and for the purposes set out in the table in paragraph 8 above.

We share your personal data with: 

All of our Group including new companies, brands or outlets we might acquire in the future (acting as controllers or processors) who are all based in the EEA and who provide IT, HR, system administration services and for whom you may have agreed can provide you with marketing communications. Our Group portfolio of brands can be found here: www.mbplc.com/ourbrands.
Service providers (mainly acting as processors, but sometimes as controllers) who help us provide our websites, and related services to you; for example, information technology companies who design and host our websites, payment services companies who enable you to use credit or payment cards with us, and data insight specialists.
Affiliated third parties (acting as processors and controllers) that provide services to us such as market research, table booking, voucher supply and redemption, marketing insight services and data analytics services.
Rewards companies (acting as controllers) which you have signed up to, in order for you to receive the rewards and benefits they offer.
Any new business partners (acting as controllers or processors) we may have over time; for example if we enter into a joint venture, reorganisation, business merger or sale of part of our business, the other party may receive some or all of your information.
Our professional advisors (acting as controllers or processors); for example, our lawyers, insurers and insurance brokers, when they need it to provide advice to us or help us obtain insurance.
The Police, the Health and Safety Executive, local authorities, Her Majesty’s Revenue and Customs (HMRC), the Courts and any other central or local government bodies (acting as controllers or processors) where we are required to do so to comply with our legal obligations, or where they request it and we may lawfully disclose it, for example for the prevention and detection of crime or to report serious health and safety incidents.
We also may share the information we collect with other third parties where we are legally obliged to do so; for example, to comply with a court order.

Some of our external third parties are based outside of the EEA so their processing of your personal data will involve a transfer of data outside the EEA.  Whenever we transfer your personal data outside of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We 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.
We will use specific contracts approved by the European Commission which give personal data the same protection as it has in the EEA.
Where we use third parties based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection for personal data shared between the EEA and the US.

If you have any questions in relation to this section, please contact data.protection@mbplc.com.

We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  We have also 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.

Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.

We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining 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.

We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary.  Details of retention periods for different aspects of your personal data are available by contacting us [link].

In certain circumstances, you may have the right to request access, transfer, rectification and/or erasure of the personal data that we process about you. You may also have the right to object to and/or restrict our processing of your personal data.  Details of the rights are set out below.

Human intervention: you may request human intervention where a decision has been made about you based solely on automated processing, and/or you may challenge that decision (this may happen in the context of our recruitment process where we collect information relating to whether or not a candidate has unspent criminal convictions).
Access: you may request access to your personal data, which enables you to receive a copy of the personal data that we hold about you and to check to see if we are processing it lawfully.
Transfer: you may request that we transfer your personal data to you or 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. Please 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.
Rectification: you may request rectification 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.
Erasure: you may request erasure of the personal data that we hold about you.  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: you may object to how we are processing 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.
Restriction: you may request that we restrict how we process 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.
Withdrawal of Consent: where we have relied on your consent to process your personal data you will have the right to withdraw your consent at any time.  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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise any of these rights please contact us using the details in paragraph 2.

 

The ICO regulates most UK data and information laws.  To learn more about your rights, visit the ICO website at www.ico.org.uk.

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