GUNPOWDER RESTAURANTS PRIVACY POLICY

Introduction

Welcome to Gunpowder’s privacy policy. 

Gunpowder 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 when you visit our Website (as defined below) regardless of where you visit it from and tell you about your privacy rights and how the law protects you. 

  1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Gunpowder collects and processes your personal data when you sign up to our newsletter via our website at https://www.gunpowderlondon.com and its associated sub-domains (the “Website”), and when you provide your information to us as part of making a reservation including with opentable.co.uk (“OpenTable”), our reservation provider. 

We do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them. 

Controller

Gunpowder Restaurants Limited (company number 09636955) (referred to as  “Gunpowder”, “we“, “us” or “our” in this privacy policy) is a data controller in respect of personal data provided by our clients and suppliers. 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

Contact details

Our full details are:

Full name of legal entity: Gunpowder Restaurants Limited (company number 09636955)

Name or title of data privacy manager: Nirmal Save

Email address: nirmal@gunpowderlondon.com

Postal address: 24 Bedford Row, London, WC1R 4TQ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

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

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name and username or similar identifier.
  • Contact Data includes address, email address and telephone number.
  • Booking Data includes information about reservations made by you with us.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Contact Data and Marketing and Communications Data by signing up to our mailing list and/or making a reservation with us. This includes personal data you provide when you:
  • make a reservation with us including via OpenTable;
  • sign up to our mailing list; or
  • give us some feedback. 
  • Third parties or publicly available sources. We may receive personal data about you from Open Table when you make a booking via OpenTable.
  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to make a reservation for you and/or process or handle the reservation.
  • In order to provide our services to you. 
  • (Where you have signed up to our mailing list) to send you targeted relevant marketing communications. 
  • 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.

Other than in respect of direct marketing communications where you have signed up to our mailing list, we do not use consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that 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 contact 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/ActivityType of dataLawful basis for processing including basis of legitimate interest
To make, amend or cancel a reservation(a) Identity  (b) Contact (c) BookingPerformance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey(a) Identity  (b) Contact  (c) Booking (d) Marketing and Communications(a) Performance of a contract with you  (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity  (b) Contact  (c) Booking (d) Marketing and CommunicationNecessary for our legitimate interests (to develop our products/services and grow our business)
To send you relevant targeted marketing communicationsMarketing and CommunicationConsent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.

Promotional offers from us 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.

You will receive marketing communications from us if you have requested information from us or signed up to our newsletter and, in each case, you have not opted out of receiving that marketing.

Third-party marketing 

We will not share your personal data with any company for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you purchasing services from us.

Cookies

We do not use cookies on our Website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

Change of purpose 

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may have to share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

We do not transfer your personal data outside the European Economic Area (“EEA”)  or European Union. 

  1. Data security

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. 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.

  1. Data retention

How long will you use my personal data for?

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. Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Erasure Request below for further information. In some circumstances 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. 

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (if applicable) and/or in order for us to meet our record-keeping obligations. In order to keep a record of your erasure request we may continue to hold your name and company name only in our database, which would be notified to you. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.