Privacy Policy
WHO is the CONTROLLER of your personal data?
The Brown Jug, Cheltenham (collectively referred to as “we”, “us”, or “our” in this privacy policy) is
the controller of your personal data.
Our Contact Details:
If you have any questions about this privacy notice or our processing activities, we can be contacted
by emailing us through our ‘Email’ link on the Website.
It is important that you read this privacy notice together with our Cookie Policy and our terms of use.
HOW and WHAT data do we collect about you?
We respect your privacy and are committed to protecting your personal data. This privacy notice
describes how we look after your personal data when you:
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– visit our website (“Website“); – use social media profiles where you have agreed for data to be shared with us (“Social – generally engage with us including by contacting us via our Website, email or telephone with |
Personal data, or personal information, means any information about an individual from which that
person can be identified. We collect this information directly from you during any Engagement with
you, as well as automatically through your use of our Website and indirectly from the third party
providers of the .Social Media Platforms or from third party marketing platforms. Depending on the
nature of our interaction with you, we collect different categories of information about you from
time to time which we have grouped together as follows:
| Identity Data | name, username, title and place and date of birth and personal characteristics including age and gender |
| Contact Data | billing address, delivery address, email address and telephone numbers |
| Profile Data | preferences, feedback, survey responses and interests including activities noted on Social Media Platforms (for example, Facebook likes/groups) |
| Technical and Usage Data | information about how you use our products, services, Website and the Wifi Services such as internet protocol (IP) address, cookies, mobile device ID, any login data, browsing history, browser type and version, time zone setting and location, viewed pages with date and time stamp (log information), browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website |
| Marketing and Communications Data | preferences in receiving communications and marketing from us |
| Location Data | GPS-based location information from your use of our Website, the Wifi Services or Social Media Platforms via your smartphone(s), tablet(s) or other devices |
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will be used in accordance
with this privacy notice.
We do not process any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade
union membership, information about your health or genetic and biometric data). Nor do we process
any information about criminal convictions and offences.
We do not knowingly collect personal data relating to children and have age verification processes on
our Website and as part of the Wifi Services. Further, we do not market our products or services to
anyone under the age of 18.
WHY do we collect your personal data?
We collect the above categories of personal data about you for the following purposes:
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– To communicate with you – this includes where we manage our relationship with you, where – To maintain and optimise our Website – this includes where we need to solve performance – To protect our business and prevent or detect crime – this includes the use of CCTV; – To improve our marketing strategies by creating profiled audience segments so that we can – To satisfy our legal obligations and to defend and exercise our legal rights.
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We will only use your personal data for the purposes above, unless we reasonably consider that we
have another appropriate reason and that reason is compatible with the original purpose. 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.
Further information on the circumstances in which we collect your data is available in Appendix 1 of
this privacy notice.
What is our LEGAL BASIS for collecting your Data?
Under data protection laws, we must have a legal basis under which we process your personal data.
When we collect and use your information, we do so under one of the following:
1. We have a legitimate interest as a business;
2. To perform a contract we have with you;
3. To comply with a legal obligation; or
4. If you have given us your consent
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Legitimate Interest as a business means conducting and managing our business to enable us to give
Performance of Contract means processing your data where it is necessary for the performance of a Compliance with a legal or regulatory obligation means processing your personal data where it is With your consent, this can only be relied on by us as a legal basis for processing where your consent |
Further information on the relevant purposes and linked legal basis are set out in Appendix 1 of this
privacy notice.
Where we need to collect personal data due to a legal or regulatory obligation, or in relation to the
performance of a contract, and you do not provide that data when requested, we may not be able to
perform the contract we have or are trying to enter into with you (for example, to provide you with
goods or services). We will notify you of this at the time.
WHO do we share your personal data with?
In order to ensure that we provide the best service to you, we may from time to time have to share
your personal data with the parties set out below for the purposes and on the legal basis as set out
in the table in Appendix 1:
– External third parties – we share your personal data with third parties which include:
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– first and third party advertising companies and media agencies for marketing and research – marketing agencies based within and outside the EEA and UK who provide promotional and – our data storage provider(s) based within the EEA and UK who securely stores consumer – third party providers of social media platforms (including Facebook); – courts, parties to litigation and professional advisers where we reasonably deem it – a purchaser or parties interested in purchasing any part of our business |
We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. Where third parties act as processors on our behalf, we only permit them to process
your personal data for specified purposes and in line with our instructions.
International transfers
Our external third parties may be based outside the UK or the EEA. Whenever we transfer your
personal data out of the UK or the EEA, we ensure that the same level of protection is afforded to it
by ensuring at least one of the following safeguards are put in place:
– We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission. For further
details, see European Commission: Adequacy of the protection of personal data in non-EU
countries;
– Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe. For
further details, see European Commission: Model contracts for the transfer of personal data
to third countries; and
– Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared
between the Europe and the US. For further details, see European Commission: EU-US
Privacy Shield.
