PRIVACY POLICY
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
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We collect, use and are responsible for certain personal information about you. When we do so we are subject to applicable data protection laws and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Who are we?
This Policy applies to both House of Holes (Derby) Ltd (aka House of Holes) and subsequent independent House of Holes Franchise Limited Companies.
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House of Holes (Derby) Ltd is a company registered in England and Wales under company number 15061930, having our registered office at The Clocktower Business Centre, Park Lane, Bestwood Village, Nottingham, England, NG6 8TQ.
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House of Holes Franchises operate as independent Limited Companies. Please see the ‘How to contact us’ section for individual contact details of each Franchise Limited Company who are the controllers of any personal information that you provide to us.
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Any questions relating to this privacy policy and our privacy practices should be sent to info@houseofholes.co.uk
This privacy policy only covers the control of data within the House of Holes operation and does not apply to any Franchisees websites or mobile apps that they operate outside of House of Holes.
Personal information we collect about you
We may collect and use the following personal information about you:
your name and contact information, including email address and telephone number;
your billing information, transaction and payment card information;
information about how you use our website, IT, communication and other systems;
your responses to surveys, competitions and promotions.
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This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
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COVID-19: We may need also collect additional contact information in line with the Government’s track and trace requirements, and ask you information regarding symptoms and/or potential exposure to Covid-19.
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How your personal information is collected
We collect most of this personal information directly from you in person, by telephone, text or email and/or via our website. However, we may also collect information:
from cookies on our website – for more information on our use of cookies, please see our cookie policy; and
via our IT systems – including but not limited to door entry systems and CCTV.
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How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
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Where we have your consent (in limited circumstances); to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
to protect your vital interests in emergency situations; for our legitimate interests or those of a third party; or
where you have given consent.
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A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
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The List below explains what we use (process) your personal information for and our reasons for doing so:
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To provide services to you, including completing your booking through our payment gateway and contact you in relation to your booking. Please note that our booking system will be accessible by our franchisees for each location that they operate
Our reason - For the performance of our contract with you or to take steps at your request before entering into a contract.
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Processing necessary to comply with professional, legal and regulatory obligations that apply to our business – for example, under health and safety regulation and the Government’s guidance on Covid-19.
Our reason - To comply with our legal and regulatory obligations.
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To prevent and detect unlawful acts
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Our reason - For our legitimate interests or those of a third party, i.e. to criminal activity that could be damaging for us and for you.
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To prevent and detect fraud against you or House of Holes
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Our reason - For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you.
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Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.
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Our reason - To comply with our legal and regulatory obligations.
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Ensuring business policies are adhered to – for example, complying with our insurance requirements and policies covering security.
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Our reason - For our legitimate interests or those of a third party, i.e. to make sure we are following our insurance and own internal procedures so we can deliver the best service to you.
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Operational reasons, such as improving efficiency, training and quality control.
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Our reason - For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.
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Ensuring the confidentiality of commercially sensitive information
Our reason -For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
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Statistical analysis to help us manage our business – for example, in relation to our financial performance, customer base or other efficiency measures.
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Our reason - For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.
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Preventing unauthorised access and modifications to systems
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Our reason - For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.
Updating customer records.
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Our reason - For the performance of our contract with you or to take steps at your request before entering into a contract.
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party – for example, making sure that we can keep in touch with our customers about existing orders and new products.
Statutory returns
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Our reason - To comply with our legal and regulatory obligations.
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Ensuring safe working practices, staff administration and assessments
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Our reason - To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party – for example, to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
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Marketing our services and those of selected third parties to:
existing and former customers;
third parties who have previously expressed an interest in our services;
third parties with whom we have had no previous dealings.
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Our reason - For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
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The above list does not apply to special category personal information, which we will only process with your explicit consent.
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Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
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We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
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We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.
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You have the right to opt out of receiving promotional communications at any time by:
contacting us at info@houseofholes.co.uk; or
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
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Who we share your personal information with
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We routinely share personal information with:
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– our franchisees, which includes access to your bookings on our booking system;
– third parties we use to help deliver our services to you – for example, our booking system provider and payment service providers;
other third parties we use to help us run our business – for example, MailChimp, marketing agencies or website hosts;
third parties approved by you – for example, social media sites you choose to link your account to or third party payment providers;
– our insurers and brokers; and
– our bank.
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We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors – for example, in relation to the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
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We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
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Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
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Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.
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How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
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to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law, including health and safety regulation or in respect of any insurance claims.
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We will not retain your personal information for longer than necessary for the purposes set out in this policy.
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Transferring your personal information out of the UK and EEA.
To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), for example:
with our service providers located outside the UK/EEA; or if you are based outside the UK/EEA.
These transfers are subject to special rules under European and UK data protection law.
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The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Canada.
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Except for the countries listed above, these non-UK/EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
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If you would like further information please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
Access - The right to be provided with a copy of your personal information (the right of access).
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Rectification - The right to require us to correct any mistakes in your personal information.
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To be forgotten -
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Restriction of processing - The right to require us to restrict processing of your personal information in certain circumstances – for example, if you contest the accuracy of the data.
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Data portability - The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.
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To object
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The right to object:
at any time to your personal information being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal information – for example, processing carried out for the purpose of our legitimate interests.
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Not to be subject to automated individual decision making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
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For further information on each of those rights, including the circumstances in which they apply, please contact us – see below: ‘How to contact us’.
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If you would like to exercise any of those rights, please:
email, call or write to us – see below: ‘How to contact us’; and let us have enough information to identify you – for example, your full name, address and booking reference number); let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and let us know what right you want to exercise and the information to which your request relates.
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Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
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How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
Data protection law also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
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How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
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Our contact details are shown below:
House of Holes, Nottingham, Privacy Team, info@houseofholes.co.uk, 01332 209 888
Changes to this privacy policy
This privacy notice was published on 16 February 2024 and last updated on 16 February 2024.
We may change this privacy notice from time to time, when we do we will inform you via our website