WHO is the CONTROLLER of your personal data?
Star Pubs & Bars Limited and Heineken UK Limited (collectively referred to as "we", "us", or "our" in this privacy notice) are part of the Heineken group. When we mention "we", "us" or "our" in this privacy notice, we are referring to the relevant company which is responsible for processing your personal data. Unless we inform you otherwise, the controller will be Star Pubs & Bars Limited. However, where processing of personal data is undertaken by Heineken UK Limited for their own independent purposes (for example in connection with a marketing campaign), that entity will be a separate controller of your personal data. The contact details for each controller are as follows:
Our Contact Details:
If you have any questions about this privacy notice or our processing activities, we can be contacted as follows:
-
Mail: 3 – 4 Broadway Park South Gyle Broadway Edinburgh EH12 9JZ, marked for the attention of the Privacy Officer; or
It is important that you read this privacy notice together with our Cookie Policy and any terms of use that apply to the services or Website which are presented to you. If you submit orders through Star Pubs & Bars Online, please review the privacy notice available at https://order.starpubsandbars.co.uk/spb/en/GBP/anon/foot_privacy_anon which describes how we look after any personal data that you submit through that website. This privacy notice supplements the other notices and is not intended to override them.
HOW and WHAT data do we collect about you?
We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we look after your personal data when you:
|
Personal data, or personal information, means any information about an individual from which that person can be identified. We collect this information directly from you during any application process, on-going business relationship or Engagement with you, as well as automatically through your use of our Website. We also collect this information indirectly from Wireless Social Limited (our third party provider of the Wifi Services at certain venues). Depending on the nature of our interaction with you, we collect different categories of information about you from time to time which we have grouped together as follows:
Identity Data | name, username, title and place and date of birth and personal characteristics including age and gender |
Contact Data | billing address, delivery address, email address and telephone numbers |
Applicant Data | work history, qualifications. National Insurance number, right to work documentation and proof of identity |
Financial and Transactional Data | credit history, bank account and card payment details, and details about payments as well as products and services purchased from us |
Profile Data | preferences, feedback, survey responses and interests including activities noted on Social Media Platforms (for example, Facebook likes/groups) |
Technical and Usage Data | information about how you use our products, services, Website and the Wifi Services such as internet protocol (IP) address, cookies, mobile device ID, any login data, browsing history, browser type and version, time zone setting and location, viewed pages with date and time stamp (log information), browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website |
Marketing and Communications Data | preferences in receiving communications and marketing from us |
Location Data | GPS-based location information from your use of our Website, the Wifi Services or Social Media Platforms via your smartphone(s), tablet(s) or other devices |
Photo and Video Data | Photos and or video footage of you captured when you attend any events hosted or sponsored by us in one of our pubs or elsewhere (your attention will always be drawn to any photography or filming that is taking place, and your consent will be obtained where required) |
Inferred Data | which is inferred or derived from the data we collect, for example inferences about your interests based on your Identity Data or Location Data |
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 or using the Wifi Services and visiting venues where we supply our products. 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 notice.
We do not knowingly process any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data). Nor do we process any information about criminal convictions and offences.
We do not knowingly collect personal data relating to children and have age verification processes on our Website and as part of the Wifi Services. Further, we do not market our products or services to anyone under the age of 18.
WHY do we collect your personal data?
We collect the above categories of personal data about you for the following purposes:
|
We will only use your personal data for the purposes above, unless we reasonably consider that we have another appropriate reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Further information on the circumstances in which we collect your data is available in Annex 1 of this privacy notice.
What is our LEGAL BASIS for collecting your Data?
Under data protection laws, we must have a legal basis under which we process your personal data. When we collect and use your information, we do so under one of the following:
-
We have a legitimate interest as a business;
-
To perform a contract we have with you;
-
To comply with a legal obligation; or
-
If you have given us your consent.
