Introduction

Data Controller

'Greene King', ‘we’, ‘us’ and ‘our’ are references to Greene King Brewing and Retailing Limited, who is the data controller in respect of this website 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.

About Greene King

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 Wacky Warehouse, Greene King, Hungry Horse, Farmhouse Inns, Chef & Brewer, Flaming Grill, Greene King Inns, Greene King IPA and Old Speckled Hen. More information about our brands can be found on here.

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 - more details about this are provided below.

Purposes

We will process your personal data whenever:

  1. you use our websites
  2. we need to verify or record information about your identity
  3. you book a play session or party
  4. you make a payment, request a refund or redeem a voucher
  5. you use our Wi-Fi service
  6. you subscribe to newsletters or direct marketing
  7. you use a gift card or participate in a loyalty scheme
  8. you submit queries, compliments or complaints
  9. you take part in a survey
  10. we record promotional videos or interviews or take photos
  11. we record CCTV images or emergency phone calls
  12. we record phone calls to our offices
  13. an accident occurs
  14. 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.

back to list

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 or registering your visit, together with the date, time and name of the venue you are visiting, will be recorded for this purpose.

If NHS or local authority test and trace teams in the UK request information from us about our 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.

back to list

3 - When you book a play session or party

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

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

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.

back to list

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.

back to list

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

back to list

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.

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

back to list

7 - When you use a gift card or participate in a loyalty scheme

When you buy a gift card, we will use the information your provide to personalise, activate and send the gift card to you or the person you bought it for.

If you join one of our loyalty schemes, we will use the information you provide to enrol you and to provide confirmation of this and other necessary information about your membership.

When you redeem your gift card and whenever you present your loyalty scheme membership number during payment, we will use information about your visit, purchases and use of our services to update your gift card balance, credit your account with any loyalty points you have earned and update your profile.

back to list

8 - When you submit queries, compliments or complaints

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.

back to list

9 - When you take part in a survey

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

back to list

10 - 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 involved, please let a member of staff know on your arrival so that they can ensure your wishes are respected.

back to list

11 - When we record CCTV images and emergency phone calls

We use CCTV and emergency audio recording technology to help keep our guests and staff safe and to help us investigate any potentially criminal or unsafe incidents which occur. Please refer to the signage on arrival at any of our venues to find out what else these recordings could be used for.

If we need to carry out an investigation, we will review these recordings to determine if they contain relevant information. If this is the case, the recording may be shared with members of our management team, our own or third party insurers, suppliers, contractors, licensing authorities or the police. Recordings may also be used in any insurance claim or other type of legal claim or proceeding that follows.

back to list

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.

back to list

13 - If an accident occurs

If you are unfortunate enough to be involved in an accident on our premises, we will use the information you or others present at the time provide to record the incident in an accident book. We may also use this information to conduct an investigation and to make or defend an insurance or other type of legal claim.

back to list

14 - 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.

back to list

Retention

Information about

Is kept until

use of our websites

25 months from your last known interaction with us.

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.

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).

marketing preferences

These are kept indefinitely to ensure we can continue to respect your wishes.

gift cards and loyalty scheme membership

6 years from the date of your last purchase or refund.

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.

CCTV and emergency audio recordings

CCTV is kept for 31 days and emergency audio is kept for 6 years from the date of the recording. However, if they are used as part of an investigation or claim, this period may be extended.

phone calls to our offices

3 months from the date of the recording.

accidents

6 years from the date of the accident, or 3 years from the age at which a child involved in the accident becomes an adult, or 3 years from the date of settlement of a claim, whichever occurs last.

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.

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 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.
  • 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 two safeguards, we may try to contact you to ask for your consent before we transfer your personal data.

Third Parties

Organisation 

Contact Details

Data shared

Reason for sharing

International data transfer Destinations and Safeguards

123 FormBuilder

Flavia Palace, Vladimirescu n° 10' Ground Floor 300195 
Timisoara, Romania

https://www.123formbuilder.com

Name, DOB, address, telephone, contact preferences, complaint / enquiries.

