12 Hay Hill’s Commitment to your Privacy:
12 Hay Hill respects your privacy and your desire to understand how your information will be handled and used. This Policy explains how we collect, use and store your information. Using your information in a way that you are comfortable with and keeping your information secure is an integral part of the luxury hospitality experience we aim to provide. 12 Hay Hill will ensure that all information protection and customer legislation standards are met when handling any of your personal information.
Privacy Statement FAQ:
|Who will use my data?||12 Hay Hill Ltd|
|What for?||We collect, process and store information about you to ensure that we can continue to provide you with a luxury hospitality experience and allow us to; enable us to process and confirm or decline your membership application, maintain your membership by providing you with services, information and access to facilities, send system updates, send offer details, process and store any transaction details, and provide membership support to you.|
|What will happen?||We will use your information to send you systems information and updates, offers and other club updates that we think you will be interested in.|
|What data will be stored?||We will store your membership details, usage info, transactions details, and any preference information we collect as part of you visiting our website.|
|What data will be shared?||We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the rights, property or personal safety of any person.|
|How long?||Your data will be kept for the duration of your active membership and a period of up to 7 years, as outlined in our data retention policy, after which time your account will be deleted.|
|Who can access my data?||We will never sell, share or otherwise distribute your data to any other third party.|
|How is my data kept secure?||We will store your data on secure UK based servers that will be processed in the UK. Such storage is necessary in order to process the information. We use industry standard security protocols/technology to secure data. By registering as a member you agree to this storing, processing and/or transfer.|
We take your privacy seriously and will only use your personal information to administer your membership and to provide the products and services you have requested from us. We will never sell, share or use your personal information other than as described here.
This policy sets out how we will use and share the information that you give us. This policy describes your relationship with 12 Hay Hill Ltd.
Who We Are and How to Contact Us
12 Hay Hill Ltd is a trading name of 12 Hay Hill Ltd that is registered in England and is registered with the Information Commissioner’s Office under the Data Protection Act 1998. The data controller is: 12 Hay Hill. You can get in touch with us in any of the following ways:
Post: Membership, 12 Hay Hill, Mayfair, London, W1J 8NR
How to change your preferences
You can email firstname.lastname@example.org to contact us to change your preferences at any time.
How we operate
We operate in line with EU GDPR (May 2018) data protection guidelines. We are committed to maintaining your personal rights and allow all users to change or withdraw their opt-in options at any time. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office.
12 Hay Hill Ltd is a private members business club. This policy relates to members of 12 Hay Hill Ltd. Processing of your data is required in order to offer you these services. This policy applies to individuals who have registered with 12 Hay Hill Ltd as either a member, guest, administrator, or in any other capacity.
What this policy applies to
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes (as a member):
- Information you provide during the registration process
- Information you provide when you create campaigns
- Information you provide in the form of number data, messages or meta-data
- Information we collect about how you use the website
- Information relating to purchases and other transactions
- Information given and stored as part of our ongoing relationship
Scope of Consent
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to grant you membership or provide you with certain services.
How can you manage the information we hold about you?
As part of our commitment to exceptional customer service, where you have provided your consent, we personalise your experience, by only sending marketing communications about the most exclusive products, services and events that we believe you will be interested in. You can amend or withdraw your consent at any time. You can also choose to object to processing at any time. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please visit www.12hayhill.com or contact us anytime at email@example.com.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
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.
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.
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.
If you would like to contact 12 Hay Hill’s Data Protection Officer, please email firstname.lastname@example.org
How we store and process your data
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.
By law we have to keep basic information about our members (including Contact, Identity, Financial and Transaction Data) for six years after they cease being members (for tax purposes). In some circumstances you can ask us to delete your data: see below for further information. 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 account data will be collected stored and processed within the UK & Ireland only. Your data will be stored as described here or until you request removal of your personal data from our system. Please note that we will be unable to carry out your request to be removed if there is still an open transaction against your account. In order to provide updates and offers that may be of interest to you we use recognised third parties to take payment, manage our company accounts and provide banking services. We will store transactions, payment (this does not include payment card data) and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the EU.
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us
- 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
- Where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, post or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new member||(a) Identity, (b) Contact||Performance of a contract with you|
|To process and deliver your membership services including managing payments, fees and charges, and to collect and recover money owed to us||(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications||(a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us.|
|To enable you to partake in a club events and improve the hospitality you experience.||(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications||(a) Performance of a contract with you, (b) Necessary for our legitimate interests to study how members use our products/services, to develop them and grow our business.|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity, (b) Contact, (c) Technical||(a) 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, (b) Necessary to comply with a legal obligation|
|To deliver relevant content and communication to you and measure and understand the effectiveness of our marketing.||(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical||Necessary for our legitimate interests to study how members use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, member relationships and experiences||(a) Technical, (b) Usage||Necessary for our legitimate interests to define types of members for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile||Necessary for our legitimate interests to develop our products/services and grow our business|
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
By registering as a member you agree to this storing, processing and/or transfer.
We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the Data Protection Act 1998 and the GDPR (2018) in the way we use and share your personal data. Among other things, this means that we will only use your personal data:
- Fairly and lawfully
- As set out in the legislation and this policy
- To the extent necessary for these purposes
We will process your personal data ourselves as the data processor. We will take reasonable precautions to safeguard the personal information that you supply.
12 Hay Hill Ltd may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.
Your data is not shared with any third parties other than as described here.
- The data you submit during the membership enrolment process.
- By giving consent during the membership enrolment to send you marketing information about goods and services that they think you may be interested in, as well as account management or relationship management purposes
In addition we may have to share your personal data with the parties set out below for the purposes set out in the table above:
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
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 such data. 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. We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours.
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 notice of every website you visit.
If you have any queries or concerns about your data usage please contact us.
To ensure your safety and for the prevention and detection of crime, CCTV is in operation during your visit to the club.
Please be aware that if we are requested to provide CCTV images of you or any other personal information relating to you by the police or any other regulatory or government authority investigating suspected illegal activities, we are obliged do so.
Under the Data Protection Act, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
Contacting us, exercising your information rights and Complaints