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OUR PRIVACY PROMISE

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.

We sometimes collect and process Sensitive Data (such as your health
information, race, ethnicity) and Children’s Data. See sections 6 and 7 of this
Privacy Policy for details. Except where set out to the contrary in another of
our privacy notices (for example, our Candidate Privacy Notice for job
applications), we do not collect or process any information about criminal
convictions and offences.

 


1. CONTROLLER

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:

 


2. CONTACT DETAILS

Our full details are:

Data Protection Officer

data.protection@mbplc.com

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.

 


3. CHANGES TO THIS PRIVACY NOTICE AND CHANGES TO YOUR DETAILS

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.

 


4. THIRD PARTY LINKS

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.

 


5. THE PERSONAL DATA WE PROCESS

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:

 * Identity Data: including your name, username (or similar unique
   identification numbers that we may apply to you), email address, marital
   status, title, date of birth and gender.

 * Contact Data: including you billing address, delivery address, email address
   and telephone number(s).

 * Financial Data: including payment card details.

 * Transaction Data: including the details of the products and services
   purchased and the date, time and location of sale and your purchasing
   activity (including vouchers and coupons activity).

 * Technical Data: including information we collect through your use of our
   websites and mobile apps, where you came to our website from and where you
   went when you left our website, how often you visit and use our websites and
   mobile apps, technical information about the devices you use to access our
   websites and mobile apps (including your device’s unique identifying codes
   (e.g. its “MAC” address), relevant IP address, operating system and version,
   web browser and version, and geographic location).

 * Profile Data: including your username and password, purchases, orders or
   bookings made by you, your interests, your preferences, your feedback, your
   survey responses, your social media content (where this is in the public
   domain including posts and comments, pictures and video footage) and profile
   information and insight from organisations that already hold information on
   you (such as credit reference agencies and ‘customer insight companies’ who
   give us their views on your household, your status, as well as your possible
   preferences and behaviours).

 * Usage Data: including information about how you use our website, mobile apps,
   products and services (such as details of your table reservations).

 * Marketing and Communications Data: including your preferences in receiving
   marketing from us and our third parties, your communication preferences and
   information on what you view, click on and access in and through our
   marketing emails, text messages and push notifications.

 * Sensitive Data: including information 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 (see section 6).

 * Children’s Data: including names, ages and dietary requirements of children
   when they attend any parties or events at one of our venues which is
   organised by an adult; Identity Data, Contact Data, Technical Data and Usage
   Data of children aged 13 or above when they log into our WiFi network ; and
   Sensitive Data relating to children where this is provided by you (see
   section 7). We do not knowingly process any other data relating to children.

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.

 


6. SENSITIVE DATA

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:

 * As part of any feedback and/or complaints which you raise with us, for
   example where you believe you have suffered a health issue following a visit
   to one of our venues (for example, suspected food poisoning or another health
   and safety incident), or where you believe we have been discriminatory
   against you (for example, discrimination based on race or sexual
   orientation). When you provide details of what happened, this may include
   giving us Sensitive Data. We are allowed to process this Sensitive Data
   (together with any other relevant information), to investigate, address and
   resolve your issue and to administer any possible legal claims or
   out-of-court procedures. We may process Sensitive Data relating to children
   in the situations set out in Section 7.

 * Where you are applying for a job with us. In this situation, we can process
   your Sensitive Data because it is necessary for carrying out our obligations
   and rights related to employment law and your working capacity; this is
   covered in a separate Candidate Privacy Policy which is displayed when you
   apply for job, and a copy of it can be provided by emailing
   data.protection@mbplc.com. We do not routinely collect and process Sensitive
   Data in any other situations. If we do, we will obtain your explicit consent.