Legitimate Interest as a business means conducting and managing our business to enable us to give you the best service and to promote and grow our business. 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 will not use your personal data for activities unless we have a compelling interest which is not overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, such as entry into a promotion or subscription to a particular service, or to take steps at your request before entering into such a contract. Compliance with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, such as anti-money laundering legislation. With your consent, this can only be relied on by us as a legal basis for processing where your consent has been freely given, is unambiguous and clear (i.e. you have actively opted into a service we provide by ticking a box). If you provide us with your consent to process your data at any point on our Website or in connection with the Wifi Services or on a Social Media Platform, you can withdraw it at any time, and we will stop all processing activities that were based on consent as a legal basis for processing. Please note we may still process the data if we have another lawful basis for processing (in most instances, this will be for a more limited purpose e.g. back-up storage or to record a withdrawal). |
Further information on the relevant purposes and linked legal basis are set out in Annex 1 of this privacy notice.
Where we need to collect personal data due to a legal or regulatory obligation, or in relation to the performance of a contract, and you do not 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). We will notify you of this at the time.
WHO do we share your personal data with?
In order to ensure that we provide the best service to you, we may from time to time have to share your personal data with the parties set out below for the purposes and on the legal basis as set out in the table in Annex 1:
-
Internal third parties - other companies in the Star Pubs & Bars/Heineken group based within the EEA and the UK;
-
External third parties – we share your personal data with third parties which include:
|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where third parties act as processors on our behalf, we only permit them to process your personal data for specified purposes and in line with our instructions.
International transfers
Our external third parties may be based outside the UK or the EEA. Whenever we transfer your personal data out of the UK or the EEA, we ensure that the same level of protection is afforded to it by ensuring at least one of the following safeguards are put in place:
-
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries; and
-
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.
How SECURE is my data?
We have put in place 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 who have a business need to know. They are subject to a duty of confidentiality.
Unfortunately, no transmission of information over the internet can be completely secure, and you should also note that the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect account information and passwords, so please take care to protect this information.
Our Website and the Wifi Services 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, plug-ins or applications and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit and third party service/application that you use.
How LONG will my personal data be used for?
We will only retain your personal data to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Further retention details for specific aspects of your personal data are noted in Annex 1.
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.
What MARKETING and PROFILING activities do we carry out?
From time to time, you may receive tailored marketing communications from us if you have:
-
requested information from us;
-
purchased goods or services from us;
-
provided your details for the purposes of the Wifi Services; and/or
-
entered a competition or registered for one of our promotions.
You will not receive marketing communications from us in any of the above scenarios if you have opted out of receiving that marketing. Where you have not opted out, you will only receive marketing communications from us in the above scenarios if the marketing is confined to online advertisements or marketing that is not direct to you. We will only send direct electronic marketing (e.g. via emails or SMS), where we have your express consent.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where you have given us your consent, we may use your Identity Data (such as your age or gender), Contact Data (your e-mail address), Profile Data (your preferences and interests), Technical and Usage Data, Marketing and Communications Data and Location Data, together with Inferred Data, to form a view on what we think you may want or what may be of interest to you and to understand your purchasing trends. We may also use data which has been collected from third parties to enrich the data we hold relating you in order to build a fuller picture of what may be of interest to you. This profiling activity informs how we decide which products, services and offers may be relevant to you, and to send you tailored communications regarding these.
You can ask us, or third parties acting on our behalf, to stop sending you marketing messages at any time by contacting us at protectingyourdata@heineken.co.uk. Where you opt out of receiving these marketing messages, we will no longer conduct any marketing unless you opt-in again at a later point. Please note that where we have another lawful basis for processing, we will continue to process personal data for other purposes – for example, we may process information provided to us in connection with an Engagement on the basis of contract necessity.
You can use the cookie banner to accept or reject non-essential cookies, including advertising cookies. Please see our separate Cookie Policy for more detail on this and how to control your preferences using the cookie preferences centre.
Please note that other than the profiling activities described here, we do not carry out any automated decision making processes which could have a legal or significant impact on you.
