Privacy, Data Protection and Cookies Policy
Introduction
Welcome to Reddington Pub Company Limited’s (RPC/ we/ us) data protection, privacy and cookies policy. We trade as the “Reddington Group of Pubs”, which includes The Reindeer Hoveringham, Nottinghamshire (Reindeer) and Old Volunteer, Caythorpe,
Nottinghamshire (Old Vol) (together referred to as Our Pubs).
RPC respects your privacy and is committed to protecting your personal data. This policy
together with our Terms of Use and any other documents referred to in it, set out the basis on which any Personal Data (as defined below) we collect from you or which you provide to us will be processed by us as a result of using or interacting with our websites as set out below.
RPC aims at all times to process and collect your data lawfully, transparently, fairly and
without adversely affecting your rights as a Data Subject (as defined below). Please read
the following carefully to understand our practices and procedures. The websites we
operate are: www.reindeerpub.com , its related domains and sub domains (Reindeer Site), which is hosted by Word Press in respect of the Reindeer and www.oldvolpub.com, its related domains and sub domains (Old Vol Site) in respect of the Old Vol which is hosted by Word Press. The Reindeer Site and Old Vol Site are collectively referred to as “Our Sites” in this policy.
We also operate a mobile app at the Old Vol which enables our customers to order food and beverages. The app is accessed via a QR code. (Our App)
Please note:
By giving your consent, you are accepting and consenting to the practices described in this policy. If you do not give your consent, please navigate away from Our Sites or Our App (as the case may be).
You may withdraw your consent at any time. An explanation of your rights is set out below.
For the purpose of the Data Protection Legislation (as defined below), the data controller is Reddington Pub Company Limited, a company registered in England and Wales with company number 13641783, whose registered office is at Unit 13e, 92 Burton Road, Sheffield S3 8BX.
Our nominated representative, as Data Privacy Manager is Maxine Griffiths- Parker for the purpose of the Data Protection Legislation.
If you are not satisfied with any action taken by us or response given, you have the right to complain to Information Commissioner at www.ico.gov.uk, or help line telephone number: 0303 1231113.
Definitions
In this policy the following terms shall have the following meanings:
Cookie: a small file placed on your computer or device by Our Sites when you visit certain
parts of Our Sites and/or when you use certain features of Our Sites.
Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC
Directive) Regulations 2003.
Data Protection Legislation: all applicable legislation relating to the privacy of personal
data in the UK including the UK GDPR and the Data Protection Act 2018 (or any
replacement or successor legislation).
Data Subject: a natural identifiable person.
personal data: has the meaning set out in the Data Protection Legislation, being as at the
data of this policy, any data which identifies a natural person (by way of example, name,
address, phone number and so on).
What this policy also covers
This policy also explains:
● What personally identifiable information of yours is collected:
− on Our Sites, when you interact with either one of them;
− when you download from either one of Our Sites;
− when you interact with either one of Our Sites including making an enquiry or
a booking.
● What organisation is collecting the information;
● How the information is used;
● With whom the information may be shared;
● What choices are available to you regarding collection, use and distribution of the
information;
● What kind of security procedures are in place to protect the loss, misuse or alteration
of information under RPC’s control;
● How you can correct any inaccuracies in the information; and
● How you can request the information we process and store to be removed.
There are other terms that may apply to you
In addition to this policy, please refer to our Terms of Use, terms of booking and group
booking/ event terms (Our Other Terms) Some or all of Our Other Terms may apply when you book a table or event with us and, buy goods and services from us.
We may make changes to these terms and our website and your duty to inform us
We may update and change these terms, Our Sites and/or Our App from time to time for a
variety of reasons. By way of examples: to reflect changes to the products and services we offer, user’s needs, regulatory or legal requirements. Every time you wish to use or interact with either one of Our Sites or Our App, please check these terms to ensure you understand the terms that apply at that time. These terms were updated on 24 May 2024.
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.
Children under the age of 18
In accordance with licensing and other applicable laws, persons under the age of 18 are not eligible to buy our goods or services and we ask that minors do not submit any personal information to us. We will not knowingly accept any data from a person who is under the age of 18 years.
By using one of Our Sites or Our App, you are confirming your are 18 years of age. We
reserve the right at all times to ask for verification of your age (including identification) and we may in our absolute discretion refuse entry to the Reindeer and Old Vol and refuse to sell alcoholic beverages.
