Privacy Policy

Introduction

Welcome to the ETM Group privacy policy. 

ETM Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you. 

1. Important information and who we are

Purpose of this privacy policy 

Controller 

Our details are below:
ETM Group Limited
10 Queen Street Place,
London,
United Kingdom,
EC4R 1AG
Company number: 05908632
ICO registration number: ZA434225 

Contact details 

Full name of legal entity: ETM Group Limited 

Email address: privacy@etmgroup.co.uk 

Postal address:
Privacy Team
ETM Group Limited,
40 Clifton Street,
London
EC2A 4DX 

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

 

2. Your data

The types of data we process are as follows: 

  1. Identity Data includes first name, last name, date of birth. 
  2. Contact Data includes email address and telephone numbers. 
  3. Payment Data includes bank account and payment card details. 
  4. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
  5. Usage Data includes information about how you use our website. 
  6. Marketing and Communications Data includes your preferences in receiving marketing from us when you sign-up to receive emails from us. 

More details on the circumstances which we process your data and how we handle it are as follows: 

 

3. Lawful bases

 

4. Disclosures of your personal data

Sharing with companies within the ETM Group 

Companies Within the ETM Group

ETM Group Limited
Group company operating The Botanist Broadgate, The Hat and Tun, ETM Collection venues, Sport London venues, and serving as the Head Office.
Company Number: 05908632
ICO Registration Number: ZA434225

ETM Concessions Limited
Operates Aviary, Burdock, Long Arm Pub, The Jugged Hare, Chiswell Street Dining Room, and Marlowe.
Company Number: 12210849
ICO Registration Number: ZB407048

ETM Premium Bars and Restaurants Limited
Operates Wagtail and Kitty Hawk.
Company Number: 16310689

ETM Premium Sports Bars Limited
Operates Greenwood, Redwood, Westwood, Broadwood, Beechwood, and Goldwood.
Company Number: 12444519
ICO Registration Number: ZB374200

The Botanist Sloane Square Limited
Operates The Botanist Sloane Square.
Company Number: 10046716
ICO Registration Number: ZB374231

Each of these companies is either bound by the terms of this privacy notice or has entered into binding agreements with us to protect and safeguard your personal data.

Sharing with our suppliers and other third-parties

We also work with a number of third-party suppliers, in doing so these third parties may be required to process your personal data in order to provide their services to us or on our behalf. These organisations are required to comply with our data protection policies, must only process personal data in accordance with our instructions and they are not permitted to use your personal data for their own purposes. 

Wireless Social
Data Shared: First name, email address, date of birth, venue
Reason for Sharing: Use of Wi-Fi service

The Access Group – Acteol – Atreemo
Data Shared: First name, surname, phone number, email, date of birth, venue
Reason for Sharing: Marketing communications following opt-in confirmation

Reputation.com
Data Shared: First name, surname, phone number, email, venue, information about the visit
Reason for Sharing: Customer feedback survey

andanotherday.com
Data Shared: First name, surname, email, venue, date of birth
Reason for Sharing: Website hosting and contact us details

engageinteractive.co.uk
Data Shared: First name, surname, email, venue, date of birth
Reason for Sharing: Website hosting and contact us details

The Access Group – DesignMyNight.com
Data Shared: First name, surname, phone number, email, venue
Reason for Sharing: Booking tables

Your Site Here (Part of DG Group)
Data Shared: First name, surname, email, venue, date of birth
Reason for Sharing: Website hosting and contact us details

5. International transfers

 

6. Data security

 

7. Data retention

How long will you use my personal data for? 

 

8. Change of purpose

 

BOOKING A TABLE OR CORPORATE EVENT WITH US 

1. By phone or in person: 

  1. For reservations by phone, in person, via our website or via 3rd party websites phone or in person we will collect your Identity Data and Contact Data so that we can contact you regarding your booking. 
  2. Where you are booking group dining or private events, we will also request information about payment and invoicing details. 

2. Design My Night, website and app: 

  1. You might also use the Design My Night website and application. Design My Night will collect your Identity, Contact and Payment Data as required and provide it to us so that we can facilitate your enquiry/booking and so we can contact you regarding your enquiry. 
  2. They will also ask you if you wish to consent to receiving further information from them as well as us with information regarding special offers and news. 
  3. Please note that we are not responsible for the data held by third-party platforms. We are only responsible for the information that they pass on to us (your name, email address and phone number) and on the understanding that such information is provided to us further to your request for a booking or enquiry. Please contact them directly and refer to their privacy policies for more information on how they process your personal data. 

3. If you provided consent to receive news and offers from us: 

  1. When we send you information regarding our latest news and offers we will always provide you with the option to unsubscribe. 
  2. We will only send this information to you until you unsubscribe or if at the end of our retention period you have not interacted with us or any marketing material further (for more info on our retention periods, click here). 
  3. We will only use your information for to send you these offers, and news items and we don’t share the information with anyone else. 
  4. You can exercise your right to access, rectify, erase, restrict or object to our use of your information in this way, please see our Your Rights section for further information. 

