1) Who we are

We are Hydes’ Brewery Limited, a company incorporated in England and Wales with company number 00126186 whose registered office address is at the Beer Studio, 30 Kansas Avenue, Salford M50 2GL (referred to in this privacy notice as “Hydes“, “we“, “our” or “us“).

We are also registered with the Information Commissioner’s Officer with registration number Z7036581.

2) How we collect your personal data and why

How we collect personal data

We may need to collect personal data about you, and there are different ways that we might do so; this privacy notice (notice) tells you what to expect when we collect personal data from:

• visitors to our our main website and our pub websites (you can see all our pubs here);
• anyone who contacts us through our websites or otherwise;
• anyone who interacts with us or contacts us through social media;
• anyone who provides customer feedback via a ‘comment card’ or other method;
• anyone who makes a purchase and/or booking through our websites or online portals;
• anyone who enters a competition through one of our websites or otherwise (for example via social media);
• anyone who applies for a job or tenancy through our websites;
• visitors to our premises where data images are captured on CCTV/ camera and
• anyone who uses our, or any of our premises’, free wifi.
  • Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation.

In Sections 2.2 – 2.8 below, we will specify one of the following legal bases for each usage of your personal data:

• Where we need information to perform the contract we have entered into with you;
• Where we need to comply with a legal obligation; or
• 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.

Visitors to our websites

When you visit our websites, we will collect technical information about how you use the website, including your IP addresses, device identifiers and information about how long you have stayed on certain pages or what pages you have clicked on. We process this personal data for the purposes of monitoring and analysing use of our websites so that we can improve the websites. We do this on the basis that it is in our legitimate interests to so. We have an interest in ensuring that we continue to improve our websites and provide our users with the best and most effective websites possible.

We also use cookies, which may collect information about you. Please see Section 7 – Cookies below for more information.

Online bookings/purchases

You can book tables, order food, drink, and accommodation online through our pub websites/ Hydes order and pay portal. If you make a booking/purchase, we will ask you for your full name (including title), telephone number, address, email address, details of the booking/purchase and any special requests, for example dietary or accessibility requirements.

For multiple room bookings, we will also collect a guest name for each room, which can be your name or another guest’s. If you give us another guest’s name, you should make sure they are aware that we will process their data in accordance with this policy.

Please note that if you include any “special categories of personal data” in your booking/purchase request (for example, information about your health, race, religion or sexual orientation), it is your responsibility to make sure you are happy for us to use that personal data in accordance with this privacy notice. You should be aware that this personal data is more sensitive and is more heavily protected by data protection legislation. If you need to make us aware of a dietary or accessibility requirement, you should make sure that you do not reveal information about the person or condition to which the requirement applies.

We process this personal data in order to process your request and to make sure that we can deliver appropriate service to you.

All of our hotel guests are required to complete a registration card showing full name (including title), address and telephone number. If you are an international guest booking a room at one of our hotels, we will also take a note of your passport number and collect your date of birth and country of residence.

We process personal data for table and room bookings and for food and drink purchases on the basis that it is necessary to perform our contract with you to provide you with our online ordering/booking service and/or to provide you with an account. If you do provide us with any special categories of personal data as part of this process, we process this either on the basis that we have a legal obligation to make reasonable adjustments (for example for someone with a disability) or on the basis that you have provided your consent by sending us these details.

We use a payment gateway for processing financial details relating to bookings/purchases (for example, to take deposit payments to secure room bookings or when making food and drink purchases. The payment gateway does not share your payment details with us, but may share any contact details you provide to them that are different to what you have provided to us for the purpose of processing your purchase.

Personal data collected when you book /purchase online is retained for as long as required, but for up to 7 years (unless we need to keep it for longer to deal with a complaint or claim that you raise).

Contacting us

Our websites provide you with different ways to contact us. All communications are handled, reviewed and responded to internally by us.

If you contact us using the e mail link or contact form on one our websites or by e mail or telephone, we collect any information you provide to us during that contact, such as your full name (including title), telephone number, email address, type of enquiry and your message. We will also collect any additional personal data that you provide to us in your message. If you visit one of our pubs and fill in a comment card or other method of giving customer feedback, we will collect the information you choose to provide on that card, including your name, email address, postal address, date of birth and any comments you choose to include. We use this information to ensure that we are continuing to analyse and improve our business and take on board customer feedback. We also use it for marketing and promotional purposes if you consent to us doing so. More information about this is set out under “Marketing” below.

If you include any “special categories of personal data” in your message or communication (for example, information about your health, race, religion or sexual orientation), it is your responsibility to make sure you are happy for us to use that personal data in accordance with this privacy policy. You should be aware that this personal data is more sensitive and is more heavily protected by data protection legislation, so you should avoid including this kind of data if possible.