 


7. CHILDREN’S DATA

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:

 * for enquiring about, and booking, children’s parties and events. When you
   fill out forms relating to the event you may choose to provide us with
   children’s names, ages and dietary requirements

 * where you believe you have suffered a health issue following a visit to one
   of our venues (for example, suspected food poisoning or another health and
   safety incident), or where you believe we have been discriminatory against
   you (for example, discrimination based on race or sexual orientation) where
   children have been involved in these situations. Again, you might provide us
   with children’s names, ages and health information;

 * where a child aged 13 or above logs into our WiFi network, we collect
   Identify Data, Contact Data, Technical Data, and Usage Data (however, only
   customers aged 18+ can register for a customer account with us).

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).


8. PROFILING

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.

 


HOW WE PROFILE AND THE LOGIC WE USE

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.

 


9. HOW WE COLLECT YOUR PERSONAL DATA

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

 * Direct Interactions: you may give us your Identity, Contact, Financial,
   Profile and Marketing and Communications Data by filling in forms or by
   corresponding with us by post, phone, email, social media or otherwise. This
   includes personal data you provide when you purchase our products or
   services, book a table with us, order a takeaway, create an account with us,
   subscribe to our services, news, offers, promotions and updates or groups,
   request marketing to be sent to you, enter a competition or promotion,
   complete a survey or give us feedback.

 * Social Media Interactions: our website and services may allow you to interact
   with them by using your social media applications. This interaction may
   result in us collecting some of your social media content (including posts
   and comments, pictures and video footage), but only where this content is in
   the public domain and/or where this content has been sent by you to us in a
   private message via social media; and also your Technical, Profile and
   Marketing and Communications Data.

 * Automated Technologies: as you interact with our website and our services, we
   may automatically collect Technical Data about your equipment, browsing
   actions and patterns. We collect this personal data by using cookies, server
   logs and other similar technologies. We may also receive Technical Data about
   you if you visit other websites employing our cookies. Please see our cookie
   policy for further details.

 * Other Third Parties or Publicly Available Sources: we may receive personal
   data about you from various third parties and public sources as set out
   below:
   
   * Technical Data from analytics providers such as Google, advertising
     networks search information providers.
   
   * Marketing and Communications Data and Technical Data from online
     advertising data providers such as Google based outside the EEA.
   
   * Identity Data, Contact Data, Financial Data, Transaction Data, Technical
     Data, Profile Data and Marketing and Communications Data from third party
     affiliate sites such as Vouchercloud and Vouchercode based in the EEA and
     table booking service providers such as Bookatable and Opentable based in
     the EEA.
   
   * Contact, Financial and Transaction Data from providers of technical,
     payment and delivery services.
   
   * Profile Data and Marketing and Communications Data from social media
     providers such as Facebook based inside and outside of the EEA
   
   * Identity, Contact and Profile Data from data brokers or aggregators.
   
   * Identity and Contact Data from publicly availably sources such as Companies
     House and the Electoral Register based inside the EEA.

 


10. HOW WE PROCESS YOUR PERSONAL DATA

We only process your personal data when allowed to do so by law. Most commonly,
we will process your personal data:

 * With your consent and please note that you have the right to withdraw your
   consent at any time by contacting us.

 * Where we need to perform a contract we are about to enter into, or have
   entered into, with you.

 * 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.

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.

 


10A

Activity

To process and deliver a product or service that you have ordered from us,
including:

 * online orders or orders at one of our sites
 * gift card purchases
 * when we issue a refund
 * to manage the payment, fees and charges
 * to collect and recover money owed to us
 * any other contractual arrangement that we agree to enter into with you

Personal Data

 * Identity Data
 * Contact Data
 * Financial Data
 * Transaction Data
 * Children’s Data (only as required for booking children’s parties and events)

Basis for Processing

 * Performance of a contract with you
 * Necessary for our legitimate interests, being to recover debts due to us or,
   in the case of Children’s Data, to provide an event tailored to your child

 

 


10B

Activity

To process your registration with us including:

 * to receive news, offers, promotions and updates 
 * to receive a voucher
 * to make full use of our apps
 * when you otherwise register as one of our customers

Personal Data

 * Identity Data
 * Contact Data
 * Profile Data

Basis for Processing

 * Performance of a contract with you

 