4. Legal Basis for Processing 

 

USING WIFI IN ONE OF OUR VENUES

1. How is your personal data collected? 

  1. When you use our free Wi-Fi access whilst at one of our venues. We use a company called Wireless Social to provide Wi-Fi and they collect your personal data for us. You are able to log in to use Wireless Social’s system with a social media account such as Facebook or sign up manually using a form. 
  2. We will receive personal data about you from Wireless Social as set out below: 
    1. Your Identity Data (name and date of birth); 
    2. Your Contact Data (email address); and 
    3. Information about which of our venues you visited. 

2. Promotional offers from us 

  1. When registering to use our Wi-fi, Wireless Social will ask you if you wish to receive news and exclusive offers from us. We will use this information to contact you about our latest news and offers for all venues within the ETM Group and our affiliated venues (for more information on this click here). 
  2. We will only send this information to you until you unsubscribe or if at the end of our retention period you have not interacted with us or any marketing material further (for more info on our retention periods, click here). 
  3. We will only use your information for to send you our news and latest offers, we may share your information within the ETM Group and with our affiliates venues regarding news and offers in relation to them, we don’t share your information with anyone else. 

3. Legal Basis for Processing 

  1. We rely on the following legal bases to process your data when you use our Wi-Fi and want to receive information about our latest news, promotional offers as well as when we make suggestions and recommendations to you about our venues: 
    1. We process your data in order to provide Wi-Fi services to our customers and to send marketing information to people who consent to receive it. 
    2. We may also send marketing to customers who, when informed that we want to do so, choose not to opt out (soft opt-in).

 

PROVIDING US WITH FEEDBACK

1. How is your personal data collected and processed? 

  1. When you visit one of our venues and provide us with your personal data for example by using our free Wi-Fi service (click here to learn more about what information this includes), a company called Feed It Back may contact you on our behalf after your visit to invite you to send us feedback about your recent visit. 
  2. All feedback provided by you is collected by Feed It Back, a research company commissioned to collect this information on ETM Group’s behalf. All information collected by Feed It Back will be shared with us. 
  3. You can also contact us directly with any queries, complaints or compliments via info@etmgroup.co.uk. In dealing with any queries you may have we may need you to provide personal data to us in order for us to assist. Any personal data provided will be processed in accordance with this privacy policy. 

2. Legal Basis for Processing 

 

USING OUR WEBSITE

1. The data we collect about you 

  1. Identity Data; 
  2. Contact Data; 
  3. Technical Data; 
  4. Usage Data; and 
  5. Marketing and Communications Data. 

2. How is your personal data collected? 

  1. Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign-up to receive marketing from us. 
  2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. 

3. How we use your personal data 

  1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
  2. Generally, we do not rely on consent as a legal basis for processing your personal data when collected through your use of our website. Although, we will get your consent before sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us. 

4. Marketing 

  1. We will use your personal data to send you updates by email about our venues including exclusive offers, and promotions. We do this using the Identity data and Contact data you provide to us when signing up to our news and offers via our website. 
  2. We rely on you providing your consent for us to use your personal data for marketing purposes. If we change our marketing approach in the future, we will update you separately and clearly. 
  3. You have the right to opt out of receiving marketing communications at any time by: 
  4. contacting us at etmgroup.co.uk/contact-us; or 
  5. using the ‘unsubscribe’ link in emails. 
  6. We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business. 

5. Third-party marketing 

  1. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 
  2. This website may 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

6. Legal Basis for Processing 

  1. We rely on the legal basis of  legitimate interest when we process your data when you use our website, the legitimate interests we are pursuing include: 
    1. to study how customers use our website, to develop and grow our business and to inform our marketing strategy; and 
    2. to define types of customers for our venues, to keep our website updated and relevant, to develop our business and to inform our marketing strategy. 

 

PROMOTIONAL PHOTOGRAPHY / VIDEOGRAPHY

 

CAPTURED ON ANY OF OUR CCTV CAMERAS

1. If you appear on any of our CCTV cameras 

  1. We use CCTV technology in our venues to help keep our customers and staff safe and to help us investigate any potentially criminal or unsafe incidents which occur. We are obligated to maintain a CCTV system under the terms of our premises licence. 
  2. Where we have placed CCTV cameras this is to assist in the safety of our customers and staff. Signs will be displayed to show when this is in use and will also display our contact number for any enquiries. 
  3. If you have any questions in relation to our collection of personal data via our CCTV system, please contact us. 

2. Legal Basis for Processing 

  1. We rely on the following legal bases when we record CCTV images when you visit one of our venues: 
    1. We may be required to do so by a licensing authority (legal obligation); and 
    2. We choose to do so for the safety of our customers and staff (legitimate interest). 