Any personal data that is provided in and during communications with us is used only for the purpose of reviewing the communications and conducting the ongoing administration and management of communications. We will not use your personal data in an identifiable manner in any publication without your further explicit consent.

This personal data is processed on the basis of our legitimate interests. We have an interest in ensuring that we respond to all communications to make sure that any queries and issues raised by our customers and website users are appropriately dealt with so that we continue to maintain high standards of care for our customers.

We will delete this personal data when we reasonably consider that we no longer need it for this purpose.  In any case, we will delete all communications that are more than 7 years old (unless we need to keep them for longer to respond to any claim or complaint that you raise).

Please note that we may need to contact you about your enquiry through email or telephone. You should make sure that you keep us updated of any changes to your contact details. If your contact details change during the course of our communications with you, please let us know by contacting us using the details set out under Section 9 – How to contact us below.

Please also note that we use email monitoring or blocking software to ensure that only emails that are legal reach us. You have a responsibility to ensure that any email you send to us is within the bounds of the law (for example, it does not include any illegal, discriminatory or sexually explicit content and it is not fraudulent);

CCTV Images/photos

We use CCTV images and camera photos to deter and detect crime and civil offences, to support court action, to support local ‘Pubwatch’ groups and to comply with our licensing requirements.

CCTV images are routinely cleared from our systems after 30 days but may on occasions be retained for longer, but only for as long as necessary, to assist the investigation of an incident. Photographs are held no longer than necessary.

WiFi

When you use the free wifi service (WiFi) at any of our premises we will need to process personal data about you. We will receive the following information from the WiFi service provider who manages the WiFi registration process:

• your contact details, including your name, address, email address and postal address;
• your date of birth and mobile number (if you have provided these details during registration); and
• the location and name of our premises that you are accessing the WiFi from.

We process this data to allow you to use the WiFi service on the basis that it is necessary to do so to perform the contract we have entered into with you to provide the WiFi.

As part of the WiFi service, we engage a WiFi service provider who will help to maintain the security and the performance of the WiFi. We recommend that you read the provider’s privacy notice by clicking through to their website from the WiFi registration page to understand how they will use your data in providing the WiFi and contact them directly if you have any concerns regarding their use of your personal data.

Social media

Our websites contain links to our social media pages. We collect information that you choose to post publicly about yourself in connection with posts about Hydes, such as “likes”, “follows”, “shares”, “tags”, “comments” and “retweets”. We use this information for internal analysis purposes to see what people are saying about Hydes, our business and our pubs so that we can use that feedback to improve our services. We will also use some of this information to contact you via social media if, for example, you raise a complaint. For example, if you tag us in a tweet about problems you’ve had with our service, we may respond to that tweet and tag you in our own tweet to respond to your comment.

We will also collect personal data about you when you contact us via social media, including your name, social media profile information and any other information you choose to provide to us in the course of that contact.  We use that information in accordance with Section 2 – Contacting us above, for the purposes only of handling and responding to your correspondence, on the basis of our legitimate interests as set out in that section.

We keep this personal data for 7 years, unless we need to keep it for longer to respond to any claim or complaint that you raise.

Any information you provide to us via social media (including messaging, “liking”, “following” and other communications) is also accessible by and controlled by the relevant social media network. We currently use:

• Facebook, which has its own privacy notice that can be located at https://www.facebook.com/privacy/explanation;
• Linkedin, which has its own privacy notice that can be located at https://www.linkedin.com/legal/privacy-policy;
• Instagram, which has its own privacy notice that can be located at https://help.instagram.com/155833707900388; and
• Twitter, which has its own privacy notice that can be located at https://twitter.com/en/privacy.

You should always bear in mind that when you post publicly, everyone will be able to see your posts and the relevant social media network will be able to see and use any information within your posts in accordance with their privacy notices. We recommend that you read their privacy notices and contact them directly if you have any concerns regarding their use of your personal data.

Personal data collected through competitions

We will collect your contact details (name and email address) in our legitimate interest and the legitimate interest of the provider of the relevant prize, if you have opted to enter a competition listed on one of our websites or elsewhere (e.g. on social media). We and the provider have a legitimate interest in running competitions to promote our businesses. Any contact details collected will be used by us to administer the competition and contact details of the winner will be passed on to the provider of the relevant prize to allow them to send the prize to the winner.

