The Shepherds Rest

HIVE PUBS – PRIVACY NOTICE

Introduction

This privacy notice explains how we collect, store and use personal data about you when you visit our websites and our mobile, tablet and other applications (our “Websites”) and the terms of this notice apply to each of our Websites in whichever form you access them.

Please stop using our Websites if you do not want your data to be used as described.

IMPORTANT: if asked to do so, we will share certain guest and visitor information with NHS Test and Trace or NHS Scotland Test and Protect during the Covid-19 pandemic. 

Greene King

'Greene King', ‘we’, ‘us’ and ‘our’ are references to Greene King Brewing and Retailing Limited, who is the data controller in respect of the Websites and the processing described in this notice. Our ICO registration number is ZA054235. We have appointed a data protection officer whose contact details are provided at the end of this notice.

As the country's leading pub retailer and brewer, Greene King welcomes customers into our 3,000 pubs, restaurants and hotels across the UK and brews a range of award-winning ales. Our products and services trade under a wide range of well-known brands, including Greene King Pub Partners, HIVE pubs by Greene King, Greene King, Hungry Horse, Farmhouse Inns, Chef & Brewer, Flaming Grill, Greene King Inns, Greene King IPA and Old Speckled Hen. 

Our franchisees

HIVE pubs by Greene King is a franchised business in accordance with the Pubs Code etc. Regulations 2016 and certain of our pubs are operated by independent franchisees. In this notice, references to ‘we’, ‘us’ and ‘our’ do not include our franchisees. The franchisee is responsible for the personal data collected by it and you should refer to the privacy notice prepared by the franchisee of the relevant pub that you visit.

Purposes

We will process your personal data whenever:

you use our websites

we need to verify or record information about your identity

you book a room, table or function online

you make a payment, request a refund or redeem a voucher

you use our Wi-Fi service

you subscribe to newsletters or direct marketing

we carry out profiling

you enter one of our competitions

you submit queries, compliments or complaints to us

you take part one of our surveys

we record promotional videos or interviews or take photos

we record phone calls to our offices

we ask for other people’s personal data

More information about each of these scenarios follows next.

1 - When you use our websites

We use information about our website visitors and their visits to learn more about what our customers like and dislike and to target our direct marketing and advertising. See the profiling section of this notice and the cookie policy of the website you are visiting for more details.

2 - When we need to verify or record information about your identity

The UK government has asked pubs, hotels and restaurants to register information about their visitors during the Covid-19 pandemic. Therefore, the identity information you provide when making a booking online, together with the date, time and name of the venue you are visiting, will be recorded for this purpose.

If NHS Test and Trace or NHS Scotland Test and Protect request information from us about visitors, we will share the information they require, to help them to identify people who are at risk of infection. Personal information collected via our SMS-based guest visit registration scheme will not be used for any other purpose or shared with any other organisation.

3 - When you book a room, table or function online

We will use the information you provide to make and confirm your booking. We will record your IP address so we can check if the booking is likely to be genuine.

If you’re making a booking on behalf of a work colleague, we will ask for information about your organisation and the guest, so that we can invoice and bill the correct party.

If you tell us about dietary preferences, allergies, food intolerances or special access needs, we will use this information to help our franchisee to look after you during your visit.

If you provide us with information about birthdays, anniversaries or other celebrations that you want to commemorate during your visit, we will use this information to help make your celebration as special as possible. If you give us permission to do so, we will use this information to send you a reminder to book again when your next birthday or anniversary is almost due.

4 - When you make a payment, request a refund or redeem a voucher

We will use the information you provide to process your payment or refund. We do not keep records of payment card details.

5 - When you use our Wi-Fi service

We will use the information you provide to register you for and connect you to the service. When you first register, and each time that you connect to the service, we obtain additional information from your device and from the equipment used to provide the Wi-Fi service. This information describes where, when and how you registered or connected. We use this information to provide and maintain your connection to the service.

