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PRIVACY & COOKIE POLICY

Spring Pub Company Ltd

This policy describes how Spring Pub Company Ltd (we, us or our) use cookies and collect (and then use) personal data obtained from you when you visit our websites (our Websites).

You acknowledge and agree that your personal data may be processed in accordance with this policy. Without this, we will be unable to provide you with certain marketing communications.

1. INTRODUCTION

We are the data controller in respect of any personal data we collect about you.
We have appointed a data protection officer who is responsible for monitoring our data protection compliance.

2. COLLECTION OF YOUR PERSONAL DATA

We collect and process the following information about you; this is for the purposes explained in section 3.

Information you give us
Name, email address (personal and/or work), postal address, encrypted password(s), telephone number(s), date of birth, gender, interests, preferences, and competition entry details and answers

Information automatically collected from you
When you visit or use any of our Websites, we automatically collect certain information from you (the majority of which is from a server log), including:

  • URLs of the pages you visited on our websites
  • domain name requested
  • operating system and browser type
  • access times
  • browser language
  • time you spent on each page visited
  • URL of the website you visited before browsing to our websites
  • other information about your use of and actions on our websites
  • IP address used to connect your computer or mobile device to the internet

We may record or monitor calls, emails, text messages and other correspondence for training purposes to improve the quality of our offering and to prevent and detect fraud.

Information collected from third parties
Google analytics – collects information about how visitors use our Websites.
Doubleclick (Data collection for Google Adwords) – collects information about how visitors use our Websites.
Authentication information – see section 10.

3. USE OF YOUR PERSONAL DATA

We may use your personal data for any or all of the following purposes:

  • to provide a high level of customer service (including assisting with any of your enquiries and bookings) and to notify you of any security and data breach alerts, and technical notices (including services messages and updates to our Websites and terms);
  • to help operate, maintain and improve our offering and our Websites;
  • to communicate with you about our offers, promotions, upcoming events, reviews and other news or those of our selected partners – this may be via email, telephone and/or text message;
  • to facilitate profiling, segmentation and personalisation – these may be based on preferences, interests and past actions (including restaurant bookings);
  • to meet our legal obligations and for establishing, exercising or defending our legal rights;
  • to compile reports and to help us understand and improve our Websites; and
  • to enable us to carry out targeted online advertising more likely to be relevant to you.
    For more information about our use of cookies and other similar technologies, see section 11.

4. SHARING OF YOUR PERSONAL DATA

We sometimes need to share the personal information we process with other organisations and, where necessary or required, we may share your personal data with the following categories of third parties:

  • service providers and suppliers assisting with our business activities, business associates, customers, payment services providers, hosting providers, providers of IT support, advertising platforms, providers of booking systems, providers of cloud-based software or services used by us, accounting firms and law firms;
  • ombudsman, regulators, public authorities and security organisations, such as the police, HM Revenue & Customs and the Information Commissioner’s Office, to the extent required by law, regulation, court order or if necessary to establish, exercise or defend our legal rights, including if we suspect fraud or attempted fraud;
  • companies that are within the same group as us;
  • current, past and prospective employers, recruitment and employment agencies, trade and employer associations and professional bodies and educators and examining bodies;
  • financial organisations and advisors, credit reference agencies, debt collection and tracing agencies, and tenants;
  • staff including volunteers, agents and temporary and casual workers;
  • family, associates and representatives of the person whose personal data we are processing;

5. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF THE UK OR THE EUROPEAN ECONOMIC AREA (EEA)

Some third parties to whom we may transfer your personal data may be located outside of the UK or the EEA. In the event of a transfer, we will seek to ensure that appropriate safeguards to protect your data are in place which could include entering into a data transfer agreement with such third parties to ensure adequate protection for your information. Examples of the types of contractual clauses we may use can be found at the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

6. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We will process your personal data where it is necessary:

  • for the performance or entering into of a contract with you, including in order to provide our offering, process your payment and to respond to enquiries and bookings made by you;
  • for compliance with our legal obligations;
  • for the purpose of furthering our legitimate interests including to:
  • improve our offering and Websites;
  • operate our Websites efficiently and effectively;
  • carry out behavioural advertising; and
  • prevent, detect and investigate fraud or illegal activity.
    We may also process your personal data on the basis of any consent given by you..

