- 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..............................................
- Data retention................................................................................
- Your legal rights.............................................................................
- Important information and who we are
Full name of legal entity: J D Wetherspoon plc
E-mail address: email@example.com
Postal address: Wetherspoon House, Reeds Crescent, Watford, WD24 4QL
You have the right, at any time, to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance, however, to deal with your concerns before you approach the ICO – so, please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed, should your personal data change during your relationship with us.
- The data we collect about you
Personal data, or personal information, means any information about an individual from which that person may be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity data includes first name, last name and title.
- Contact data includes your address, e-mail address and telephone number(s).
- Financial data includes, when booking a room, the card-holder’s name, card type, card number, issue date (not mandatory), expiry date, issue number and CVV number.
- In accordance with the payment card industry data security standard (PCI), this data is not held or stored by Wetherspoon or Guestline – it is passed straight to our merchant payment provider; as part of that process, it is removed from Guestline’s system.
- Transaction data includes details about payments to and from you and other details of products and services which you have purchased from us.
- Technical data includes Internet protocol (IP) addresses time zone setting and location, browser plug in types and versions, operating system and platform
- Usage data includes information about how you use our website, products and services.
We do not collect any special categories of personal data about you (this includes details about your race and ethnicity, religious and philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). We do not collect any information about criminal convictions or offences.
If you fail to provide personal data
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 be unable to perform the contract we have or are trying to enter into with you (for example, to complete a booking in a hotel room). In this case, we may have to cancel a product or service which you have with us, but we will notify you at the time, if this is the case.
- How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your name, contact and financial data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you, for example,:
- complete a form to give us feedback, lodge a complaint and/or incident or otherwise contact us.
- order food and/or drinks using the Wetherspoon app.
- book a hotel room.
- Scan a QR code or complete a form to provide contact information for the NHS Test and Trace contact tracing scheme or similar scheme to tackle COVID-19.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- technical data from analytics providers, such as Google, based outside the EEA
- contact, financial and transaction data from providers of technical, payment and delivery services such as PayPal/Braintree, based inside the EEA.
- Identity and contact information from third party providers which collect personal data for the contact tracing scheme to tackle COVID-19.
- How we use your personal data
We will use your personal data only when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (eg to complete a hotel room booking through the website).
- 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.
Generally, we do not rely on consent as a legal basis for processing your personal data. We do not send third-party direct marketing communications to our customers.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all of the ways in which we plan to use your personal data, along with which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing, including basis of
To register you as a new customer
Performance of a contract with you
To process and deliver your hotel booking, including:
(a) managing payments, fees and charges
(b) collecting and recovering money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To enable you to provide feedback, lodge a complaint or complete a survey
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to obtain feedback from our customers, process, investigate and respond to complaints and grow our business around our customers’ needs)
To use application improvement analytics to improve our website, products/services etc
Necessary for our legitimate interests (to keep our website updated and relevant and to develop our business)
|To collect personal data for a contact tracing scheme such as NHS Test and Trace or similar scheme developed for tackling COVID-19.
Necessary for legitimate interests of customers, our staff, our business and the public efforts to tackle COVID-19.
Change of purpose
We will use your personal data only for those purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the above table - Purposes for which we will use your personal data.
- External third parties as set out in the glossary.
- Specific third parties, namely:
- Guestline (Roomlinks/Rezlynx) – third party which administers hotel bookings
- Secure Trading – online payment gateway
- Braintree and Paypal – merchant payment provider
- Filter Digital – third party which manages, maintains and updates our website
- Airship Services Limited and any other third party which collects personal data for the sole purpose of the contact tracing scheme including the NHS Test and Trace or similar scheme for tackling COVID-19.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We permit them to process your personal data only for specified purposes and in accordance with our instructions.
We share your personal data with Braintree and PayPal. This will involve transferring your data outside of the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- We will transfer your personal data only to those countries deemed, by the European Commission, to provide an adequate level of protection for personal data. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they form part of the Privacy Shield, requiring them to provide similar protection as that for personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us, if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties with a business need to know. They will process your personal data only on our instruction and are subject to a duty of confidentiality.
We have implemented 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.
- Data retention
For how long will you use my personal data?
We will retain your personal data only for as long as is reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
By law, for tax purposes, we must keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers.
In some circumstances, you can ask us to delete your data: see your legal rights below for further information.
- Your legal rights
Under certain circumstances, you have rights under data protection laws, in relation to your personal data:
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 processing it lawfully.
Request correction of the personal data which we hold about you. This enables you to have corrected any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data which 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 our 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. However, please note that, for specific legal reasons which will be notified to you, if applicable, at the time of your request, we may not always be able to comply with your erasure request.
Object to processing of your personal data, where we are relying on a legitimate interest (or that 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 consider that it affects 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, where:
- you want us to establish the data’s accuracy.
- our use of the data is unlawful, yet you do not want us to erase it.
- 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.
- you have objected to our use of your data, yet 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 applies only 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 consent, we may be unable to provide certain products or services to you. We will advise you, at the time you withdraw your consent, if this is the case.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, if your request is clearly unfounded, repetitive or excessive. Alternatively, in these circumstances, we could refuse to comply with your request.
What we may need from you
We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month, if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure, before we process your personal data for our legitimate interests, that we consider and balance any potential impact on you (both positive and negative) and your rights. 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, by contacting us, further information about how we assess our legitimate interests against any potential impact on you, in respect of specific activities.
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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
External third parties
- Service providers acting as processors, based in the EEA, which provide IT and system administration services.
- Health and safety consultants and advisors, based in the EEA, which investigates accident and incidents and provides advice and consulting services.
- Professional advisers acting as processors, including bankers, auditors and insurers, based in the EEA, which provide banking, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers, based in the United Kingdom, which require reporting of processing activities, in certain circumstances.
- Airship Services Limited, based in the United Kingdom, which provides services for the collection of personal data for the NHS Test and Trace contact tracing scheme or similar scheme for the purpose of tackling COVID-19.