Privacy notice

Introduction

Welcome to The Angel Inn’s privacy notice. 

The Angel Inn respects your privacy and is committed to protecting your Personal Data. This privacy notice will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This privacy policy was last updated in July 2018. 

You can download a pdf version of the policy here.

1. Purpose of this privacy notice

This privacy notice aims to give you information on how The Angel Inn collects and processes your Personal Data, including through your use of the website, https://www.angelinnpetworth.co.uk/ (“the Website"). 

The Website is not intended for children and we do not knowingly collect data relating to children.  Protecting the safety of children when they use the Internet is very important to us.  We recommend that children receive permission from their parent or guardian before gaining access to the Website or sending personal information to us or anyone else online.

It is important that you read this privacy notice 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 so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

2. Controller

Market Town Foods Limited (collectively referred to as "we", "us" or "our" in this privacy notice) is the controller and responsible for your Personal Data. We are a company incorporated in England and Wales and our company registration number is 07265685.  Our registered office is at The Martlet Partnership, Martlet House, E1 Yeoman Gate, Yeoman Way, Worthing, West Sussex BN13 3QZ, and our VAT number is 108 2611 44. 

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below. 

Contact details

Our full details are:
Full name of legal entity: The Angel Inn (Petworth) Limited
Email address: reservations@angelinnpetworth.co.uk
Postal address: 1 Angel St, Petworth GU28 0BG
Telephone number: 01798 344445

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. 

3. Third-party links

The Website 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, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

“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).

In Schedule 1, we have set out, in table form, a description of the different types of Personal Data we may collect, use, store and transfer, the ways we plan to use the Personal Data, and the legal justification on which we rely in order to do so. Where we rely on the justification that it is necessary to process the Personal Data for our Legitimate Interests we have, where appropriate, also identified what we consider those Legitimate Interests to be.

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.

How is your Personal Data collected?

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

(a) Direct interactions. 

You may give us your identity, contact and financial data by filling in forms in store or on-line, or by corresponding with us by post, telephone, email or otherwise. This includes Personal Data you provide when you: 
apply for our products or services;
upload or submit any material via the Website; 
complete forms or create an account on the Website;
subscribe to our service or publications; 
request any marketing or other information to be sent to you;
enter a competition, promotion or survey; 
give us your details at networking events; 
report a problem or submit queries, concerns or comments regarding the Website or its content; or
give us any other feedback. 

(b) Automated technologies or interactions. 

As you interact with the Website, we may automatically collect technical data about your equipment, browsing actions and patterns, such as the type of internet browser you use, any website from which you have come to the Website and your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server.  You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.

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. 

Cookies are pieces of information that a website transfers to your computer hard drive to store and sometimes track information about you.  Although they do identify a user's computer, cookies do not personally identify users.  Cookies are specific to the server that created them and cannot be accessed by other servers, which means they cannot be used to track your movements around the internet.  

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.

In addition to cookies, tracking Gifs may be set by us or third parties in respect of your use of the Website. Tracking Gifs are small image files within the content of the Website or the body of our newsletters so we or third parties can understand which parts of the Website are visited and whether particular content is of interest. 

For more information about the cookies we use, please see our Cookie Policy. 

(c) 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:

(a) analytics providers, such as Google based outside the EU;
advertising networks, such as Facebook, Instagram, Twitter, LinkedIn, Pinterest, Google and Bing based outside the EU;
search information providers, such as Google and Bing based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Authipay based inside the EU.
Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
Identity and Contact Data from recommendations and referrals from existing clients and contacts based inside or outside the EU.
Identity and Contact Data from publicly availably sources such as Companies House and the electoral roll based inside the EU.

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 perform the contract we are about to enter into or have entered into with you.

Where we need to comply with a legal or regulatory obligation.

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.

See Schedule 1 for more details.

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 goods 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. 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us or other companies within our group if you have requested information from us, purchased goods or services from us or provided us with your details when you entered a competition or registered for a promotion provided, in each case, that you have not opted out of receiving that marketing.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to such marketing at any time by contacting us.

We will get your express opt-in consent before we share your Personal Data with any company outside the Angel Inn group of companies for marketing purposes. 
You can ask us or third parties to stop sending you marketing messages at any time, either by checking or unchecking relevant boxes as directed on the Website to adjust your marketing preferences when providing your information, or at any time thereafter by logging on to the Website and checking or unchecking the relevant boxes, by following the unsubscribe/opt-out instructions 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 a product/service purchase, warranty registration, product/service experience or other transactions.