 


10C

Activity

To tailor our direct marketing to you and to send you direct marketing
communications including via:

 * Email
 * SMS
 * Push Notifications

Personal Data

 * Identity Data
 * Contact Data
 * Technical Data
 * Transaction Data
 * Usage Data
 * Profile Data
 * Marketing and Communications Data

Basis for Processing

 * In terms of tailoring our direct marketing, necessary for our legitimate
   interests, being to develop our business and inform our marketing strategy
 * In terms of sending direct marketing where you are a customer and have not
   previously opted out of receiving such direct marketing, as necessary for our
   legitimate interests, being to offer you relevant products and services
   related to what we have previously provided to you
 * In terms of sending direct marking where you are not one of our customers,
   with your consent given when you sign up to our mobile app, website or
   otherwise give your details and provide consent when doing so

 

 


10D

Activity

To enable you to take part in prize draws, competitions or surveys.

Personal Data

 * Identity Data
 * Contact Data
 * Usage Data
 * Profile Data
 * Marketing and Communications Data

Basis for Processing

 * Performance of a contract with you
 * Necessary for our legitimate interests, being to study how customers use our
   products and services, to develop them and grow our business


10E

Activity

To understand our customers, matching common information from various sources to
build a profile of you; this may include:

 * understanding your habits, where you are from time to time, your personal
   circumstances and those of your family or household, and the things you may
   like, dislike and be interested in
 * the ways you interact with us, such as subscribing to news, offers,
   promotions and updates, booking tables, completing surveys, entering
   competitions, using our Wi-Fi, mobile apps, browsing website pages,
   interacting – e.g. by likes and comments – with our social media accounts and
   reviewing our products and services in public forums
 * creating Aggregated Data

Personal Data

 * Identity Data
 * Contact Data
 * Technical Data
 * Transaction Data
 * Usage Data
 * Profile Data
 * Marketing and Communications Data
 * Children’s Data (limited to data concerning use of our WiFi by children aged
   13+)

Basis for Processing

 * Necessary for our legitimate interests, being to develop our business,
   products, services, content and advertising campaigns to make these relevant
   for you, and tracking the effectiveness of our advertising campaigns

 

 


10F

Activity

To manage our relationship with you, which includes:

 * to notify you about changes to our privacy policy
 * to communicate with you about operational changes to our products, services,
   websites and mobile apps, for example if we were to withdraw one of our apps
 * to gather feedback from you about our brands, websites, mobile apps and other
   services and activities from time to time
 * to respond to, deal with and address any questions, suggestions, issues or
   complaints you have raised and reporting and analysis in respect of these
 * to respond to any social media reviews, posts or other public comments you
   make about us, our brands, websites, mobile apps, services or other
   activities

Personal Data

 * Identity Data
 * Contact Data
 * Profile Data
 * Marketing and Communications Data
 * Sensitive Data (only as required for dealing with feedback and complaints
   about specific issues)
 * Children’s Data (only as required for dealing with feedback and complaints
   for specific issues)

Basis for Processing

 * Performance of a contract with you
 * Necessary to comply with a legal obligation
 * Necessary for our legitimate interests (to keep our records updated and to
   study how customers use our products/services)

 

 


10G

Activity

To administer and protect our business and website and offer safe and secure use
of our products and services, which includes:

 * the process of anonymising your information so that you are no longer
   identifiable to us, where we no longer need your data in an identifiable form
 * to provide safe access to our websites, mobile apps and Wi-Fi networks
 * to power user security measures and services, such as recognition of your
   usernames and passwords, as well as reset functions
 * to monitor security measures around our websites, mobile apps and Wi-Fi
   networks to check they are not being abused or threatened
 * to protect you and our business against potential criminal behaviour, such as
   fraud
 * to administer troubleshooting, data analysis, testing, system maintenance,
   support, reporting and hosting of data

Personal Data

 * Identity Data
 * Contact Data
 * Technical Data
 * Usage Data
 * Profile Data
 * Marketing and Communications Data
 * Children’s Data (limited to data concerning use of our WiFi by children aged
   13+)

Basis for Processing

 * Performance of a contract with you
 * Necessary for our legitimate interests, being to run our business, ensure
   network security and prevent potential criminal behaviour
 * Necessary to comply with a legal obligation

 

 


10H

Activity

To provide information to legal and regulatory bodies where we are under a legal
or regulatory obligation to do so.

