Privacy Policy

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in https://bookthepub.com/legals/privacy-policy/ and it is important that you read that information.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy https://bookthepub.com/legals/privacy-policy/

YES I consent to the installation of the App for the purposes set out in the https://bookthepub.com/legals/privacy-policy/

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us using the contact details we provide to you but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Book the Pub Ltd (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our end-user licence agreement as set out at https://bookthepub.com/legals/eula/ (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

• The Book the Pub website and mobile application software (App) available on our site hosted on www.bookthepub.com (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED?

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

GLOSSARY

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Important information and who we are

Book the Pub Ltd is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Book The Pub Ltd
• Company number: 13377397
• Name or title of data privacy manager: Thomas Caloe
• Email address: info@bookthepub.com
• Postal address: Number 7 Rosemary Lane, Louth, LN11 9NS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 8th November 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data

We explain these categories of data https://bookthepub.com/legals/

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App 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 policy.

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. Whilst we may enable free-text or other areas where you may choose to submit this kind of information, if we see it we will usually delete it and we will not actively take any steps to associate that information with you directly. If you share this kind of information with any third parties using the functionality we make available to you then you acknowledge that it will be that third party who processes your information in that context. We retain the right to delete any Special Category Personal Data you submit from time to time.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions or enter a competition, promotion or survey. This may also include information you provide when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. We only collect first party analytical data using cookies, and our third party cookie providers may also derive some aggregated information from those cookies, as further described in the section of this policy below which sets out the third parties whom we share information with.
• Location Data. We also use Google Location Services (where you have consented to turn this on on your Device) to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings Device settings or by amending your settings at https://myactivity.google.com/activitycontrols?pli=1. We may also allow you to set your location manually by placing a pin, entering a postcode or city, or some other method, and in each case this will require you to take a positive affirmative action to input that information and we will let you if that information will be publicly viewable or not at the time.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Device Data from the following parties:

analytics providers such as Google Ireland Limited based inside the UK and the EEAand ActiveCampaign, LLC based in the USA;

advertising networks such as Facebook Ads, Linkedin Ads based outside the UK; and

search information providers such as Google Analytics operated by Google LLC based outside the UK Google’s privacy policy can be found at www.google.com/policies/privacy/partners/.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Inc based in the USA and Stripe Ireland Limited based inside the EEA;
• Identity and Contact Data from data brokers or aggregators based inside the UK; and
• Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK;

Cookies

We use cookies and other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. We use certain cookies in order to make parts of our Services work smoothly, and some of those we consider “Essential” to making the Services work. We do not require your consent for cookies that we consider to be Essential in this way. Where we capture any information using cookies that we don’t strictly need to make our Services work, we will only do this where we feel that your privacy rights aren’t unfairly prejudiced and if we aren’t sharing that information with anyone else and where we use it strictly for the legitimate reasons and purposes set out in this policy. We use Google Analytics in order to measure the way that users interact with our services so that we can make decisions about how we take our business forward. Google does not receive any personal data that they could use to identify you without your express consent when these cookies are used, but they might receive aggregated information that isn’t considered in law to be  “Personal Data”. To find out more about Google’s use of your data, you can visit their privacy policy at www.google.com/policies/privacy/partners/.

How we use your personal data

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

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered 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.

See Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent or if you haven’t opted out of marketing in relation to a particular channel and if you were given an opportunity to opt-out at the time (this is known as a soft-opt-in). Where we rely on the soft-opt-in basis for sending you marketing, we will only send you marketing that is relevant to our own Services and your data will not be shared with third parties for their own marketing purposes. You can opt-out at any time by contacting us.  You also have the right to withdraw any consent you may have given us at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. The only exception to this is where you use our Services to specifically request to be contacted by a particular third party business or other user of ours who you’ve connected to via the Services (and that third party may deem your contact to be permission to send you marketing about their own services, subject to their own privacy policy, where applicable). We will never sell your personal data to third parties who you you’ve never met, or requested to be contacted by, for the purpose of their own marketing activities.

Purposes for which we will use your personal data

Disclosures of your personal data

When you provide us with your personal data, we may share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table Purposes for which we will use your personal data
• 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 policy.

International transfers

We do not transfer your personal data outside the UK, although our third party IT Service Providers may access it or provide back-up services from other countries within the EU or from a country that has been deemed to provide adequate protection for your Personal Data equivalent to the level of protection it receives in the EU and the UK.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

Certain Services include public profile, social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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

In some circumstances we will 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.

In the event that you do not use the App for a period of two (2) years then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer or your personal data.
• Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at info@bookthepub.com.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. Withdrawing consent doesn’t affect the legality of any processing that has already taken place, but it does mean that no further processing can take place without your further consent except to the limited extent that we need to retain certain data to record the fact that you have withdrawn your consent to something, and strictly in accordance with our other legal duties.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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 contacting us.

Performance of Contract 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties

There are none yet, but if we do eventually become part of a wider corporate group then we may need to share data internally with those other group members, but only for the same purposes we would have processed the data for ourselves (for example, for IT and system administration services or leadership reporting within the group).

External third parties

Our Services enable you to connect with various third parties, and you may choose to provide those third parties with personal data as part of their provision of services to you as their customer. We will only share limited Personal Data with these third parties on the basis that you are looking to enter into a contract with them and only for the purpose of that third party entering into a contract with you or as set out in their privacy policy. We don’t control what policies a third party has in place so it is up to you to determine whether or not that is a good decision for you as an individual in each instance. We have contracts in place with the third parties we link to via our Services which require them to process your data in accordance with applicable laws.

ActiveCampaign, LLC (including ActiveCampaign Ireland Limited) who operate and administer the marketing platform that we use, who are based in the United States of America (with offices in the EEA). ActiveCampaign are processors acting under our instructions and supply us with IT services. Their privacy policy is available at https://www.activecampaign.com/legal/privacy-policy. ActiveCampaign, LLC ensure that any transfer of information to the USA is protected in accordance with the EU Standard Contractual Clauses for international data transfers.

WPMU Dev which is a trading name of Incsub, LLC based in Alabama, USA, who act as a processor under our instructions. Incsub, LLC provide us with technical services and their privacy policy is set out at https://incsub.com/privacy-policy/.  

Service providers acting as processors based in England, Scotland, Wales, Northern Ireland, the Republic of Ireland and the wider European Economic area where the GDPR applies who provide IT and system administration and other support 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 and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances. For example, we might share your personal data with the Information Commissioners Office (the “ICO” – the UK’s regulator for personal data) where we are legally required to do so, or where we are trying to comply with any applicable laws or assist in the investigation or reporting of data breaches and data subject access rights requests, including where we are seeking guidance from the ICO as to how to deal with our obligations or your queries.

Your legal rights

You have the right to:

• 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 and to check that we are lawfully processing it.
• 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, though we may need to verify the accuracy of the new data you provide to us.
• 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. 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 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 override your rights and freedoms.
• 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:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • 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.
• 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

• Identity Data: [first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender].
• Contact Data: [billing address, delivery address, email address and telephone numbers].
• Financial Data: [bank account and payment card details].
• Transaction Data: includes [details about payments to and from you and details of in-App purchases].
• Device Data: includes [the type of mobile device you use,] [a unique device identifier [(for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device)],] [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION].
• Content Data: includes information stored on your Device, including [friends’ lists,] [login information,] [photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].
• Profile Data: includes [your username and password, in-App purchase history, your interests, preferences, feedback and survey responses].
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, [traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access].
• Marketing and Communications Data: includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
• Location Data: includes [your current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]].