How SECURE is my data?
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 are subject to a duty of confidentiality.
Unfortunately, no transmission of information over the internet can be completely secure, and you
should also note that the security of information depends in part on the security of the computer
you use to communicate with us and the security you use to protect account information and
passwords, so please take care to protect this information.
Our Website includes 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, plug-ins or applications and are not responsible for their privacy
statements. We encourage you to read the privacy notice of every website you visit and third party
service/application that you use.
How LONG will my personal data be used for?
We will only retain your personal data to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements. Further retention details for
specific aspects of your personal data are noted in Appendix 1.
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.
What MARKETING and PROFILING activities do we carry out?
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We may use your Identity Data, Profile Data, Technical and Usage Data
and Location Data to form a view on what we think you may want or what may be of interest to you
and to understand your purchasing trends. This profiling activity is used as part of how we decide
which products, services and offers may be relevant (we call this marketing).
You will receive tailored marketing communications from us if you have:
– requested information from us;
– purchased goods or services from us; and/or
– provided your details for the purposes entering a competition or registering for a promotion
You will not receive marketing communications from us in any of the above scenarios if you have
opted out of receiving that marketing. Where you have not opted out, you will only receive
marketing communications from us in the above scenarios if the marketing is confined to online
advertisements or marketing that is not direct to you. We will only send direct electronic marketing
(e.g. via emails or SMS), where we have your express opt-in consent.
You can ask us, or third parties acting on our behalf, to stop sending you marketing messages at any
time by emailing us through our ‘Email’ link on the Website . Where you opt out of receiving these
marketing messages, we will no longer conduct any marketing unless you opt-in again at a later
point. Please note that where we have another lawful basis for processing, we will continue to
process personal data for other purposes – for example, we may process information provided to us
in connection with an Engagement on the basis of contract necessity.
You can also set your browser or device to refuse all or some cookies including advertising cookies –
please see our separate Cookie policy or more detail on this.
Please note that other than the profiling activities described here, we do not carry out any
automated decision making processes which could have a legal or significant impact on you
What are my RIGHTS?
Under certain circumstances, you have various rights in relation to your personal data under data
protection laws. If you wish to exercise any of these rights, please email us through our ‘Email’ link on
the Website.
You will not have to pay a fee to access your data or exercise any of your other rights, but please note
that 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.
In order to respond to any request in relation to your data access rights, we may need to request
specific information from you to help us confirm your identity. 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.
You have the right to:
| 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 overrides your rights and freedoms. |
You also have the right to:
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– Request access to your personal data (commonly known as a “data subject access request“).
– 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, or where you have successfully exercised your right to object to processing (see box above); – Request restriction of processing of your personal data. This enables you to ask us to – Request the transfer of your personal data to you or to a third party. We will provide to 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 services to you. We will advise you if this is the case at the time you withdraw your consent. |
You also 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 using the details at the start of this notice.
This version was last updated in January 2020.
Appendix 1
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
Retention period |
| Where we perform the contract we have in place with you for the purchase of products, including managing payments, fees and charges |
– Identity – Contact -Financial and Transactional Data |
Performance of a contract with you; and To perform our legal obligations |
After the duration of your contract with us has expired, our online sales records will be retained by us for 7 years or longer if required by tax or corporate bookkeeping |
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To manage our – responding to any specific requests made by you; – sending you newsletters or alerts that you have asked to receive; – notifying you about changes to our terms or privacy policy |
– Contact – Profile – Usage – Marketing and Communications |
Necessary for our legitimate interests (for running our business) |
1 year from when the compliant/issue/incident is resolved If you no longer wish to receive any e-mails/alerts from us, you can unsubscribe at any time, and we will remove your email address within 30 days of receiving your unsubscribe notification, unless it requires to be retained for other purposes as listed in this privacy notice |
| To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
– Identity – Contact – Technical and Usage |
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); and Necessary to comply with a legal obligation |
26 months from Website visit |
| To deter crime and ensure the personal safety and security of visitors and staff through the use of CCTV |
– Identity | Necessary for our legitimate interests (to protect the safety and security of visitors and staff and assist in criminal investigations) |
Video footage will be retained for a limited time before it is automatically deleted. The retention of CCTV is determined by any specific requirements as specified by the local licensing authority in the premises licence, as well the need to investigate health and safety incidents or criminal incidents, including in connection with any legal proceedings or requests from law enforcement authorities |
| To make suggestions and recommendations to you about goods or services that may be of interest to you and to issue tailored marketing content and offers to you |
– Contact – Profile – Technical and Usage – Marketing and Communications – Location |
Necessary for our legitimate interests (to maintain the relevance of our brand and reputation and to grow our business by issuing tailored offers); and Where required by privacy laws and for any direct marketing, consent |
Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable, after which point it will be anonymised save that we will retain details of the opt-out/objection |