Personal Data

 * Identity Data
 * Contact Data
 * Technical Data
 * Transaction Data
 * Usage Data
 * Profile Data
 * Marketing and Communications Data
 * Sensitive Data
 * Children’s Data

Basis for Processing

 * Necessary to comply with a legal obligation

 

 


11. HOW WE SHARE YOUR PERSONAL DATA

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: 

 * All of our Group including new companies, brands or outlets we might acquire
   in the future (acting as controllers or processors) who are all based in the
   EEA and who provide IT, HR, system administration services and for whom you
   may have agreed can provide you with marketing communications. Our Group
   portfolio of brands can be found here: www.mbplc.com/ourbrands.

 * Service providers (mainly acting as processors, but sometimes as controllers)
   who help us provide our websites, mobile apps, Wi-Fi networks and related
   services to you; for example, information technology companies who design and
   host our websites, payment services companies who enable you to use credit or
   payment cards with us, and data insight specialists.

 * Affiliated third parties (acting as processors and controllers) that provide
   services to us such as market research, table booking, voucher supply and
   redemption, marketing insight services and data analytics services.

 * Rewards companies (acting as controllers) which you have signed up to, in
   order for you to receive the rewards and benefits they offer.

 * Any new business partners (acting as controllers or processors) we may have
   over time; for example if we enter into a joint venture, reorganisation,
   business merger or sale of part of our business, the other party may receive
   some or all of your information.

 * Our professional advisors (acting as controllers or processors); for example,
   our lawyers, insurers and insurance brokers, when they need it to provide
   advice to us or help us obtain insurance.

 * The Police, the Health and Safety Executive, local authorities, Her Majesty’s
   Revenue and Customs (HMRC), the Courts and any other central or local
   government bodies (acting as controllers or processors) where we are required
   to do so to comply with our legal obligations, or where they request it and
   we may lawfully disclose it, for example for the prevention and detection of
   crime or to report serious health and safety incidents.

 * We also may share the information we collect with other third parties where
   we are legally obliged to do so; for example, to comply with a court order.

 


12. INTERNATIONAL TRANSFERS

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:

 * We 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.

 * We will use specific contracts approved by the European Commission which give
   personal data the same protection as it has in the EEA.

 * Where we use third parties based in the US, we may transfer personal data to
   them if they are part of the Privacy Shield which requires them to provide
   similar protection for personal data shared between the EEA and the US.

If you have any questions in relation to this section, please contact
data.protection@mbplc.com.

 


13. HOW WE KEEP YOUR PERSONAL DATA SECURE

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.

 


14. OUR RETENTION OF YOUR PERSONAL DATA

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.

 


15. YOUR RIGHTS

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.

 * Human intervention: you may request human intervention where a decision has
   been made about you based solely on automated processing, and/or you may
   challenge that decision (this may happen in the context of our recruitment
   process where we collect information relating to whether or not a candidate
   has unspent criminal convictions).

 * Access: you may request access to your personal data, which enables you to
   receive a copy of the personal data that we hold about you and to check to
   see if we are processing it lawfully.

 * Transfer: you may request that we transfer your personal data to you or 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. Please
   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.

 * Rectification: you may request rectification 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.

 * Erasure: you may request erasure of the personal data that we hold about you.
   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, at the time of your request.

 * Object: you may object to how we are processing 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.

 * Restriction: you may request that we restrict how we process 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.

 * Withdrawal of Consent: where we have relied on your consent to process your
   personal data you will have the right to withdraw your consent at any time.
   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.

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.

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