Privacy policy.

Scope of this Privacy Policy Document

We are The Dark Horse Camden Ltd, registered in England and Wales, Company number 16072771 with its registered office at Windover House, St Ann Street, Salisbury, Wiltshire, SP1 2DR.

We have produced this Privacy Policy in order to keep you informed of how we use your personal data when you (User you or your): (a) use our website at www.thedarkhorsecamden.com, and any sub-domains of this website (unless expressly excluded by their own terms and conditions) (Website) (b) attend The Dark Horse at Camden Stables Market, 87/88 North Yard, Chalk Farm, London, NW18AH (the pub), (c) register for an account on our loyalty program, (d) make a table booking, book tickets for an event (f) receive marketing and promotional information from us about events.

Please read this Privacy Policy carefully. To contact us see ‘Contact Us’ at the end of this Privacy Policy.

Data Protection Legislation

All handling of your personal data is done in compliance with any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the General Data Protection Regulation (EU) 2016/679 (GDPR), and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation.

“Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer. Our Data Protection Lead can be contacted at info@thedarkhorsecamden.com.

For the purposes of the loyalty applicable Data Protection Legislation, we are a data controller in respect of the personal data we collect when you use the Website or register and use the loyalty program.

What personal data do we collect from you?

We may collect, use, store and transfer different kinds of Personal Data about you as detailed in the table below. We have grouped together personal data into the following categories:

Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.

Contact Data such as email addresses and telephone numbers.

Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms; mobile device information; and other technology on the device used to access this Website, some of which is automatically collected.

Usage Data such as analytics relating to how you use the Website

Marketing and Communications Data such as your preferences about receiving communications from us or third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this Privacy Policy.

Our lawful basis for processing personal data

The lawful basis for our use of your Personal Data is detailed in the table below. Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are as follows: (a) ‘your consent’; (b) 'performance of a contract'; (c) 'compliance with a legal obligation'; (d) 'protection of your, or another’s vital interests'; (e) ‘public interest/official authority’; and (f)'our legitimate interests'. Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact info@thedarkhorsecamden.com.

How do we use your data?

Inform you about the change in ownership of the pub and thereafter communicate offers, events, and news about The Dark Horse (only with your consent). If you no longer wish to receive communications from us, you can click the "Unsubscribe" link in any email we send or contact us directly at info@thedarkhorsecamden.com. We will promptly update your preferences.

What personal data do we collect and how do we process your personal data?

Your request to register for an account on our loyalty programme or Website

Whenever you request to register for an account on our loyalty program or Website, we use the personal data that you give us or we collect from you, in order to process your registration.

This processing is conducted lawfully on the basis of your consent and our legitimate interests in providing you with information about our events and merchandise.

Your table booking

Whenever we receive your request and/or order to make a booking we use your personal data you provide to us or we collect from you, in order to manage your order, process payments and fulfil your booking. This processing is conducted lawfully on the basis of performance of our contract with you.

Direct Marketing

If you are a current customer or if you previously attended an event at the pub, or registered for an account or membership or purchased from us or if you opted in to marketing communications, and providing that you haven't opted-out before or since we collected your personal data, we, our affiliates or the third parties listed in the section Third Party Interests below, may occasionally send you marketing information about other goods and services we feel may interest you, (for example membership information or promotions). If do not you want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data. You can always opt-out of receiving marketing emails from us. All future marketing communications will also contain a simple way to opt out of receiving such further communications from us. This processing is conducted lawfully on the basis of our legitimate interests and your consent.

Photographs and filming of you at the pub

The Website, the loyalty program and social media pages relating to the pub contain photos of artists who have performed at the pub as well as members of the public who have been in the pub or attended certain gigs or events. When you enter the pub, you may be filmed or have your photo taken. This will be used for social media posts and to have recent photos of events included on the website. On entering the pub, you will be asked to sign an acknowledgement and consent. This processing is conducted lawfully on the basis of your consent and our legitimate interests in promoting and marketing the pub.

CCTV

We use CCTV at the entrance to the pub, around the perimeter of the pub and inside the pub to:

(a)to prevent and detect crime and protect buildings and assets from damage, disruption, vandalism and other crime;

(b) identify, apprehend and prosecute offenders;

(d) to support law enforcement bodies in the prevention, detection and prosecution of crime;

(e) to assist in day-to-day management, including ensuring the health and safety of staff, visitors and other members of the public;

(f) to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;

(g) dealing with any queries, complaints or enquiries;
(h) ensure the security of our and your property and that of our visitors;
(i) ensure that our policies and procedures are being adhered to;
(j) to assist in the defence of any civil litigation, including employment tribunal proceedings.

