• provide your contact details when you visit one of our pubs in order to assist the NHS England Test and Trace, NHS Wales Test, Trace, Protect and NHS Scotland Test and Protect programmes;

• apply to become a tenant/operator at one of our pubs;

• take on the role of tenant/operator at one of our pubs;

• act as a guarantor to support a tenant/operator’s application;

• visit our website (“Website”);

• visit a venue where we sponsor the Wi-Fi services (“Wifi Services”);

• use social media profiles where you have agreed for data to be shared with us (“Social Media Platforms”); or

• generally engage with us including by contacting us via our Website, email or telephone with an enquiry or complaint,  taking part in a competition or purchasing products or services from us (“Engagement”).

Identity Data

name, username, title and place and date of birth and personal characteristics including age and gender

Contact Data

billing address, delivery address, email address and telephone numbers

Applicant Data

work history, qualifications. National Insurance number, right to work documentation and proof of identity

Financial and Transactional Data

credit history, bank account and card payment details, and details about payments as well as products and services purchased from us

Profile Data

preferences, feedback, survey responses and interests including activities noted on Social Media Platforms (for example, Facebook likes/groups)

Technical and Usage Data

information about how you use our products, services, Website and the Wifi Services such as internet protocol (IP) address, cookies, mobile device ID, any login data, browsing history, browser type and version, time zone setting and location, viewed pages with date and time stamp (log information), browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website

Marketing and Communications Data

preferences in receiving communications and marketing from us

Location Data

GPS-based location information from your use of our Website, the Wifi Services or Social Media Platforms via your smartphone(s), tablet(s) or other devices

Photo and Video Data

Photos and or video footage of you captured when you attend any events hosted or sponsored by us in one of our pubs or elsewhere (your attention will always be drawn to any photography or filming that is taking place, and your consent will be obtained where required)

Inferred Data

which is inferred or derived from the data we collect, for example inferences about your interests based on your Identity Data or Location Data

• To comply with our legal obligation to collect contact details of visitors to our venues in order to assist the NHS England Test and Trace, NHS Wales Test, Trace, Protect and NHS Scotland Test and Protect programmes and help to contain the spread of COVID-19.  We will only share details collected about you for this purpose with NHS England Test and Trace, NHS Wales Test, Trace, Protect or NHS Scotland Test and Protect if requested, and your details will not be shared or used for any other purpose;

• To verify if you would be a suitable tenant/operator (in response to your application) – this includes using the information that you have provided for the purposes of verifying your identity and carrying out anti-money laundering and credit checks against you (this may include use of a credit reference agency or other third parties);

• To perform a contract we have in place with you, including managing payments, fees and charges and delivering the requested product or service;

• To enable you to make bookings at our managed outlets;

• To communicate with you – this includes where we manage our relationship with you, where we respond to complaints or enquiries, where we invite you to events, or where we make suggestions to you about various products and services that you could benefit from;

• To improve our services to you – this includes asking you to complete surveys about how we can improve the services we offer you and/or the application process, recording customer calls to our Customer Hub for quality and training purposes, or asking you for information on how we can improve our Website or our Engagements with you;

• To maintain and optimise our Website – this includes where we need to solve performance issues, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to improve the availability of the Website and to secure the Website against fraud;

• To protect our business and prevent or detect crime – this includes recording calls that are placed with our Customer Hub for fraud prevention purposes, and the use of CCTV across our managed pub estate;

• For data analytical purposes in order to improve our products/services, marketing, customer relationships and experiences;

• To improve our marketing strategies so that we can send you relevant offers and content; by creating individual profiles and profiled audience segments so that we can tailor our content to you, in particular when we sponsor Wifi Services or use data management platforms; and by using Location Data to send targeted content based on your location;

• To improve our marketing strategies by ‘matching’ data we have collected, such as your e-mail address, with your profile on a Social Media Platform so that we can show you marketing content which may be of interest to you (for example, by using Facebook Custom Audiences);

• To improve our internal business processes by giving our colleagues the tools to develop their skills (including through monitoring call quality); and

• To satisfy our legal obligations and to defend and exercise our legal rights.