The data we collect from you
We may collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier and
date of birth. .
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other
details of bookings you have made and goods and services you have purchased
from us.
• Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and
versions, operating system and platform, and other technology on the devices
you use to access this website.
• Profile Data includes your username and password, purchases or orders made
by you, your interests, preferences, feedback and survey responses (if applicable).
• Usage Data includes information about how you use Our Sites or Our App, and
our products and services.
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
The data we collect from you
We may collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, username or similar identifier and
date of birth. .
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other
details of bookings you have made and goods and services you have purchased
from us.
• Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and
versions, operating system and platform, and other technology on the devices
you use to access this website.
• Profile Data includes your username and password, purchases or orders made
by you, your interests, preferences, feedback and survey responses (if
applicable).
• Usage Data includes information about how you use Our Sites or Our App, and
our products and services.
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
We may 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 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 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.
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 not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods 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.
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 Identity, Contact and Financial Data
by filling in forms or by corresponding with us by post, phone, email, via Our
Sites, Our App or otherwise. This includes personal data you provide when you :
• make an enquiry with us for a booking, event and/or to buy goods and/or
services;
• order food and beverages from us via our App;
• enter into a contract with us at either the Reindeer or the Old Vol for a table or
event, for the supply of goods and services;
• request marketing to be sent to you;
• interact with us on social media; or
• give us feedback or contact us.
Please note: We may also record images of you on our CCTV when you visit
the Reindeer and the Old Vol. Your car number plate may also be recorded.
We use CCTV for the detection and prevention of crime.
• 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 the following parties:
(a)
analytics providers such as Google based outside the UK; and
(b)
Word Press.
Use of your information
We will use the data collected about you in the following ways:
• to provide goods and services to you, to perform our contract with you;
• to provide information about our businesses, products or services which may be of
interest to you when you have given us consent to contact you for marketing
purposes;
• improve the efficiency of Our Sites and Our App;
• to develop goods or services;
• to notify you of changes to our goods or services;
• to understand our customer requirements and preferences, perform analysis and
comparisons;
• to administer and update Our Sites and Our App, to ensure it runs smoothly on your
hardware;
• to offer you support in the event that you have problem or an issue with Our Sites or
Our App;
• to comply with any legal or regulatory obligations we may have for example to
HMRC; and
• where it is in our legitimate interest to do so, where we have considered and
balanced any potential impact on you. For example, where our insurers have
requested that we retain information.
Please see further details in the table below and please also refer to the “Cookies” section.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. As referred to above, we will only contact you for marketing purposes where you have given your express consent.
You may withdraw your consent at any time by contacting us at : admin@oldvolpub.co.uk
Where we store your personal data
• Although the data we collect from you is stored in the European Economic Area ("EEA"), data transferred to third parties to perform our contract with you may be transferred to third parties outside the EEA. By submitting personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
• As referred to above, all information you provide to us is stored on our secure servers via Word Press.
• In addition, we use SSL (Secure Sockets Layer) technology to encrypt the data on the
Our Sites. The parties with whom we share your data to perform our contract with you
may have different arrangements in place.
• We take all reasonable technical, organisation and security steps to ensure that the information you supply to us over the internet is secure.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal, regulatory,
tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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,
regulatory, tax, accounting or other requirements.
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 and
insurance purposes.
In some circumstances you can ask us to delete your data (please 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.
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.
• 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.
How to exercise your legal rights: Please contact us at admin@oldvolpub.co.uk or write to us at our registered office.
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, we could refuse to comply with your request in these circumstances.
What we may need from you
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 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 a number of requests. In this case, we will notify you and keep you updated.
Disclosure of your information
You agree that we have the right to share your Personal Data with:
• Any member of our group, which means our subsidiaries, our ultimate holding company
and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Selected third parties including: business partners, our couriers, suppliers and sub-contractors for the
performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and
optimisation of Our Sites.
• To HMRC, regulators and other authorities.
• To a prospective buyer or seller if we sell or buy any business or assets.
• If any of the shares in RPC are sold or substantially all of its assets are acquired by a
third party, in which case Personal Data held by it about its customers will be one of the
transferred assets.