7. PROTECTION OF YOUR PERSONAL DATA

We are committed to protecting your personal data and to keeping it safe and confidential. We will therefore ensure that appropriate technical and organisational physical, electronic and procedural safeguards are implemented to protect it. Access to your personal data will also be limited to our employees and certain third parties who process it on our behalf.

8. STORAGE OF YOUR PERSONAL DATA

Your personal data will generally be stored for up to 5 years.
We may, however, keep your personal data for longer than 5 years if we need it to fulfil our contractual obligations to you, the law requires us to maintain it for a longer period or you have not withdrawn your consent.

9.  YOUR RIGHTS

You have the following rights, albeit some of them only apply under certain circumstances:

  • to have a copy of the personal data we have collected about you and to send a copy of it to another data controller;
  • to update or amend the personal data we have collected about you if it is inaccurate or incomplete;
  • to erase, or restrict the processing of, the personal data we have collected about you;
  • to object to the processing of the personal data we have collected about you, including in respect of any data processed for direct marketing purposes;
  • to withdraw any consents you have provided in respect of our processing of your personal data; and
  • to lodge a complaint with the Information Commissioner’s Office (ico.org).
    To exercise any of these rights, please contact us – see section 12.

10. CONNECTING TO THIRD PARTY SERVICES INCLUDING SOCIAL NETWORKS

Our offering may contain links to third-party apps, services, tools and websites that are not affiliated with, controlled or managed by us (including Facebook, Instagram, LinkedIn and Twitter®) and these services and links may also include social networking features (such as the Facebook® “Like” button and widgets, “Share” buttons, and other interactive mini-programs). Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn® to log into some of our services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information, such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use or access as the privacy practices of these third parties will be governed by their own privacy statements. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the services we provide and do not participate in social sharing.

11. COOKIES

We collect data about how you interact with our Websites through the use of cookies and other similar technology.

What is a cookie?
Cookies are small text files containing small amounts of information which are downloaded to your computer or mobile device when you access our Websites. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.

Why do we use cookies?
Cookies are useful because they allow our Websites to recognise your device. We use them to make our Websites work, or work more efficiently, as well as to store information about your preferences or past actions. You can find out more information about cookies at www.allaboutcookies.org.

We also use cookies to enhance and improve your online experience (for example, by remembering your language and/or preferences) and to understand better how our Websites are used. Cookies may tell us, for example, whether you have visited our Websites before or whether you are a new visitor. They can also help to ensure that adverts seen online are more relevant to you and your interests. They cannot be used to identify you personally.

What types of cookies do we use and how?

We use the following types of cookies:

  • ‘session cookies’: these are allocated to your device only for the duration of your visit to our Websites – they are deleted automatically once you close your browser; and
  • ‘permanent cookies’: these survive after your browser is closed and can remain on your device for a period of time – they can be used by our Websites to recognise your computer or mobile device when you open your browser and browse the internet again.
    These cookies may be served directly by us to your computer or mobile device (so-called ‘first-party cookies’) or by one of our service providers (so-called ‘third-party cookies’). A first-party cookie is only used by us to recognise your computer or mobile device when you revisit, or access content via, our Websites. Third-party cookies can be used to recognise your computer or mobile device across different websites (and are most often used for analytical and advertising purposes).

What purposes do we use cookies for?
We use cookies for the purposes stated below:

  • essential cookies: these are essential to provide you with services available through our Websites and to use some of their features, such as access to secure areas – without these, providing core functionality, such as transactional pages and secure login accounts, would not be possible;
  • analytics cookies: these are used to collect information about how you and others use our Websites – the information gathered does not identify you and is aggregated – this includes the number of visitors to our Websites, the websites or other applications that referred them to our Websites and the pages that they visited on our Websites – we use this information to help operate our Websites more efficiently, to gather broad demographic information and to monitor the level of activity on our Websites;
  • functionality cookies: these allow our Websites to remember choices you make (such as your user name or the region you are in) and provide enhanced, more personal features – they can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize – they may also be used to provide services you have asked for, such as watching a video or commenting on a blog – the information these cookies collect may be anonymised and they cannot track your browsing activity on other websites;
  • performance cookies: these collect information about how you and others use our Websites, for example, which pages are most visited, if error messages come up and how effective our online promotions are – they are only used to help us improve how our Websites work and to ensure ease and speed of use;
  • marketing cookies: these facilitate online advertising – our Websites, for instance, use remarketing with Google – third-party vendors, including Google, use these cookies to tailor adverts based on someone’s past visits to our Websites and serve these across the web – you can set preferences for how Google advertises to you using the Google Ads Settings; and
  • social media cookies: these are used when you share information using a social media sharing button or “like” button on our Websites or you link your account or engage with our content on or through a social networking site such as Facebook, Instagram, Twitter or Google+ – the social network will then record that you have done this and the information may be linked to advertising activities such as targeted banners.

What particular cookies do we use?
The following are our own cookies; they are controlled by us and used to provide information about usage of our Websites. These are all session cookies and automatically expire when you close down your browser:

  • ci_session / ASPSESSIONIDQABRARAD / fueldid / PHPSESSID: these are unique identifiers for your session;
  • TextSize: this sets the text size;
  • TextType: this sets the graphic version;
  • js-cookie-notice: this remembers the status of your cookie banner; and
  • landing_auth: this remembers the status of your popups.
    We use a number of suppliers who may also set cookies on their websites on their behalf. We do not control the use of these cookies, so you should check the third party websites for more information about them.

 

Provider

Name

Purpose

More info

Google Analytics

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These cookies are used to collect information about how you use our Websites. We use the information to compile reports and to help us improve the Websites. The cookies collect information in an anonymous form, including the number of visitors to the Websites, where visitors have come to the Websites from and the pages they visited.

Google Privacy policy

Share This

__uset

__stid

Tracks what is being shared and by whom.

Share This privacy

YouTube

VISITOR_INFO1_LIVE

APISID

HSID

LOGIN_INFO

PREF

SAPISID

enabledapps.uploader

Google uses these cookies to measure the number and behaviour of Youtube users, including information that links your visits to our websites with your Google account if you are signed in to one.

Google Privacy policy

Facebook

datr

lu

Facebook Social Plugin – embedding Facebook content.

Facebook privacy policy

Google Maps

NNID

PREFAPISIDHSID

Google uses these cookies to measure the number and behaviour of Google Maps users.

Google Privacy policy

New Relic

JSESSIONID

NREUM

NRAGENT

Used to store a session identifier so that New Relic can monitor session counts for an application.

New Relic Cookies

Double Click

test_cookie

Id

ide

_drt_

The advertisements that drive traffic to our Websites (when shown) are served by a third-party ad serving provider called DoubleClick. The cookies accompanying the ads allow monitoring of the effectiveness of the ads (for example by using statistical analysis cookies) and make the ads more relevant to you.

Google Advertising Info

Crazy Egg

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adxs

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These cookies are placed by Crazy Egg, a platform that produces heatmaps that allow us to analyse how users engage with our websites. More info: https://www.crazyegg.com/opt-out.

Crazy Egg Cookie Policy

 

How to manage cookies?

You have the right to choose whether or not to accept cookies. However, if you do not accept our cookies, you may not be able to use the full functionality of our Websites.

You can find more information about how to manage and remove cookies at allaboutcookies.org/manage-cookies/ or by visiting the websites relevant to the browser you are using. Below we have provided links to some of the most popular browser websites:

Google Chrome
Mozilla Firefox
Microsoft Internet Explorer
Apple Safari
Opera

12. CONTACT INFORMATION AND UPDATING YOUR PREFERENCES

If you have any comments or questions, please contact us at Riverside House, 26 Osiers Road, Wandsworth, London, SW18 1NH (marked for the attention of our Data Protection Officer), via phone (020 8875 7000) or via email (privacy.springpubcompany@gmail.com).

To unsubscribe from any of our marketing-related activities, please contact us at privacy.springpubcompany@gmail.com and we will process your request.

 

13. CHANGES TO THIS POLICY

From time to time we may change this policy. Changes made to it will be notified to you. If you do not accept the changes within the specified timeframe (which will be no less than 30 days) we may have to cease providing you with access to our offering and/or our Websites.