Please take these steps to prevent information sharing when you are not actively using the service:

Don't select the ‘connect automatically’ option if you want to avoid connecting and sharing information automatically whenever you are in range of our or another Sky partner's Wi-Fi service

If you chose to automatically connect to the service but have since changed your mind, either delete then recreate the Wi-Fi connection, or turn off Wi-Fi on your device whilst you are not using it

Check you have not saved your Greene King Wi-Fi connection settings before you let anyone else use your device

6 - When you subscribe to newsletters or direct marketing

If you permit us to do so, we will use the information you provide to select and send you messages containing special offers, discounts, promotions or any other type of information you have requested.

Every marketing message we send includes an unsubscribe link or similar opt-out mechanism.

Greene King Wi-Fi users can change their marketing preferences on the Wi-Fi app's Account Settings page at any time.

7 - When we carry out profiling

We use customer profiles to keep track of our customer interactions and learn more about their likes and dislikes. This helps us target our advertising and marketing and improve our products, brands and services.

The personal data we use in our profiles includes:

• Demographic information, such as your age, gender, address and postcode
• Purchase information, such as what you bought, how you paid and whether or not you took advantage of a discount
• Your likes and dislikes, such as what you drink, what you eat, whether or not you take advantage of special offers and whether or not you like what we post on our Websites and social media pages
• Information about family events and special occasions, such as the dates of birthdays, weddings and anniversaries
• Information about your visits to our pubs, restaurants and Websites, such as which ones you visit, when, how often and how long you stay for
• Information about your use of our services and whether or not you participate in our promotions, such as our Wi-Fi service, email clubs, loyalty schemes and any competitions you enter
• Information about how you respond to our marketing and advertising campaigns, such as whether or not you read our marketing messages, see adverts for the pub on social media or take up any of our special offers

If we get our profiling right, you will enjoy our products, services and brands more and more as we make improvements to them based on what we learn about you. And if you have signed up to receive direct marketing, you will get the special offers that we think will most appeal to you.

If you don’t want us to use your personal data this purpose, you can let us know using the contact details at the end of this notice.

8- When you enter one of our competitions

Please read our competition’s privacy notice before you submit your entry.

9 - When you submit queries, compliments or complaints to us

We will use the information you provide to deal with your enquiry and keep you informed about its progress. If you compliment a person or a team for their service, we will pass your compliment on to them and their manager, so that their achievement can be recognised.

Most complaints can't be resolved without discussing the matter with other people, so we may need to share information about your complaint with: the team at the pub you visited, or their area or regional manager; the management team of a contractor we have engaged; or other types of third party organisation. We will only share information with others when it's necessary to do so in order to investigate and resolve your complaint.

10 - When you take part in one of our surveys

Please read our survey's privacy notice before you participate.

11 - When we record promotional videos or interviews or take photos

We display signage at our venues to notify visitors whenever these activities are taking place. If you don’t want to be involved, please let a member of staff know on your arrival so that they can ensure your wishes are respected.

12 - When we record phone calls to our offices

We record some of the telephone calls we receive, including all of the calls to our Guest Relations team. If we intend to record your call, a recorded message will be played to inform you of this before recording commences. Your options for avoiding the call being recorded will also be explained.

We use suitable recordings anonymously, to train call handlers. We may review a recording if you or we are disputing a matter that the recording deals with.

13 - If we ask for other people’s personal data

Please refer them to this notice and ask for their permission to share their information first.

