We take your privacy seriously and we respect your privacy and data protection rights. This privacy notice aims to give you information on how we collect and process your personal data through your use of our websites, mobile apps and our services, including any data you may provide through our websites, mobile apps and our services when you sign up to receive news, offers, promotions and updates, book a table with us, take part in a competition, complete a survey, provide feedback, use our Wi-Fi, use our mobile apps, or otherwise purchase a product or service (such as ordering a takeaway and buying a gift card).
Please take time to read this privacy notice in full, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you understand and are happy with how we collect and process your personal data. This privacy notice supplements the other notices and is not intended to override them.
Mitchells & Butlers is made up of different legal entities, brands and outlets, details of which can be found at www.mbplc.com (Group). This privacy notice is issued by Mitchells & Butlers Leisure Retail Limited (company number 01001181 with its registered office at 27 Fleet Street, Birmingham B3 1JP) on behalf of the Group so when we refer to “we”, “us” or “our” in this privacy notice, we are referring to the relevant company within the Group that is responsible for processing your data. Mitchells & Butlers Leisure Retail Limited is the controller and is responsible for our websites, mobile apps and this service.
We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details below:
Our full details are:
Data Protection Officer
27 Fleet Street, Birmingham B3 1JP
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
We will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for the flags on our websites and materials that indicates we have changed this privacy notice. If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes.
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our websites, mobile apps and/or the service may include 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 and are not responsible for their privacy statements. When you leave our website, mobile app and/or service, we encourage you to read the privacy notice of every website, plug-in and/or application that you visit.
Personal data 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 process different kinds of personal data about you, which we have categorised as follows:
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.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to 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 products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
In certain situations we have to collect Sensitive Data about you. Under data protection law this is known as “special category” data and includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data.
When do we process Sensitive Data? We only collect and process Sensitive Data where you provide such information to us in the following situations:
Children need particular protection where their data is collected and processed. We may collect and process Children’s Data in certain situations as described below.
When do we process Children’s Data? We only collect and process Children’s Data in the following situations:
We are allowed to process Children’s Data where it is required for our legitimate interests (offering and hosting children’s parties and other events in our venues, dealing with feedback and complaints, understanding how customers interact with our mobile apps and websites, providing safe and secure use of our online facilities) or whenever required to comply with a legal obligation; and, in any of these situations, where the processing is necessary.
Alternatively, or in addition, we may process Children’s Data on the basis of consent, given or authorised by the holder of parental responsibility (and in these circumstances we will always make reasonable efforts to verify such consent).
We do, from time to time, process personal data about you in an automated way to evaluate certain personal aspects about you, including to enable us to analyse and make predictions about your interests and how you are likely to interact with our Group. This is commonly referred to as profiling and it is our way of providing you with a more bespoke customer experience based on how we think you engage with us and our Group.
The personal data about you that we process for profiling purposes includes your Identity Data, your Contact Data and your Profile Data. We do not process personal data about you for profiling purposes that consists of Special Category Personal Data. We process your personal data for profiling purposes for our legitimate interests as set out below. Click here if you would like to learn more about exactly the kind of profiling we do and what profiling means to you. You also have the right to object to us processing your personal data for profiling; to learn more about your right to object, click here.
We collect your personal data from several sources, including directly from you, which we then combine in order to create a view of your interactions with our group of companies. Once we have this record, we match multiple variables that are unique to you (such as name, email, postcode and/or mobile number) to create an overall matched record. We then clean the record by comparing it with certain third-party reference files (such as the Post Office Address File, the Bereavement Register and email validation) to try to ensure that the record is as accurate as possible.
Once the record is cleaned, we add the record to our customer database and we start to build a behavioural profile about you, which details the brands that you do, or do not, engage with. We also infer a visit to a particular brand location so that we can gain a better understanding of how far you might travel to visit a particular brand of ours. In addition, we apply our algorithms or scoring models to the record to indicate how likely it will be that you will visit a particular brand in the future. We then segment our overall database to create a customer base for each brand to determine those customers with a high likelihood to visit a brand and those who are unlikely to visit a brand. Your record may be in more than one segmented element of the database, for example, you may be high likelihood for 3 of our brands and low likelihood for 2 of our brands within your catchment area.
As well as looking at how you interact with our brands, we also apply demographic profiles (provided to us by a third party supplier of demographic data) to your record using your postcode. These profiles are trends based on a nationally representative sample. This enables us to understand your likely profile such as age, home and financial situation as well as your attitudes to family, home life, matters such as dining, media consumption or your purchasing behaviour.
Finally, to ensure that you get the most relevant communications from us, we may use the above variables (if you have agreed to us sending you certain communications) to select an appropriate communication for you to receive, as well as ensuring the you receive the right content or offer. For example, our profiling will help us determine whether you may be more interested in a family message and offer as opposed to a champagne promotion. We enhance this information with data we have regarding the communications and promotions that you have (or have not) engaged with in the past.
Significance and Consequence of the Profiling
The profiling we do enables us to better understand how you interact, or may interact, with our brands. It enables us to provide you with the most relevant information (such as vouchers and offers where you have agreed to receive these) and to determine whether a particular brand or outlet should be more tailored to those people who do, or who are likely to, visit it. The profiling also helps us to improve our services and the offerings of our brands depending on the demographic of existing or future visitors.
We use different methods to collect personal data from and about you including through:
We only process your personal data when allowed to do so by law. Most commonly, we will process your personal data:
The below table sets out how we process your personal data. Please contact us if you would like further information about the specific basis for processing.
To process and deliver a product or service that you have ordered from us, including:
Basis for Processing
To process your registration with us including:
Basis for Processing
To tailor our direct marketing to you and to send you direct marketing communications including via:
Basis for Processing
To enable you to take part in prize draws, competitions or surveys.
Basis for Processing
To understand our customers, matching common information from various sources to build a profile of you; this may include:
Basis for Processing
To manage our relationship with you, which includes:
Basis for Processing
To administer and protect our business and website and offer safe and secure use of our products and services, which includes:
Basis for Processing
To provide information to legal and regulatory bodies where we are under a legal or regulatory obligation to do so.
Basis for Processing
We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the laws applicable to us and for the purposes set out in the table in paragraph 8 above.
We share your personal data with:
Some of our external third parties are based outside of the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data outside of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
If you have any questions in relation to this section, please contact email@example.com.
We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have also 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.
Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.
We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining 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.
We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available by contacting us.
In certain circumstances, you may have the right to request access, transfer, rectification and/or erasure of the personal data that we process about you. You may also have the right to object to and/or restrict our processing of your personal data. Details of the rights are set out below.
To exercise any of these rights please contact us using the details in paragraph 2.
The ICO regulates most UK data and information laws. To learn more about your rights, visit the ICO website at www.ico.org.uk.