Managing guest queries and complaints, managing competition entries & ad hoc web forms

 

Action Solutions Vouchers Limited

The Grange Worksop Road, Aston, Sheffield, S26 2EB

Name, contact details, payment details, details regarding the gift vouchers and their usage

Providing gift vouchers

 

BookingLive Software Limited

Suite 231 179 Whiteladies Road, Clifton, Bristol, BS8 2AG

https://www.bookinglive.com/

Name, email, telephone, child data

Managing Playzone soft play bookings

 

Bunzl Retail and Healthcare Supplies Limited t/a MDA

York House, 45 Seymour Street, London, W1H 7JT

Name, contact details, payment details, details regarding the gift vouchers and their usage

Fulfilment of gift vouchers

 

Campaign Monitor Pty Limited

Australia

Name, email, address, DOB, contact preferences, telephone, email engagement, website visit engagement

Managing our customer database

Australia, Standard Contractual Clauses

Card Commerce Limited t/a Savvy

5 Wormwood Street, London, EC2M 1RQ

Name, contact details, payment details, details regarding the gift vouchers and their usage

Providing gift vouchers

 

Celerity Information Services Limited

82 St John Street, London EC1M 4JN

www.celerity-is.com

Name, address, date of birth, email address, purchase information engagement information, preferences, marketing opt out status, demographics

Managing our customer database

 

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

 

EagleEye Solutions Limited

5 New Street Square, London EC4A 3TW

https://www.eagleeye.com

Name, email, telephone, address, DOB, transaction and voucher information

Managing the Season Ticket app

 

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

 

Extravision Limited

Tomorrow Blue, Media City UK, Salford M50 2AB

www.extravision.com

Name, email, address, DOB, contact preferences

Managing and distributing email marketing campaigns

 

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

GBG Group Plc

The Foundation, Herons Way, Chester Business Park, Chester CH4 9GB

guest identity information including copies of ID documents

Managing information recorded using the Scannet system

 

GI Solutions Group Limited

147 Scudamore Road, Leicestershire LE3 1UQ

www.gi-solutionsgroup.com

Name, address, phone, email

Data entry of paper forms into our electronic systems and fulfilment of Loch Fyne loyalty cards

 

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

Guestline Limited

Guestline House, Shrewsbury Business Park, Shrewsbury, SY2 6LG

Name, address, DOB, payment details, email, telephone

Managing hotel bookings

 

Hopewiser Limited

Merlin Court, Atlantic Street, Altrincham, WA14 5NL

www.hopewiser.com/privacy-policy

Name, address

Data cleansing for OEI mailing data

 

Hotelshop UK Limited

Brine Well House, Tower Hill, Droitwich Spa, Worcestershire WR9 8BY

www.hotelshopuk.com/

Name, address, DOB, payment details, email, telephone

Managing hotel function room bookings

 

Inspire Protection Solutions Limited

Hilton Hall, Hilton Lane, Essington WV11 2BQ

Visual images

Managing, maintaining and operating CCTV

 

Inspired Thinking Group (ITG) Limited

315 Fort Dunlop, Fort Parkway, Birmingham B24 9FD

Name, address, DOB, email, telephone

Managing our OEI mailer and fulfilment

 

JT Response Limited 

28 Mill Road, Ashley, Suffolk CB8 9EE

IP address, MAC address, Cookies, Web browsing history

Managing and maintaining our websites

 

LiveBookings Limited

5th Floor, Elizabeth House, 39, York Road, London, SE1 7NQ

http://console.livebookings.com/

Name, email, telephone, child data

Managing Wacky Warehouse soft play bookings

 

Logwood Computing Ltd

The Old Granary The Lynch, Kensworth, Dunstable, Bedfordshire LU6 3QZ

Name, email, telephone, address, DOB

Managing table bookings

 