Retention

Information about	Is kept until
use of our websites	25 months from your last known interaction with us.
age verification checks	No information is retained, unless required for another purpose in this list.
identity verification checks	Information collected solely for the purpose of sharing with NHS Test and Trace or NHS Scotland Test and Protect is retained for 21 days from when it is collected.
online bookings	Booking information that you provide directly to a venue is normally held for 1 year from the end date of the booking. However, some of our venues use a booking diary and these diaries are kept for 2 years from the end of the calendar year. Contractual paperwork relating to bookings is kept for 2 years after the contract has concluded. When you make a booking online, we keep booking information for 13 months from the date of your last booking. However, if you opt in to receive direct marketing, this period is extended (see below).
payments, refunds and voucher redemption	6 years from the date of the transaction. Payment card details are not retained unless they are faxed to us by your booking agent, in which case they are held until the booking has been completed and paid for.
Wi-Fi usage	13 months from the date you last used our Wi-Fi. However, if you opt in to receive direct marketing, this period is extended (see below).
customer profile	13 months from your last known interaction with us, or for as long as you remain opted-in to marketing, then for a further 25 months from your last known interaction with us.
marketing preferences	These are kept indefinitely to ensure we can continue to respect your wishes.
competition entries	Normally 4 months after the end of the competition, but please check the rules for each competition before you enter.
queries, compliments and complaints	1 year from the date of the last correspondence on the matter.
guest surveys	See the survey's privacy notice.
promotional video, audio and photos	See the signage on display during the recording.
phone calls to our offices	3 months from the date of the recording.
exercising your data protection rights	12 months from the date of our final response to you.
information used in connection with an insurance or other legal action, proceeding or claim	6 years from the date that the action, proceeding or claim is settled.

 

Data Sharing

Other companies in the Greene King group

Whenever other companies in the Greene King group help us to provide our products or services, we may need to share some of your personal information with them. These companies are:

Company	Role	Registered Office
CK Asset Holdings Limited	The ultimate holding company of the Greene King group	8th Floor, Cheung Kong Centre, 2 Queen’s Road Central, Hong Kong
Greene King Limited	The holding company in the Greene King Group	Westgate Brewery, Bury st Edmunds, Suffolk, IP33 1QT
Greene King Retailing Limited	Operating companies that own pubs within the group
Spirit Pub Company (Managed) Limited
Spirit Pub Company (Trent) Limited
Greene King Services Limited	Companies that employee the group's employees
Greene King Retail Services Limited

Each of these companies is bound by the terms of this privacy notice and they are required to comply with our data protection policies. They are not permitted to use your personal data for their own purposes.

Other organisations who help us to provide our products and services

We work with a number of third-party suppliers and service providers. Many of these organisations process personal data in order to provide products or services to us, or on our behalf. See the Third Parties list for more details.

These organisations are bound by the terms of this privacy notice and they are also required to comply with our data protection policies. They are not permitted to use your personal data for their own purposes.

Clarabridge, Inc

11400 Commerce Park Drive, Suite 500, Reston, VA 20191, USA

Survey data

Sourcing and analysing survey data

USA, Privacy Shield

Dotmailer Limited

No.1 London Bridge, London SE1 9BG

https://www.dotmailer.com

Name, email address, DOB, contact preferences

Managing and distributing email marketing campaigns 

Experian Limited

Landmark House, Experian Way, NG2 Business Park, Nottingham NG80 1ZZ

www.experian.co.uk

Name, age, address, purchase information, engagement information (this information describes your use of our services and our websites)