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.

Disclosures of your Personal Data

We may have to share your Personal Data for the purposes set out in Schedule 1 with external third parties such as:

Service providers acting as processors such as Mailchimp, based in the USA, who provide marketing services, Superrb, based inside or outside the EU who provide delivery and other fulfilment services to assist us in providing the services we offer through the Website and On Site Computer Services, based inside or outside the EU, who provide IT and system administration and support services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances, or if we believe that such action is necessary to prevent fraud or cyber crime or to protect the Website.

We may also share your Personal Data, in strict confidence, 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 notice. 

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.

We may disclose aggregate statistics about visitors to the Website, members, customers and sales in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information. 

9. International transfers

Personal Data that you submit via the Website is sent to and stored on our secure servers located in the United Kingdom.  

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA. 

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

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. 

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. 

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. 

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. 

Data security

We place great importance on the security of your Personal Data, and 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. For example, our security and privacy policies are periodically reviewed and enhanced as necessary.  

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. 

Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.  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.

You should bear in mind that submission of information over the internet is never entirely secure.  We cannot guarantee the security of information you submit via the Website whilst it is in transit over the internet and any such submission is at your own risk.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your Personal Data if you use a shared computer or a computer in a public place.

For how long will you use my Personal Data?

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.

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. 

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

Unless you have opted out of receiving marketing communications from us or other companies within our group, we will retain your Personal Data for such purpose indefinitely, or for so long as we wish to continue sending you such communications.  

Your legal rights

Data protection laws gives you a number of rights, under specified circumstances in relation to your Personal Data. These rights, and how to exercise them, are described in more detail in Schedule 2. 

SCHEDULE 1

TYPES OF PERSONAL DATA, AND LEGAL JUSTIFICATION FOR HOW WE WILL USE IT

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.

In the table below, we use the following abbreviations:

Type of data

1 = Identity Data such as first name, maiden name, last name, username or similar identifier, marital status, title, age, date of birth and gender.

2 = Contact Data such as billing address, delivery address, email address and telephone numbers.

3 = Financial Data such as bank account and payment card details.

4 = Transaction Data such as details about payments to and from you and other details of products and services you have purchased from us through the Website or in store.

5 = Technical Data about the devices you use to access the Website, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform and other technology. 

6 = Profile Data such as your log-in and password details, purchases or orders made by you, your interests, preferences, feedback and survey responses, how you found out about us and what you typed into Google or other search engines to find us.  

7 = Usage Data such as information about how you use our website, products and services and about your visits to and use of our website including your referral source, length of visit, page views and website navigation. 

8 = Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

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 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.

Legal justification for processing

A = We process your Personal Data because it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

B = We process your Personal Data because it is necessary for compliance with a legal or regulatory obligation to which we are subject.

C = We process your Personal Data because it is necessary for the legitimate interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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. 

SCHEDULE 2

YOUR LEGAL RIGHTS

You have the following rights with regard to the Personal Data we hold about you, namely the right to:

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

(b) 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.

(c) 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, at the time of your request. 

(d) Object to processing of your Personal Data
This applies 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.

(e) Request restriction of processing of your Personal Data. 
This enables you to ask us to suspend the processing of your Personal Data where:
(i) you want us to establish the data's accuracy;
(ii) our use of the data is unlawful but you do not want us to erase it;
(iii) you need us to hold the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or 
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

(f) Request the transfer of your Personal Data to you, or to a third party you have chosen, in a structured, commonly used, machine-readable format. 
This applies only where you initially provided the Personal Data to us in electronic form and (i) we needed to use it to perform a contract with you, or (ii) we are relying on your consent to process the Personal Data.

(g) Withdraw consent at any time

This is relevant only where we are relying on such consent to process your Personal Data.  It will not affect the lawfulness of any processing carried out before you withdraw your consent and it will, of course, not affect the lawfulness of any processing which is not reliant on your consent.  Please note that, if you withdraw a consent on which we are relying, we may not be able to provide certain products or services to you.

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

Note:

1. You will not have to pay a fee to exercise any of the above rights. However, we may refuse to comply with a subject access request access or, alternatively, may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive.

2. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above 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.

3. We try to respond to all legitimate requests within one month but, if your request is particularly complex or you have made a number of requests, it may take us longer. In this case, we will notify you and keep you updated. 

4. 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.