Legitimate Interest as a business means conducting and managing our business to enable us to give you the best service and to promote and grow our business. 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 will not use your personal data for activities unless we have a compelling interest which is not overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, such as entry into a promotion or subscription to a particular service, or to take steps at your request before entering into such a contract.

Compliance with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, such as anti-money laundering legislation.

With your consent, this can only be relied on by us as a legal basis for processing where your consent has been freely given, is unambiguous and clear (i.e. you have actively opted into a service we provide by ticking a box). If you provide us with your consent to process your data at any point on our Website or in connection with the Wifi Services or on a Social Media Platform, you can withdraw it at any time, and we will stop all processing activities that were based on consent as a legal basis for processing. Please note we may still process the data if we have another lawful basis for processing (in most instances, this will be for a more limited purpose e.g. back-up storage or to record a withdrawal).

• service providers such as solicitors, accountants, surveyors, stock takers, providers of property repair and property security services, payment processing providers and distributors who assist us to ensure that we meet our legal and regulatory obligations (e.g. property maintenance, health and safety, tax and pubs code compliance), and in order to fulfil our obligations under the terms of our tenancy agreements;

• suppliers such as coffee suppliers, satellite TV (SKY), WiFi (BT) and web-hosting companies in order to fulfil any requests that our tenants have made for those services;

• credit reference agencies (“CRA”) - where you submit an application to become one of our tenants, we will supply your personal information to a CRA, and they will give us information about you, such as your financial history, for the purposes of carrying out identity and credit checks against you. Please note that CRAs may also share your information with other interested parties for credit reporting purposes. The identities of CRAs and details of the ways in which they may use your personal information are explained in more detail online at https://www.experian.co.uk/crain/index.html.

• Independent debt recovery and tracing agencies for the purpose of collecting monies due or outstanding on our tenants’ accounts;

• regulators (Pubs Code Adjudicator), local licensing authorities, the Health & Safety Executive, the Police and HMRC, to comply with any legal or regulatory requirements or investigations;

• NHS England Test and Trace, NHS Scotland Test and Protect or NHS Wales Test, Trace, Protect in connection with the collection of contact details at our pubs for COVID-19 contact tracing purposes;

• operators of our managed outlets for the purposes of fulfilling table bookings that you have submitted through our managed outlet websites;

• first and third party advertising companies and media agencies for marketing and research purposes;

• marketing agencies based within and outside the EEA and UK who provide promotional and prize fulfilment services on our behalf;

• our data storage provider(s) based within the EEA and UK who securely stores consumer data obtained through competitions on our behalf;

• our data management platform provider, Relay42, who provides us with marketing strategy services;

• third party providers of social media platforms (including Facebook) and the Wifi Services (including Wireless Social);

• courts, parties to litigation and professional advisers where we reasonably deem it necessary in connection with the establishment, exercise or defence of legal claims;

• our technical dispense equipment service provider, Serviced Dispense Equipment Limited, and their subcontractor, Innserve Limited, to install, maintain and remove dispense equipment;

• our insurance claims manager, QuestGates, and our insurance companies for the purposes of valuing and making insurance claims; and

• a purchaser or parties interested in purchasing any part of our business.

Object to processing of 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 overrides your rights and freedoms.

