1. What is this?
At Club Global Ltd (referred to as “we”, “us”, “our”) we take privacy seriously and we are committed to protecting it.
This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure. It relates to the Club Global mobile application software (“App”) and the services accessible through the App once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”).
Club Global Ltd (a company registered in England and Wales with company number 10791248) is the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.
This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.
2. PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
When you use the App, our products or services, the categories of information that we may collect about you are as follows:
Personal information you give to us:
Information you give to us voluntarily: This is information about you that you give to us by entering information via:
- the App;
- linked social media platforms;
- corresponding with us by phone, email or otherwise,
and is provided entirely voluntarily. This includes information provided at the time of registering through the App, booking VIP areas, tables, booths, or otherwise including the purchasing of any products through the App for any venue advertised on the App, including but not limited to any nightclub, bar, pub or live music venue in the United Kingdom (“Venue”) or requesting further products on the App (including engaging in correspondence with us by phone, email or otherwise). This consists of the following categories of information:
- Emial address
- Contact telephone number
- Date of birth
- Cardholder and payment details
- Details of Venue bookings, orders you place and transactions
- Information contained in our correspondence or other communications with you about our products or business
- Information relating to the sale of products or services, including Venue bookings
- Your marketing preferences
- Other: We may also ask you for information when you report a problem with the App. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well, including your name, address, email address, phone number and enquiry details, which may include records of any correspondence and responses to any surveys.
Personal information we collect about you:
- Information we collect about you and your Device: We may automatically collect information about you, such as details of transactions you carry out through your visits to the App, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer/Device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, your Device IMEI and other technical information about your Device. Please see Cookies for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform].
- Facebook and social media: You may choose to integrate your account with social media platforms including Facebook, Instagram and Twitter. By doing so you authorise us to collect your information, such as your username, encrypted access credentials, and other information, that may be available on or through your social media account. Such information may include your name, profile picture, country, hometown, e-mail address, date of birth, gender, and profile pictures and networks. We may store this information and use it for the purposes explained in here and to verify your credentials with social media platforms.
- Location data: We use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings, but please be aware that this will impact your ability to use these features.
Personal information we may receive from other sources: We may obtain certain personal information about you from sources outside of our business including our third party partners which may include the following: social media providers (for example Instagram, Facebook and Twitter); and mobile service providers. The personal information received is as described in the paragraphs above.
3. HOW WE USE YOUR PERSONAL INFORMATION
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
- To contact you via email or text with marketing information about our services if you (i) register for an account with us online via the App and indicate that you would like to receive such marketing from us; (ii) sign up to our newsletter, emails/ texts via the App or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so; or
- To share your data with other recommended third party partners for them to contact you with marketing information about their products and services. Please use the link on the relevant page to find out more about these third parties and the Marketing section below in this policy.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
Where it is required to complete a CONTRACT
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
- for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services or share your details with third parties to do the same, as explained above);
- for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on the App);
- to correspond or communicate with you;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the management of queries, complaints, or claims; and
- for the establishment and defence of our legal rights.
Where there is a LEGAL REQUIREMENT
We will use your personal information to comply with our legal obligations: (i) to assist any public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you.
4. DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION
Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
5. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
Our suppliers and service providers: We may disclose your information to our third party Venues, service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include: Venues, cloud service providers (such as hosting and email management), advertising agencies and administrative services.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Third parties who provide products and services: We may work closely with various third parties to bring you a range of products and services that are complementary to those that we provide. In particular, we may offer experience packages, events or parties in respect of Venues or other establishments. When you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.
Credit/debit card payment processors: When you purchase any products or services through the App, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
Customer satisfaction surveys: As customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services.
Other ways we may share your personal information: We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
6. WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA), and/or the United Kingdom (if at any point the United Kingdom ceases to be within the EEA).
If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.
7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
8. SECURITY AND LINKS TO OTHER SITES
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the App and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we collect any sensitive personal information about your ethnic background, sex life, political opinions, religion, trade union membership of criminal record, we will apply additional security controls to protect that data.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
The App may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
Like many other mobile apps and websites, the App may us cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to the App). 'Cookies' are small pieces of information sent to your computer or Device and stored on its hard drive to allow the App to recognise you when you visit.
10. OUR MARKETING
We may collect your preferences to receive marketing information directly from us in the following ways:
- When you register for an account with the App and indicate that you would like to receive marketing information directly from us;
- If you place a booking with a Venue and indicate that you would like to receive marketing information; or
- When you revise your marketing preferences or when responding to a request from us to do so.
If you do not complete a booking or purchase and have not indicated that you would prefer otherwise, we may send a reminder to you about your incomplete booking or purchase.
We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.
11. THIRD PARTY MARKETING
You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your Consent and Objecting to our use of your personal information and automated decisions made about you above for further details on how you can do this.
12. YOUR RIGHTS
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of your information is important to us. If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know or update your profile information directly in the App.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Objecting to our use of your personal information and automated decisions made about you
Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as set out under How we use your personal information, you may object to us using your personal information for these purposes. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
You may also contest a decision made about you based on automated processing.
Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal information in a structured data file (“data portability”)
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details. If you have any concerns about the way we have handled your personal information, we encourage you to contact us and we will seek to resolve any issues or concerns you may have.
13. CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on the App and by notifying you next time you start or login to the App. We recommend you regularly check for changes and review this policy whenever you visit the App. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.
14. CONTACT US
- Email: [INFO@CLUBGLOBAL.COM] with the email subject heading ‘Data Protection’