For demographic segmentation and profiling 

Facebook, Inc

1 Hacker Way, Menlo Park, CA94025, USA

www.facebook.com/about/privacy

email address, address, DOB, marketing opt out status

Assisting with preparing, sending and monitoring marketing emails

USA, Privacy Shield

Google, LLC 

1600 Amphitheatre Parkway, Mountain View, CA 94043, United States

https://policies.google.com/privacy

Cookie information, IP address

Website analytics

USA, Privacy Shield

Inspire Protection Solutions Limited

Hilton Hall, Hilton Lane, Essington WV11 2BQ

Visual images

Managing, maintaining and operating CCTV 

Mercury Security Systems Limited

9 Bridgegate Centre, Martinfield, Welwyn Garden City, Hertfordshire, AL7 1JG

Visual images

Managing, maintaining and operating CCTV 

OR Multimedia Limited

50 Eastcastle Street, London W1W 8EA

www.ormlondon.com

IP address, MAC address, Cookies, Web browsing history

Managing and maintaining our websites and apps

Pointer Security  Scotland Security

65 North Wallace Street, Glasgow, Strathclyde, G4 0DT

Visual images

Managing, maintaining and operating CCTV 

Service Now Nederland

B.V.Hoekenrode 2, 1102 BR, Amsterdam Zuidoost, The Netherlands

Name, contact information, enquiry / complaint information 

Managing guest queries and complaints 

Sky UK Limited

Grant Way, Isleworth, Middlesex, TW7 5QD

https://service.thecloud.net

Name, age, address, email address, gender and mobile number

Providing the Wi-Fi service in our pubs and restaurants 

Veriserv Limited

Energy House, Attwood Road, Burntwood Business Park, BurntwoodWS7 3GJ

Visual images

Managing, maintaining and operating CCTV 

WorldPay (UK) Limited

The Walbrook Building, 25 Walbrook, London EC4N 8AF

www.worldpay.com/uk/

Name, address, payment card information

Making card-based payments and refunds 

Zonal Retail Data Systems Limited 

1 Tanfield, Edinburgh EH3 5DA

Name, contact details, booking information, loyalty card, transaction details, date of birth, email, telephone, payment details

Managing table bookings and reservations, till and voucher data, loyalty schemes and apps (including the order & pay app) 

Zone Limited

Western Transit Shed, 12-13 Stable Street, London N1C 4AB

IP address, MAC address, Cookies, Web browsing history

Managing and maintaining our websites 

In a Pub

PO Box 779 Banbury Oxfordshire OX16 6QQ

IP address, MAC address, Cookies, Web browsing history

Managing and maintaining our websites 

Smartsight CCTV

Unit 26 West Station Yard Spital Road Maldon Essex CM9 6TW

Visual images

Managing, maintaining and operating CCTV

Wireless Social

Sterling House Ackhurst Business Park Foxhole Road Chorley PR7 1NY

Name, age, address, email address, gender and mobile number

Providing the Wi-Fi service in our pubs and restaurants 

Other situations in which we may share your personal data

We will share your personal data if it is necessary to do so to comply with a legal requirement, such as with the franchisee or to comply with a condition attached to a premises license by a licensing authority.

We will share your personal data if it is necessary to protect our business interests, such as to enforce the terms of a contract, pursue an overdue debt or defend other legal rights.

We may need to share your personal data with an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, acquisition, restructuring or insolvency of any part of our business, provided that we inform any recipient that it must use your personal information only for the purposes disclosed in this privacy notice.

We may share your personal data where there is a legitimate interest to do so, for example, for the detection or prevention of crime, fraud or money laundering; to allow a regulator or ombudsman to investigate a complaint you have submitted to them; or to protect the rights of other people or organisations.

International data transfers

Before your personal data is transferred outside the UK, we implement at least one of the following safeguards:

Check whether the personal data is being transferred to a country that has been deemed to provide an adequate level of protection by the UK government. More information about this is available on the UK government website.

Where we use third parties based in the United States, check if they have signed up to the Privacy Shield framework. This framework requires signatories to provide a similar level of protection to personal data as would be the case if the personal data remained within the UK.

Use contractual clauses approved by the UK government which give personal data equivalent protection to that which it would have if processed in the UK.

If we are unable to apply any of the first three safeguards, we will try to contact you to ask for your consent before we transfer your personal data.