Market Force Information (Europe) Ltd

Mount Mill Farm, Stratford Road, Wicken, 
Milton Keynes MK19 6DG

www.marketforce.com

Survey data

Sourcing and analysing survey data

 

Mercury Security Systems Limited

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

Visual images

Managing, maintaining and operating CCTV

 

Mobas Limited 

Cambridge House, 65 London Road, Stapleford, Cambridge CB22 5DG

www.mobas.com/privacy-notice

IP address, MAC address, Cookies, Web browsing history

Managing and maintaining our websites

 

Movable,  Inc 

5 Bryant Park, 9th Floor, New York City, NY 10018, USA

movableink.com/legal/privacy

Location, email address, email responses

Assisting with preparing, sending and monitoring marketing emails

USA, Privacy Shield

Opentable International Limited

5 New Street Square, London, EC4A 3TW

www.opentable.com

Name, email, telephone, address, DOB

Managing table bookings

 

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

 

Propeller Communications Limited

33 Great Queen Street, Covent Garden,  London WC2B 5AA

IP address, MAC address, Cookies, Web browsing history

Managing and maintaining our websites

 

Red Box Recorders Limited

Bradmore Business Park, Loughborough Road, Bradmore, Nottingham, NG11 6QA

Name, contact information, nature of enquiry or complaint

Managing telephone conversation recordings

 

Secure Trading Limited

European Operations Centre, Parc Menai, Bangor, Gwynedd LL57 4BL

www.securetrading.com

Name, address, payment card information

Making card-based payments and refunds for gift cards

 

Sensor Technologies UK Limited

Unit 9, Southgate Industrial Park, Green Lane, Heywood, Lancashire OL10 1ND

Voice recordings

Managing emergency audio recordings

 

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

 

Skyguard Limited

Skyguard House, 457 Kingston Road, Epsom, Surrey KT19 0DB  

Voice recordings

Managing emergency audio recordings

 

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

 

WPR Agency Limited

39-40 Calthorpe Road, Edgbaston, 
Birmingham, 
West Midlands B15 1TS

Name, contact information, DOB, address, telephone, Social media tracking information, website tracking data

Managing PR and social media campaigns

 

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

 

This section of the notice will be updated as and when suppliers change. Last updated: 6th July, 2020.

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.

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 a booking, payment, request a refund, use a loyalty card, use a gift card, 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 you use a gift card or participate in a loyalty scheme 

 To provide the benefits you are due under the contract.

When you submit queries, compliments or complaints

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 a survey

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 CCTV images or emergency phone calls

We may be required to do so by a licencing authority (legal obligation) or choose to do so for the purposes stated on the signage (legitimate interest).

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.

When an accident occurs

 We record accidents primarily for compliance with our legal obligations and to support and defend claims (legitimate interest).

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.

Name of right

Description

Information

You have the right to be informed what we will use your personal information for, where we obtain it, who we share it with and how long we keep it for. This is the primary reason for publishing this notice.

Access

You have the right to access a copy of your personal data and an explanation of what we are using it for. This is also known as a ‘subject access request’, ‘SAR’ or ‘DSAR’.

Rectification

You have the right to ask us to correct or stop processing inaccurate personal data.

Erasure ('right to be forgotten')

You have a right in certain situations to ask us to delete your personal data.

Restriction of processing

You have a right in certain situations to ask us not to process your personal data.

Object to processing

You have the right in certain situations to object to the fact that we are processing some of your personal data.

Portability

You have the right in certain situations to ask us to pass some of your personal data to another data controller on your behalf.

Complain

You have a right to submit a complaint to the UK Information Commissioner’s Office (ICO).

withdraw Consent

Most of the personal data processing we do is not dependent on your consent but any consent that we are relying on can be withdrawn if you wish to do so.

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.

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.

Status

This version of our privacy notice is effective from 08/09/2020.