Personal data collected when applying for jobs

When you apply for a job or tenancy through our website, we will collect your contact details (name, address, telephone number and email address) and any information contained in your CV (together with any further information we obtain about you through the application process, for example during your interview) for the purposes of processing your application, contacting you in relation to it and deciding whether to offer you a role. We do this on the basis that it in our legitimate interest to collect and process applicant information to ensure that we recruit the most suitable candidates. If we need to obtain a reference about you from a third party, we will ask you for your consent to do this.

If you are successful in your application, we will retain your personal data and a copy of your CV in accordance with our Employee Privacy Notice, which will be provided to you on induction.

If you are unsuccessful, we will retain your personal data and a copy of your CV for one year after informing you of the outcome of the application process. This is for our own record-keeping purposes in our legitimate interests.

If you provide us with any special categories of personal data during the application process (for example, information about your health, race, religion or sexual orientation), it is your responsibility to make sure you are happy for us to use that personal data in accordance with this privacy policy. You should be aware that this personal data is more sensitive and is more heavily protected by data protection legislation. You should avoid providing us with this information unless absolutely necessary.

3) Marketing

Where you have consented to us doing so, we will use your email address and/or your telephone number to send you emails or texts for marketing purposes. We will provide you with a clear choice when we collect your personal data to opt into receiving marketing materials.

We sometimes run promotions, for example if you provide us with your date of birth on a comment card in a pub, we might give you a free bottle of wine on your birthday if you have consented to us contacting you using the details you provide for promotional purposes. If you participate in these promotions we will use your personal data the purposes of facilitating the promotion on the basis that we have a legitimate interest in running promotions to promote our business.

We use a third party service provider to manage our marketing communications. If you ever decide you no longer wish to receive our marketing communications, you can do so at any time by unsubscribing from the mailing list using the customer preference link provided in the marketing communication. If you do unsubscribe your details will be deleted and you will not receive further marketing communications.

4) Disclosure of personal data

We sometimes need to share your data with third parties for legitimate purposes as set out in this section.

Third party services

We need to share your personal data with third parties who provide services to us to enable them to provide their services. Where we do so, we will always make sure that those third parties protect your personal data in the same way that we do. Details of where we use third party services are as follows:

• Our websites are managed by a third party service provider. As part of the service provided by that provider, they will help to maintain the security and the performance of our websites by: (i) protecting user connections; (ii) using third party scanning services to scan against known web attacks; (iii) investigating site errors; and (iv) providing secure hosting services.
• If you apply for a job or tenancy through one of our websites, we use a third party online recruitment service provider to process our online applications.
• where communication is made in a language other than English, we will use third party translation services to translate the communication or application and all of its content; the third party will not use the personal data for any other purpose;
• Whenever you visit one of our websites, our website hosting provider will use a third party service, Google Analytics, on our behalf and for our legitimate interests in improving our website, to collect standard information about your website use, such as internet logs and details of your visitor behaviour patterns. The reason we use this service is so that we can find out how many people visit the website and the various parts of the website. This information helps us to find out how our websites are working and how to improve them. We do not identify anyone, and we do not make or allow Google Analytics to (or attempt to) identify anyone visiting our websites.
• We use a third party service provider to send you booking confirmation emails after you have booked online. The third party is only provided with your email address and will never use it for any other purpose.
• We have YouTube video content embedded on some of our websites. YouTube controls any information that is collected by viewing their content. YouTube’s privacy policy can be located at https://www.google.co.uk/intl/en-GB/policies/privacy/.

We will not usually disclose your personal data other than as set out above. However, there may be circumstances where we need to share personal data other than as anticipated above. These include:

• where we are legally required to disclose the information, for example because a court orders us to do so;
• where the disclosure of the personal data is required for the purposes of the prevention and detection of crime. This includes sharing the personal data with tax authorities and law enforcement agencies;
• where we need to disclose the personal data for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
• where disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance); and
• to any actual or prospective purchaser of our business assets or organisation.

We do not transfer or store your data outside the UK and the EEA. If we do need to do so, we will update this Privacy Policy and we will put measures in place to make sure that the third party we transfer it to protects your data in the same way that it would be protected in the UK.

5) Keeping personal data secure

We know that you provide your personal data in good faith and expect it to be looked after. This is why we take the security of your personal data seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal data. This includes:

• keeping all personal data that we control on secure servers;
• ensuring strict access controls on a need to know basis;
• monitoring access to the personal data; and
• encryption of the personal data on our servers.

6) Your rights

You have rights in respect of your personal data and this Section explains a bit more about those rights that are applicable to what we do with your personal data and when you can exercise them. If you would like more information about any of your rights, please contact us on the details set out below.

Accessing your personal data

We want you to fully understand and be comfortable with how we use your personal data. The purposes for which we use your personal data are set out in this privacy notice.