 

OTHER WAYS WE COLLECT YOUR DATA

Other than in the circumstances and the ways set out in elsewhere in our privacy policy, we will also process your personal data in the following ways: 

1. To verify your age

2. When we hold competitions, special events and prize draws at our venues

3. When we record promotional videos or interviews or take photos

APPLYING FOR A JOB OR ARE EMPLOYED BY US

1. If you apply for a job with us 

1. In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you: 

    1. The information you have provided to us in your curriculum vitae and covering letter. 
    2. The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications. 
    3. Any information you provide to us during an interview.

2. We may also collect, store and use the following types of more sensitive personal information: 

    1. Information about your race or ethnicity, religious beliefs and sexual orientation. 
    2. Information about your health, including any medical condition, health and sickness records. 
    3. Information about criminal convictions and offences. 

3. Where do we collect your personal data from: 

    1. You, the candidate. 
    2. recruitment agencies. 
    3. background check provider. 
    4. Disclosure and Barring Service in respect of criminal convictions. 
    5. Your named referees. 

4. We will use the personal information we collect about you to: 

    1. Assess your skills, qualifications, and suitability for the role. 
    2. Carry out background and reference checks, where applicable. 
    3. Communicate with you about the recruitment process. 
    4. Keep records related to our hiring processes. 
    5. Comply with legal or regulatory requirements. 

5. We will use your particularly sensitive personal information in the following ways: 

    1. We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview. 
    2. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. 

6. It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role. 

7. We also need to process your personal information to decide whether to enter into a contract of employment with you. 

8. In certain circumstances, we will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are sometimes required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We may be legally required the Home Office (or other relevant alcohol licensing authority) to carry out criminal record checks for those carrying out role. 

2. If you are employed by us 

1. This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical. 

2. We will collect, store and use the following categories of personal information about you: 

    1. Personal contact details such as name, title, addresses, telephone numbers and personal email addresses. 
    2. Date of birth. 
    3. Gender. 
    4. Marital status and dependants. 
    5. Next of kin and emergency contact information. 
    6. National Insurance number. 
    7. Bank account details, payroll records and tax status information. 
    8. Salary, annual leave, pension and benefits information. 
    9. Start date and, if different, the date of your continuous employment. 
    10. Leaving date and your reason for leaving. 
    11. Location of employment or workplace. 
    12. Copy of driving licence. 
    13. Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process). 
    14. Employment records (including job titles, work history, working hours, holidays, training records and professional memberships). 
    15. Compensation history. 
    16. Performance information. 
    17. Disciplinary and grievance information. 
    18. CCTV footage and other information obtained through electronic means such as swipe card records. 
    19. Information about your use of our information and communications systems. 
    20. Photographs. 
    21. Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied. 

3. We may also collect, store and use the following more sensitive types of personal information: 

    1. Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions. 
    2. Information about your health, including any medical condition and sickness records, including: 
      1. details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and 
      2. where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions. 
    3. Information about criminal convictions and offences.

4. We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. 

5. We will collect additional personal information in the course of job-related activities throughout the period of you working for us. 

6. How we will use information about you: We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. Please contact us for more information on which legal bases we rely on when processing your data. 

7. When will we use sensitive personal information: In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below. 

    1. We will use information about your physical or mental health, or disability status, to: 
    2. ensure your health and safety in the workplace; 
    3. assess your fitness to work; 
    4. provide appropriate workplace adjustments; 
    5. monitor and manage sickness absence; and 
    6. administer benefits including statutory maternity pay, statutory sick pay, and pensions. 
    7. We need to process this information to exercise rights and perform obligations in connection with your employment. 
    8. If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being. 
    9. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation to ensure meaningful equal opportunity monitoring and reporting. 

8. Criminal convictions: We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

  

OUR RETENTION PERIODS

We only keep your personal information for as long as necessary, depending on the purpose it was collected for. Below is a summary of how long we retain different types of data:

To make a booking
Indefinitely, unless you exercise your rights of erasure

To conduct customer surveys and receive customer feedback
6 months, after which the data is hashed and anonymised

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
12 months, after which the data is hashed and anonymised

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
12 months, after which the data is hashed and anonymised

To contact you about the latest news, promotions and events as well as make suggestions and recommendations to you about our venues
3 years, after which the data is hashed and anonymised

To record CCTV images
At least 39 days but no longer than 60 days from the date of recording. We may retain this data longer if required to do so as a result of an investigation or claim, or if we are required to do so by the licensing authority

To verify your age
No information retained or recorded unless otherwise needed for another purpose in this policy

To provide competitions, special events and prize draws
3 years, after which the data is hashed and anonymised

To record promotional videos or take photos
Indefinitely, unless you withdraw your consent and request us to remove the content

When you apply for a job with us
12 months, after which it is erased

When you are employed by us or otherwise work for us
6 years, after which it is erased