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you;

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, or where you have successfully exercised your right to object to processing (see box above);

• Request restriction of processing of 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;

• Request the transfer of your personal data to you or to 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. 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; and

• Withdraw consent at any time where we are relying on consent to process your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

To collect your contact details when you visit one of our pubs in accordance with our legal obligation to assist the NHS England Test and Trace, NHS Wales Test, Trace, Protect and NHS Scotland Test and Protect programmes

• Identity

• Contact

Limited to first name, surname, telephone number, the date, time and name of the pub visit

To comply with our legal obligation to conduct contact tracing in Scotland, England and Wales

21 days from the date of collection

To process your application to become a tenant/operator in one of our pubs

• Identity

• Contact

• Applicant

Necessary for our legitimate interests (recruitment of tenants/operators and internal administration)

6 months after notification to you that your application was unsuccessful, or 6 years following the termination of the tenancy agreement if successful

To register you as a new tenant/operator if your application is successful

• Identity

• Contact

• Applicant

Performance of a contract with you

6 years following the termination of the relationship

To add unsuccessful applications to our talent bank of excellent candidates so that we can contact you when suitable opportunities to become a tenant/operator of one of our pubs arises

• Identity

• Contact

• Applicant

Consent, where expressly provided by you

Contact details are removed from our talent bank after three unresponsive contacts have been made to you, or if you notify us that you no longer wish to be contacted by us (whichever is the earlier)

Where we perform the contract we have in place with you for the purchase of products, including managing payments, fees and charges

• Identity

• Contact

• Financial and Transactional Data

Performance of a contract with you; and

To perform our legal obligations

After the duration of your contract with us has expired, our online sales records will be retained by us for 7 years or longer if required by tax or corporate bookkeeping

To deter crime and ensure the personal safety and security of visitors and staff through the use of CCTV in our managed pub estate

• Identity

Necessary for our legitimate interests (to protect the safety and security of visitors and staff at our sites and assist in criminal investigations)

Video footage will be retained for a limited time before it is automatically deleted.  The retention of CCTV is determined by any specific requirements as specified by the local licensing authority in the premises licence, as well the need to investigate health and safety incidents or criminal incidents, including in connection with any legal proceedings or requests from law enforcement authorities

To manage our relationship with you and communicate with you, which may include:

• responding to any complaints or specific requests made by you;

• liaising with you in relation to any incidents at one of our pubs;

• sending you newsletters or alerts that you have asked to receive;

• notifying you about changes to our terms or privacy policy

• Identity

• Contact

• Profile

• Usage

• Marketing and Communications

Performance of a contract with you; and

Necessary for our legitimate interests (for running our business)

Customer services will retain all information for 1 year from when the compliant/issue/incident is resolved

If you no longer wish to receive any e-mails/alerts from us, you can unsubscribe at any time, and we will remove your email address within 30 days of receiving your unsubscribe notification, unless it requires to be retained for other purposes as listed in this privacy notice

To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

• Identity

• Contact

• Technical and Usage

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and

Necessary to comply with a legal obligation

26 months from Website visit

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences

• Technical and Usage

• Location

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

26 months from Website visit

To improve our marketing strategies and create individual profiles and profiled audience segments (including custom audiences), and to enrich existing profiles using third party data, so that we can issue tailored marketing content and offers, including sending you targeted content based on your location.

• Identity

• Profile

• Technical and Usage

• Marketing and Communications

• Location

• Inferred Data

Consent

Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable.

To send you online advertisements or marketing which isn’t tailored to you but forms part of a wider brand campaign or initiative.

• Identity (limited to age and gender)

• Profile

• Marketing and Communications

Necessary for our legitimate interests (to maintain the relevance of our brand and reputation and to grow our business by serving consumers with advertising relating to our brands).

Where required by privacy laws, Consent

Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable.

To conduct market research with unsuccessful or withdrawn candidates

• Identity

• Contact

• Applicant

Necessary for our legitimate interest (to improve and streamline application process)

2 weeks after notification to you that your application was unsuccessful / after you have withdrawn your application (as applicable)

To send you direct electronic marketing (i.e. via SMS, email or direct messaging through social media platforms) relating to our brands which we consider may be of interest to you.

• Identity

• Contact

• Profile

• Marketing and Communications

Consent

Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable.