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Privacy Policy

Introduction

Revolution Bars Group PLC (“Revolution Bars Group”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our browser-based Order and Pay app or visit our website (regardless of where you visit it from). This policy will tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Revolution Bars Group collects and processes your personal data through your use of our Order and Pay App and this website. The Order and Pay app and this website are not intended for children and we do not knowingly collect data relating to persons under the age of 16. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

Controller

Revolution Bars Group is the controller and responsible for your personal data (collectively referred to as Revolution Bars Group, the “Company”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Our full details are:

Revolution Bars Group PLC
21 Old St,
Ashton-Under-Lyne,
Tameside,
OL6 6LA

dpo@revolutionbarsgroup.com

You 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.

Changes to the privacy notice and your duty to inform us of changes

We may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective 24th May 2018 and was further updated on 10th September 2021.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store 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.

What data do you collect?

We may collect some or all the following (including personal) data (this may vary according to your relationship with us):

Information you may provide:

  • Name, Date of birth, Gender, Address, Email address, Telephone number
  • Payment information (card details are not retained)
  • Information about your preferences and interests and any information submitted via the completion of forms on websites and emails correspondence. Automatically collected via websites
  • IP, MAC address (unique device identifiers and mobile network information)
  • Information about your browser, operating system device types, software versions and model numbers
  • Information about your visit, including the journey to, through and out of our websites (inc. date & time)
  • Information about your network, such as information about devices, nodes, configurations, connection speeds, network/application performance and location information when available.
Personal data may also be obtained from the following third parties:
  • Wireless Social – Guest Wi-Fi service provider
  • Feeditback – Guest Experience Management & Feedback
  • Social media platforms i.e. Facebook, Twitter & Instagram
  • Omnifi – Revolucion de Cuba Online ordering platform
  • Pepper – Revolution App
  • Airship – Customer relationship management
  • Toggle – Gift Card processing
Personal data may also be obtained from the following third parties:
  • Wireless Social – Guest Wi-Fi service provider
  • Feeditback – Guest Experience Management & Feedback
  • Social media platforms i.e. Facebook, Twitter & Instagram
  • Omnifi – Revolucion de Cuba Online ordering platform
  • Pepper – Revolution App
  • Airship – Customer relationship management
  • Toggle – Gift Card processing
How do you use my data?

Under GDPR, we must have a lawful basis for using your ‘personal data’. This is because you have consented to our use of your personal data, or because it is in our legitimate business interests or other valid legal grounds to use it for your benefit. Data collected (including ‘personal data’) may be used for the following:

  • Supplying our services to you including Gift card, Reservations or bookings and online order & payment facilities
  • Communicating with you. This may include seeking feedback on services supplied responding to emails, calls, feedback or inquiries from you.
  • Supplying you with information and/or marketing materials by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by using the ‘unsubscribe link’ included in all emails or by contacting us via the address stated in part 1.
  • Gathering information to form statistical and trend analysis; research and analytics on an aggregate and/or anonymous basis.
  • Monitoring website usage and demand for services.
  • Meeting legal, regulatory and compliance requirements.
  • Messages posted via social media (including Facebook, Twitter, and Instagram) or other social platforms, we will collect the information provided to us. We may retain this information for the purposes set out in this privacy policy and use as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
  • We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this combined information for the purposes set out above.
  • If you stop using our services, we may continue to use and disclose your personal information in accordance with this privacy policy (as amended from time to time)

Third Parties whose content appears on our site(s) may use third-party Cookies, please see (use of cookies) for more information. Please note: we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

1. Submitting an enquiry

Type of data:
Identity
Contact
Any other personal information you provide.

We will use this information to respond to your enquiry.

Lawful basis for processing including basis of legitimate interest:

Dealing with your enquiry which is performance of a contract with you.

2. To process and deliver your order

This includes:

Managing payments, fees and charges
Collecting and recovering money owed to us

Type of data;

Identity
Contact
Transaction
Any other personal information you provide

We will use this information to fulfil your order, ensure the most suitable products are sent to you and to confirm your age for legal reasons.

Lawful basis for processing including basis of legitimate interest:

Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)

3. To manage our relationship with you

This includes:

Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
Answering any queries you may have

Type of data;

Identity
Contact
Profile
Marketing and Communications

Lawful basis for processing including basis of legitimate interest;

Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To deal with your enquiries

4. To enable you to partake in a prize draw, competition or complete a survey

Type of data;

Identity
Contact
Profile
Usage
Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

5. To administer and protect our business, this website and the Order and Pay app

This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data;

Identity
Contact
Technical

Lawful basis for processing including basis of legitimate interest;

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) Necessary to comply with a legal obligation

6. To deliver relevant app content, website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 Type of data;

Identity
Contact
Profile
Usage
Marketing and Communications
Technical

Lawful basis for processing including basis of legitimate interest;

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

7. To use data analytics to improve our app, our website, products/services, marketing, customer relationships and experiences

Type of data;

Technical
Usage

Lawful basis for processing including basis of legitimate interest;

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)

8. To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data;

Identity
Contact
Technical
Usage
Profile

Lawful basis for processing including basis of legitimate interest;

Necessary for our legitimate interests (to develop our products/services and grow our business)

9. To process a booking you have with us

Type of data;

Identity
Contact
Any other personal information you provide

Lawful basis for processing including basis of legitimate interest;

Performance of a contract with you Necessary for our legitimate interests

10. To use our WiFi

Type of data;

Identity
Contact
Technical
Usage
Profile

Lawful basis for processing including basis of legitimate interest;

Performance of a contract with you Necessary for our legitimate interests. To enforce our terms of usage.

11. Club Scan

Licenced premises have a responsibility to uphold four objectives from the Licensing Act 2003:
·         Public Safety
·         Prevention of Public Nuisance
·         Prevention of Crime and Disorder
·         Protection of Children from Harm

In order to uphold these objectives, in particular; the prevention of crime and disorder and the protection of children from harm we use the IDScan system in some of our venues.

Revolution Bars Group plc is registered with the Information Commissioner’s office for use of this system and we take data protection and privacy considerations seriously.

Considerable attention is paid to seeking to ensure that data captured is held securely.

IDScan retains a copy of customer identity documents. Scanning is entirely voluntary, however the management reserve the right to refuse entry if ID is not volunteered.

Access to stored data is restricted to management level. Data viewed by door supervisors extends merely to the photograph and DOB.

Occasionally we may share this data with Police, if requested following an incident in the venue, to assist in crime and disorder investigation or prosecution. An individual’s data may also be shared with Scannet, in conjunction with Pubwatch, if that individual is placed on a Barred List.

Our systems are set to automatically purge data that is over 3 years old which is in line with the statute of limitations for civil claims. Copies of ID documents will be retained for a maximum 3 years with the exception of any individual who is on the Barred List, where their details will be retained for as long as they remain on that list.

Should you require that we purge you’re information, and given that the information need not reasonably be kept for any of the purposes above, please email dpo@revolutionbarsgroup.com

12. CCTV

In the interests of Public Safety, and the prevention of Crime and Disorder Revolution Bars Group PLC uses CCTV  in all of its venues. We may, in some of our premises use body cameras for the same purpose and the use one or both may be a condition on the premises licence. Where we use CCTV, this will be clearly signposted at the entrance to the premises.

Video footage will be retained for a minimum of 31 days and will only be accessed by the following personnel;

  • Site management
  • The Risk and Compliance Team
  • Local law enforcement officers

Video copies of specific incidents may be retained and made available to local law enforcement officers and/or legal representatives where the footage is part of an accident investigation,  official investigation or legal case.

Enquiries regarding CCTV footage should be sent to dpo@revolutionbarsgroup.com

13. Live Chat Software

We use live chat software on our website, this is provided by Click4Assistance, a 3rd party UK based Software Company. Information regarding how the data is processed and stored can be viewed here.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications.
We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or expressed an interest in our products and, in each case, you have opted in to receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Revolution Bars Group group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

We use technologies, such as cookies and pixels, to customise content and advertising, to provide social media features and to analyse traffic to the site. We also share information about your use of our site with our trusted social media, advertising and analytics partners.

Change of purpose

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

  • Internal Third Parties as set out in the glossary.
  • External Third Parties as set out in the glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

International transfers

Wherever possible we do not transfer your personal data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may sometimes involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • 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.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

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 will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have 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.

Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Request erasure 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

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 may 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 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.

Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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 do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply 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.

THIRD PARTIES
Internal Third Parties
  • Other companies in the Revolution Bars Group acting as joint controllers AND/OR processors and who are based in the UK and provide [IT AND/OR system administration services].
External Third Parties
  • Digital service providers acting as processors, operating in the EU, who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.
  • Professional advisers acting as processors AND/OR joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Marketing services providers acting as processors including mailing and survey companies operating in and outside of the EU who provide distribution, reporting and analysis of emails and surveys.
YOUR LEGAL RIGHTS

You have the right to:

  • Request access

    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

    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

    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

    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

    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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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

    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

    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.