• If we are under a duty to disclose or share your personal data to comply with any legal
obligation, or to enforce or apply our terms of business or terms of use, and other
agreements; or to protect the rights, property, or safety of RPC, our customers, or others.This includes exchanging information with other companies and organisations for the purposes of fraud detection and credit risk reduction.
Cookies
All Cookies used by RPC on Our Sites are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
• Strictly Necessary Cookies (SNC) - a Cookie falls into this category if it is essential to the
operation of Our Sites, supporting functions such as logging in.
• Analytics and Flash Cookies (AFC) - it is important for RPC to understand how you use
Our Sites. For example, how efficiently you are able to navigate around it, and what
features you use. Analytics Cookies enable us to gather this information, helping RPC to
improve Our Sites and your experience of it.
• Functionality Cookies (FC) - enable us to provide additional functions to you on Our Sites
such as personalisation and remembering your saved preferences. Some functionality
Cookies may also be strictly necessary Cookies, but not all necessarily fall into that
category.
• Persistent Cookies (PC) - any of the above types of Cookie may be a persistent Cookie.
Persistent Cookies are those which remain on your computer or device for a
predetermined period and are activated each time you visit Our Sites.
• Session Cookies (SC) - any of the above types of Cookie may be a session Cookie.
Session Cookies are temporary and only remain on your computer or device from the
point at which you visit Our Sites until you close your browser. Session Cookies are not
deleted when you close your browser, to delete these cookies you will need to clear your browser history.
• Web beacons (WB) - certain pages on Our Sites and e-mails may contain small
electronic files known as web beacons. Web beacons permit RPC to monitor the volume
of users of Our Sites and the popularity of certain pages.
Before Cookies are placed on your computer or device you will be shown a cookie
compliance statement, requesting your consent to set those Cookies. By giving your
consent to the placing of Cookies you are enabling us to provide you with the best possible
experiences and services to you. You may wish to deny consent to the placing of the
Cookies at which point we request you cease using Our Sites.
In addition to the controls that RPC provide, you can choose to enable or disable Cookies
and the web beacons referred to above in your internet browser. Most internet browsers
also enable you to choose whether you wish to disable all Cookies or only third-party
Cookies. By default, most internet browsers accept Cookies, but this can be changed. For
further details, please access the help menu in your internet browser.
We have set out details of Cookies so that you can see what external tools we are using,
who provides these tools, what kind of data in form of cookies they are collecting, how long
this data is held and who has access to this data:
Essential Cookies, Functionality Cookies and Session Cookies
• wordpress_logged_in_[hash]: to indicate when you are logged in, and who you
are. This cookie is maintained on the front-end of the website as well when logged in.
• wordpress_test_cookie: to check if the cookies are enabled on the browser to
provide appropriate user experience to the users. This cookie is used on the front
end, even if you are not logged in.
• wp-settings-{time}-[UID]: to customize the view of your admin interface and the
front-end of the website. The value represented by [UID] is the individual user ID of the user as given to them in the users’ database table.
These cookies are strictly necessary without which the website will not function properly. you do not require any consent from users who visit Our Sites.
Persistent Cookies
They expire in almost a year after loading on the visitor’s system.
• comment_author_[hash]: remembers the value entered into the comment form’s
name field.
• comment_author_email_[hash]: remembers the value entered into the comment
form’s email field.
• comment_author_url_[hash]: remembers the value entered into the comment
form’s URL field.
Commenters cookie is only activated if the users give their consent to save the details.
A list of Google Analytics Cookies can be viewed via the following link:
https://business.safety.google/adscookies/
The optional cookies can be deactivated via our cookie settings.
You can also prevent the use of any cookies by the settings of your browser. However, this could affect the service functions and block also technically necessary cookies.
External Web Services and Links
We use a number of external web services on Our Sites to display content within our web
pages. If you make a booking with us, you will also be re-directed to Res Diary which is a third party application. Your use of Res Diary will be subject to their terms and conditions which can be accessed via the following link: https://www.resdiary.com/Terms
This is not an exhaustive or complete list of the services we may use, or might use in the
future, when embedding content, but these are the most common. We cannot prevent these third-party sites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads and so on.
Email tracking
Some emails that we send may have tracking on so that we can tell how much traffic those
emails send to Our Sites.