In addition, you can contact us at any time to ask whether we process any personal data about you. If we do hold or use your personal data in any way, you have the right to access that personal data. All we ask is that:

• you make your request to access your personal data in writing to the contact details below;
• you provide any documents we ask for so that we can verify your identity; and
• you are fair and reasonable with how often you make this kind of request.

Please allow us up to one month from receipt of your request in order to provide a response. If your request is particularly complex or you have made numerous requests, it may take up to three months from receipt to respond. We will let you know if this is going to be the case.

Requesting more information

We have tried to be as clear and as open as we can in this privacy notice about how we use your personal data and we will continue to update this notice as our use of personal data develops. However, if you have any questions regarding our use of your personal data, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details below.

Additional rights

As well as the right of access above, you also have some additional rights that you may exercise as set out here. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses below and provide verification of your identity.

• You have the right to request that we rectify any inaccurate personal data about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address);
• You have the right to request that we erase your personal data. Please be aware that we can only comply with such a request if:
  • your personal data is no longer required for the purposes it was collected for (for example, if we needed your personal data to respond to a communication and the communication has now been responded to and we don’t need to keep your personal data for anything else);
  • the personal data has been unlawfully processed;
  • the personal data needs to be deleted to comply with a legal obligation; or
  • you have objected to the processing in accordance with 3.5 below and we don’t have any other legitimate reason to process your personal data.

We will not be able to comply with a request for erasure if your personal data is required for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings, if the processing is required to comply with a legal obligation or if the processing is in the public interest.

• You have the right to request that we restrict processing of your personal data (which means that we only store your personal data and do not carry out any further processing with it):
  • for the time it takes us to verify the accuracy of your personal data where you have disputed its accuracy;
  • where the collection, storage or use of the personal data by us is unlawful but you decide not to ask for erasure;
  • where we no longer need your personal data but you need the data for the purposes of establishing, exercising or defending a legal claim; or
  • for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal data, where you have exercised your right to object to processing.
• You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into or performing a contract. This means that you have the right to have a copy of your personal data transferred to you in a common electronic format, so that you can transfer it easily to another company. If you exercise this right, we will transfer a copy of the information that you have provided to us ­­­as soon as we can and in any event within one month of your request.
• You have the right to object to our use of your personal data:
  • where we are using that information based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal data; or
  • at any time, where we use your personal data to send you the newsletter or any other type of direct marketing, in which case it will no longer be used for that purpose, but we may use it for another lawful purpose.

7) Cookies

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your device.  Like most websites, we use cookies on our websites for our legitimate interests. There are different types of cookies that we use for different purposes; however generally speaking cookies help us to distinguish you from other users of our website, which allows us to provide you a better experience and also allows us to improve our website/s.

You can block cookies at any time by activating the setting on your browser that allows you to refuse some or all cookies. However, if you do block cookies there may be parts of our websites that you will be unable to access or that will not function properly.

Our cookies help to:

• make our websites work as you would expect;
• remember your settings during and between visits;
• improve your and other users’ experiences of our websites;
• allowing you to sign up to marketing and updates if you have requested to do so;
• remembering if we have already asked you certain questions; and
• improve the speed/security of our websites.

We use the following types of cookies:

Strictly necessary cookies

These are cookies that are essential for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites or use our online booking services.

Analytical/performance cookies

They allow us to recognise and count the number of visitors and to see how visitors move around our websites when they are using them. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognise you when you come back to our websites so that we can personalise our content for you and remember your preferences (for example, your region).

8) Complaints

You are important to us, and so is protecting your personal data. We have high standards when it comes to collecting and using personal data. For this reason, we take any complaints we receive from you about our use of your personal data very seriously and request that you bring any issues to our attention.

Where you are communicating with us for the purpose of making a complaint, we will only use your personal data to handle, investigate and respond to the complaint and to check on the level of service we provide. Where the complaint is about a member of our company, we may have to disclose your identity to whoever the complaint is about. You may let us know that you don’t want information that identifies you to be disclosed and we will try to respect your request; however, it may not be always possible to handle a complaint on an anonymous basis.

If you are unhappy, you can also contact the Information Commissioner’s office to make a complaint directly.

9) Updating this privacy notice

We keep our notice under regular review in order to ensure that it properly reflects our use of personal data. This notice was last updated on 26^th August 2021

10)How to contact us

You can contact us by:

Post:  Finance Director or Company Secretary at Hydes’ Brewery Limited, The Beer Studio, 30 Kansas Avenue, Salford, M50 2GL

Email: mail@hydesbrewery.com

Telephone: 0161 226 1317