What are my RIGHTS?
Under certain circumstances, you have various rights in relation to your personal data under data protection laws. If you wish to exercise any of these rights, please email us at protectingyourdata@heineken.co.uk.
You will not have to pay a fee to access your data or exercise any of your other rights, but please note that we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
In order to respond to any request in relation to your data access rights, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.
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.
You have the right to:
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 overrides your rights and freedoms. |
You also have the right to:
|
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details at the start of this notice.
This version was last updated in September 2020.
Annex 1
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest | Retention period |
---|---|---|---|
To collect your contact details when you visit one of our pubs in accordance with our legal obligation to assist the NHS England Test and Trace, NHS Wales Test, Trace, Protect and NHS Scotland Test and Protect programmes |
Limited to first name, surname, telephone number, the date, time and name of the pub visit | To comply with our legal obligation to conduct contact tracing in Scotland, England and Wales | 21 days from the date of collection |
To process your application to become a tenant/operator in one of our pubs |
| Necessary for our legitimate interests (recruitment of tenants/operators and internal administration) | 6 months after notification to you that your application was unsuccessful, or 6 years following the termination of the tenancy agreement if successful |
To register you as a new tenant/operator if your application is successful |
| Performance of a contract with you | 6 years following the termination of the relationship |
To add unsuccessful applications to our talent bank of excellent candidates so that we can contact you when suitable opportunities to become a tenant/operator of one of our pubs arises |
| Consent, where expressly provided by you | Contact details are removed from our talent bank after three unresponsive contacts have been made to you, or if you notify us that you no longer wish to be contacted by us (whichever is the earlier) |
Where we perform the contract we have in place with you for the purchase of products, including managing payments, fees and charges |
| Performance of a contract with you; and To perform our legal obligations | After the duration of your contract with us has expired, our online sales records will be retained by us for 7 years or longer if required by tax or corporate bookkeeping |
To deter crime and ensure the personal safety and security of visitors and staff through the use of CCTV in our managed pub estate |
| Necessary for our legitimate interests (to protect the safety and security of visitors and staff at our sites and assist in criminal investigations) | Video footage will be retained for a limited time before it is automatically deleted. The retention of CCTV is determined by any specific requirements as specified by the local licensing authority in the premises licence, as well the need to investigate health and safety incidents or criminal incidents, including in connection with any legal proceedings or requests from law enforcement authorities |
To manage our relationship with you and communicate with you, which may include:
|
| Performance of a contract with you; and Necessary for our legitimate interests (for running our business) | Customer services will retain all information for 1 year from when the compliant/issue/incident is resolved If you no longer wish to receive any e-mails/alerts from us, you can unsubscribe at any time, and we will remove your email address within 30 days of receiving your unsubscribe notification, unless it requires to be retained for other purposes as listed in this privacy notice |
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
| Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and Necessary to comply with a legal obligation | 26 months from Website visit |
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences |
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) | 26 months from Website visit |
To improve our marketing strategies and create individual profiles and profiled audience segments (including custom audiences), and to enrich existing profiles using third party data, so that we can issue tailored marketing content and offers, including sending you targeted content based on your location. |
| Consent | Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable. |
To send you online advertisements or marketing which isn’t tailored to you but forms part of a wider brand campaign or initiative. |
| Necessary for our legitimate interests (to maintain the relevance of our brand and reputation and to grow our business by serving consumers with advertising relating to our brands). Where required by privacy laws, Consent | Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable. |
To conduct market research with unsuccessful or withdrawn candidates |
| Necessary for our legitimate interest (to improve and streamline application process) | 2 weeks after notification to you that your application was unsuccessful / after you have withdrawn your application (as applicable) |
To send you direct electronic marketing (i.e. via SMS, email or direct messaging through social media platforms) relating to our brands which we consider may be of interest to you. |
| Consent | Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable. |
Address
Branston Arms, 115-116 Branston Road, Burton upon Trent, Staffordshire, DE14 3DD
Call Us
01283 741401