Lawful Bases

The lawful bases we rely on for our processing are:

Purpose	Lawful basis
When you use our websites	It is in our legitimate interests to provide a fully-functioning, accessible and useful website to our customers.
When we need to verify your age	We process this data to satisfy our legal obligation to not sell alcohol to anyone under the age of 18. It is in our legitimate interests to ensure that we do not market alcohol to anyone under the age of 18.
We need to verify or record information about your identity	This is sometimes due to a legal obligation imposed under the Licensing Act, or in the case of assisting NHS Test and Trace and NHS Scotland Test and Protect, their legitimate interest of being able to act quickly during the pandemic.
When you make an online booking, payment, request a refund, use our Wi-Fi or when we send you service-related communications	We process data to set up the contract, provide the services to you and notify you of any important changes to them.
When you subscribe to newsletters or direct marketing	We send marketing information to people who consent to receive it. We may also send marketing to customers who, when informed that we want to do so, choose not to opt out (soft opt-in). It's a legitimate interest to send direct mail marketing to let our customers know about our products, brands, services and any special offers we are running. Customers who no longer want to receive marketing can opt out at any time (please follow the instructions in the marketing messages we send you).
When we carry out profiling	This helps our business to develop by targeting our advertising and marketing and understand more about our customers like and dislikes, which are legitimate interests for us.
When you enter one of our competitions	Please see the privacy notice for the competition.
When you submit queries, compliments or complaints to us	Sometimes our processing will be necessary for us to meet the terms of the contract we have with you. Otherwise, it we will have a legitimate interest in dealing fully with the matter you have raised.
When you take part in one of our surveys	It is a legitimate interest to ask you what you think of our service, what we do well and what you think we can improve on, and act on that.
We record promotional videos or interviews or take photos	It is in our legitimate interests to take photos and video and recordings to promote our businesses positively via our marketing and press releases.
When we record phone calls to our offices	It's in our legitimate interest to be able to use suitable recordings to train call handlers and to be able to refer to recordings when that can help resolve a dispute.

The ICO have published a helpful guide to lawful bases for the general public which you can find here.

Safeguards

We protect the personal data we hold from theft, accidental loss, corruption and other threats that would have a negative impact on our customers. Our protective measures include:

Not collecting personal data that we don’t really need

Securely destroying or anonymising personal data when we don’t need it any more

Only allowing our employees and our suppliers to process the personal data they need to carry out their duties

Encrypting personal data to render it useless to anyone who is not authorised to access it

Making sure that staff are trained on how to handle personal data safely and securely and are fully aware of their personal responsibilities

Binding our suppliers and partners to the same standards and duty of care that we hold ourselves to

Protecting our websites, networks and IT systems from unauthorised access and from threats such as denial of service attacks, viruses and malware

Making periodic checks that these safeguards are working well and making improvements to them when we think we can do better

Your Rights

Data protection law provides you with certain rights and as a responsible data controller, we are committed to uphold these.

Detailed information about all of these rights can be found on the ICO website.

Responding to your request

If you notify us that you want to exercise your rights, we will acknowledge your request promptly. if we don't already know who you are, we may need to ask you to provide us with additional information to enable us to verify your identity. The information we would need depends on the nature of your request.

Once we have confirmed your identity, we will validate your request and gather the information we need to be able to respond to it. We will carry out this work as quickly as possible but it may take up to 30 days to respond in full. If your request is particularly complex, we may ask you for further information to help us respond more quickly, or ask you if there is some information that you want particularly urgently. We may also respond to your request in phases, as relevant information becomes available.

If we cannot satisfy your request within 30 days, we will write to you to tell you why, and when we expect to be able to provide you with a full response.

Some of these rights are subject to conditions. If for any reason we decide that we cannot satisfy your request, we will provide you with our decision and our reasons for reaching it within 30 days.

Please note that we are unable to comply with any request relating to personal data held exclusively by our franchisee. You may also like to contact the relevant pub that you visited and make a similar request to the franchisee directly.

Contact Us

If you want to discuss how we use your personal data, opt out of profiling, exercise your data protection rights or contact our data protection officer, you may write to: Greene King, Westgate Brewery, Bury St Edmunds, Suffolk, IP33 1QT; or send an email to: dataprotection@greeneking.co.uk.