This processing is conducted lawfully on the basis our legitimate interests to provide the services to you and protect the pub’s business and license. We operate the CCTV in accordance with our CCTV Policy. We retain CCTV data for 60 days in accordance with our CCTV Policy.

Service improvement/Market Research

Identity Data Contact Data Transaction Data Technical Data

We may use your personal data or aggregate data to improve our products/services; to administer and protect our business and the loyalty program including troubleshooting, data analysis and system testing and/or to monitor trends so we can improve the Website and loyalty program. This processing is conducted lawfully on the basis of our legitimate interest in promoting and marketing our events, promotions, competitions and membership, managing the Website and providing a better service for our customers.

How we collect data

We collect data in the following ways: (a) data is given to us by you, for example through your use of the Website or the loyalty program and your device, or by corresponding with us.. To the extent that you access the Website and on account creation for and usage of the loyalty program, we will collect your data automatically, for example: (a) we automatically collect some information about your visit to the Website or use of the loyalty program, this information helps us to make improvements to Website and loyalty program content and navigation and in the case of the loyalty program. The information we collect includes your IP address, the date, times and frequency with which you access the Website or loyalty program and the way you use and interact with its content; (b) we will collect your data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies"; (c) information about your installation and device, for example, the type of operating system, may be sent to us.

Our Data Processors

Web hosting providers

Website hosting, including the storage of data forming the website content and processing your Technical Data (and Profile Data, where applicable) in order to provide you with access to our websites.

Internal technology providers

• CRM and ERP software providers, whose services we use in order to manage our business with you.

• Telephony providers.

• Office software providers, such as email clients.

• IT Support services, (including CCTV) who might require access to our systems (with our strict supervision) in order to remedy faults with our technology.

• Mobile loyalty program and Web development providers whose service we use in order to develop and maintain our loyalty program through which we provide services to you.

Marketing technology providers

Providers who enable us to send you our marketing emails

Third Party Payment Services Providers

We use these processors so that we can take electronic or card payments securely and without the requirement for you to disclose your card data to us.

Social Media Providers

We post photos and videos taken by us in the pub on social media platforms including, but not limited to, Facebook, Twitter, Instagram and YouTube.

Business to Business relations

If you are an employee of one of our business partners, we may use your personal data (Identity Data and Contact data) to communicate with you and your business about achieving our respective business objectives. This processing is conducted lawfully on the basis of 'performance of a contract' This data may be provided by you directly or referred to us by one of yours or our partners.

What profiling or automated decision-making do we perform?

We do not perform any profiling or automated decision-making based on your personal data.

How long will your personal data be kept?

We hold different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held. We normally retain contract information (including personal data) for 6 years. It may be longer if it is clear that you wish us to continue to retain it either by you indicating this is the case or by making it clear through your actions, for example still visiting the pub. We retain CCTV images for up to sixty (60) days unless we are required by authorities or another legal requirement to retain for longer.

Keeping your data secure

We will use generally accepted industry standards to implement technical and organisational measures to safeguard the personal information you submit to us, both during transmission and once we receive it. However, no method of transmission over the internet (Instagram, YouTube, Facebook, Twitter) or via other devices is 100% secure. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy, but we cannot take responsibility for any unauthorised access or loss of personal data that is beyond our control. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address info@thedarkhorsecamden.com.

What are your rights?

Your rights arising under Data Protection Legislation include: (a) the right to be informed of how your Personal Data is used (through this Privacy Policy); (b) the right to access any personal data held about you; (c) the right to withdraw consent at any time, by opting-out using the options present in communications; (d) the right to rectify any inaccurate or incomplete personal data held about you; (e) the right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy; (f) the right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and (g) the right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted. You can access certain of your personal data held about you by emailing info@thedarkhorsecamden.com with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your account and attaching a photocopy of your driver's license or passport and such other identification documentation we may reasonably request to identify you. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request.

Cookies

A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our Website, which helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. The cookies we use on the Website allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example by ensuring that users are finding what they are looking for easily. For further details, see our Cookie Policy https://www.thedarkhorsecamden.com

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law.

General

You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected. We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of The Dark Horse.. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally supplied to us. We may also disclose data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. This Privacy Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under this Privacy Policy will be subject to the exclusive jurisdiction of the English courts.

Contact Us

If you any questions, comments or requests regarding our use of your personal data, or wish to delete your personal data from the Website or the loyalty program, please contact us by email to: info@thedarkhorsecamden.com or write to us at the following address: The Operations Manager, The Dark Horse at Camden Stables Market, 87/88 North Yard, Chalk Farm, London, NW18AH.