Our websites and apps aren’t intended for children under the age of 13 and we don’t knowingly collect data relating to children.
Hawthorn Leisure is made up of different legal entities and outlets. This privacy notice is issued by Hawthorn Leisure, a registered limited company registered in England and Wales with company number 08791672 and whose registered office is at Touchstone, Pinewood Business Park, Coleshill
Road, Birmingham, West Midlands, B37 7HG
By contacting us, using our services or visiting our website, which is owned and controlled by us, you are accepting and consenting to the practices described in this policy unless you inform us otherwise. For any questions relating to this privacy notice, including any requests to exercise your legal rights, please contact us using the details below
Our full details are email@example.com, Touchstone, Pinewood Business Park, Coleshill Road, Birmingham, West Midlands, B37 7HG
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 may change this policy from time to time as the law and/or our business changes and develops. We will endeavour to inform you consent to receiving communication from us. Otherwise, please look out for notifications on the website which indicate we have made a change. If you continue to use our
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 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, we encourage you to read the privacy notice of every website 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:
Through our websites, we do not collect any Special Categories of Personal Data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and information about your health and genetic and biometric data. We also do not knowingly process any
data relating to children. See section 3.2 for further detail
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.
You don’t have to give us any of your personal data but, if you don’t, you are unlikely to receive our optimal customer service experience. 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, ie. Any reservations or loyalty sign up.
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 your relationship with us.
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.
3.1 We only collect and process Sensitive Data where you provide such information to us in the following situations:
3.1.1 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 one of our venues (i.e. suspected food poisoning or another health and safety incident),
– Where you believe we have been discriminatory against you (i.e. 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.
3.1.2 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. 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.
3.2.1 We only collect and process Children’s Data in the following situations:
– For enquiring about, and booking, children’s parties and events. 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)
– 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;
– Where a child aged 13 or above logs into our WiFi network, we collect Identify Data, Contact Data, Technical Data, and Usage Data (however, only customers aged 18+ can register for a customer account with us).
We are allowed to process Children’s Data where it is required for our legitimate interests (offering and hosting children’s parties and other events in our venues, dealing with feedback and complaints, understanding how customers interact with our 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 use different methods to collect data from and about you including through:
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:
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.
We may receive personal data about you from various third parties and public sources as set out below:
We only process your personal data when allowed to do so by law. Most commonly, we will process your personal data:
|Activity||Personal Data||Basis for Processing|
|To register you as a new customer and manage your account: including to receive news, offers, promotions, to receive a voucher, to enter a prize draw or survey||Identity Data, Contact Data, Profile Data, Marketing & Communications||To perform our contract with you. We can’t process the activity if we don’t know who you are. We have a legitimate interest to study how customers use our products and services, to develop them and grow our business|
|To tailor our marketing to you including SMS, Push Notification and Email.||Identity Data, Contact Data, Technical Data, Transaction Data, Usage Data, Profile Data, Marketing & Communications Data||We have a legitimate interest - to make it easier for you to be informed and to tailor our marketing and business strategy to customer needs. Being able to offer you services related to what we have previously provided you. And for new customers, with your consent when you sign up for the new information.|
|To understand our customers, using various sources to build a profile of you; this may include:
understanding your habits, your location, your personal circumstances, and the things you
may like or dislike.|
The ways you interact with us, such as subscribing to news, offers, promotions and updates, completing surveys, entering competitions, using our Wi-Fi, 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||This is a legitimate business interest, being to develop our business, products, services, relevant campaigns and tracking the effectiveness of our tools and campaigns.|
|To process and deliver a product or service that you have ordered from us, including: 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 children’s parties and events).||To perform our 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 event tailored to your child.|
|To take payments and give refunds.||Financial data.||To perform our contract with you.|
|To send you service messages, such as when we need to tell you about an update our privacy notice.||Identity Data, Contact Data.||We’ve got a legal obligation to provide you with updated privacy notice information.|
|To process any pub applications via our website||Identity Data, Contact Data, Financial Data, Profile Data||Necessary for our legitimate interests, being to appoint the right person in line with our Recruitment Policy. To access a copy of this, please contact us.|
|To provide customer service and support.||Transactional Data, Identity Data, Contact Data, Profile Data, Sensitive Data (where this is provided by you)||To perform our contract with you. You expect (and we want to deliver) the best possible customer service.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have said that we can send them to you when you provided us with your details when you entered a competition, signed up for a newsletter, loyalty scheme or used our Wi-Fi.
You can tell us that you want to stop receiving marketing communications from us at any time. You can do this by clicking on the unsubscribe link in any email we send you or by contacting us directly by email to firstname.lastname@example.org post or over the phone.
We’ll process any such request as quickly as we can, but it might take a few days for all of our systems to be updated.
We will only use your personal data for the 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. We regularly review and, where necessary, update our privacy information, if we need to use your personal data for a new purpose, we update our privacy information, we will notify you and we will explain the legal basis which allows us to do so.
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.
We do not and will not, sell any of your personal data to any third party – including your name and contact details and your payment information. We’re committed to protecting your privacy – we want to earn and maintain your trust, and we believe this is absolutely essential in order do that.
We cannot however, 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 above.
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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Sometimes we might need to transfer your personal data to third-party processors outside the European Economic Area (EEA) – for example, this might be required to process your payment details or provide support services. We will only do this if there are appropriate safeguards in place to make sure your personal data receives the same protection as when it is being processed inside the EEA.
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.
To determine 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.
In some circumstances, you can ask us to delete your data: see the section detailing your legal rights below for further information. In some circumstances, we may 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.
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.
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.
You have lots of legal rights relating to your personal data. 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.
The ICO regulates most UK data and information laws. To learn more about your rights, visit the ICO website at www.ico.org.uk.
We may need to request specific information from you to help us 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 in relation to your request to speed up our
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.