STRONGARM HOSPITALITY — PRIVACY POLICY
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1. INTRODUCTION
As part of its business activities, Strongarm Hospitality, in its capacity as data controller, collects and processes personal data relating to visitors to our website and the services we offer across our venues, including our three nightclubs and restaurant in Mayfair, London.
The purpose of this document is to provide clear, transparent, and accessible information about how we handle your personal data, so you can understand the conditions under which it is processed.
If you have any questions, please contact us at:
Email: enquiries@strongarmhospitality.com
Post: Strongarm Hospitality, Mayfair, London
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2. FAIR AND TRANSPARENT COLLECTION OF YOUR DATA
Strongarm Hospitality is committed to collecting your data fairly and transparently. We inform all individuals of the data processing activities we carry out and ensure that no data is collected without your knowledge or without appropriate notice being provided.
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3. LEGITIMATE AND PROPORTIONATE USE OF YOUR DATA
When we process your data, we do so for specific, clearly defined purposes. We collect only the data that is adequate, relevant, and necessary for those purposes. We take reasonable steps to keep your data accurate and up to date, and have procedures in place to rectify or delete inaccurate information where necessary.
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4. THE PERSONAL DATA WE COLLECT
Strongarm Hospitality may collect and process the following categories of personal data:
Identification Data
First name, last name, phone number, email address, date of birth (for age verification purposes)
Personal and Professional Data
Preferences, dietary requirements (for restaurant bookings), and professional details where relevant
Booking and Transaction Data
Reservation details, event bookings, and purchase history across our venues
Technical Data
Browsing data collected during your visit to our website through cookies and similar tracking technologies
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5. LEGAL BASES AND PURPOSES OF OUR DATA PROCESSING
Consent
Enquiry forms submitted via our website; marketing communications; promotional updates about our venues, events, and offers
Contractual Necessity
Processing bookings and reservations at our nightclubs and restaurant
Legitimate Interest
Showcasing our venues, services, and events; managing enquiries sent to enquiries@strongarmhospitality.com; operating links to third-party platforms including Google Maps, Instagram, Facebook, and LinkedIn
Legal Obligation
Age verification and compliance with licensing and regulatory requirements
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6. RECIPIENTS OF YOUR DATA
Your personal data is only accessible to members of our team who require it in order to carry out their roles. We may also share your data with the following categories of trusted third parties:
Website platform providers — Website management and contact form processing
Booking and reservation software — Managing table and venue bookings
Marketing platforms — Sending communications where you have given consent
Payment processors — Processing payments securely
We ensure that all third parties we work with are authorised to access only the data they need, and that appropriate data protection agreements are in place.
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7. INTERNATIONAL TRANSFERS OF YOUR DATA
In some cases, the IT tools we use may result in your personal data being transferred outside the United Kingdom or European Union. Where this occurs and the recipient country does not provide an equivalent level of data protection, Strongarm Hospitality will implement appropriate safeguards — such as standard contractual clauses — to ensure your data remains protected. You may request further information about these safeguards by contacting us at enquiries@strongarmhospitality.com.
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8. HOW LONG WE KEEP YOUR DATA
We retain your personal data only for as long as is necessary for the purposes for which it was collected. Our standard retention periods are as follows:
Customer and contact relationship management — 3 years from the date of last contact
Website analytics and marketing — 25 months
Booking records — 3 years from the date of the booking
Cookie data — Up to 13 months (consent records: 6 months; data derived from cookies: 25 months)
Exercise of data subject rights — Duration of the request, plus archiving for the applicable statutory limitation period
In the event of a dispute, your data may be retained until the matter is resolved or until the relevant legal limitation period has expired (typically 6 years in the UK for civil and commercial matters).
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9. SECURITY OF YOUR PERSONAL DATA
Strongarm Hospitality has implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. While we take every reasonable step to safeguard your data, the security of information also depends in part on the practices of each individual, and we encourage all visitors to remain vigilant when sharing personal data online.
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10. SUBCONTRACTING
Where we engage third-party service providers who process data on our behalf, we ensure they provide sufficient guarantees regarding their data protection and security practices. All such arrangements are governed by written contracts that set out the conditions under which personal data may be processed.
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11. COOKIES
Our use of cookies is governed by our separate Cookie Policy, which is available on our website. We use cookies to improve your browsing experience, analyse site traffic, and support our marketing activities.
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12. YOUR RIGHTS
Under UK GDPR and the Data Protection Act 2018, you have a number of rights in relation to your personal data. These are set out below.
12.1 Right of Access
You may request confirmation of whether we hold personal data about you, and if so, a copy of that data along with information about how it is used.
12.2 Right to Rectification
You may ask us to correct or update any personal data that is inaccurate, incomplete, or out of date.
12.3 Right to Erasure
In certain circumstances, you may ask us to delete your personal data. Please note that this right is not absolute and applies only where specific conditions under applicable law are met.
12.4 Right to Restriction of Processing
You may request that we limit the way we process your personal data in certain circumstances.
12.5 Right to Object
Where we process your data on the basis of legitimate interest, you have the right to object on grounds relating to your particular situation. You also have the right to object to your data being used for direct marketing purposes at any time.
12.6 Right to Data Portability
Where processing is carried out by automated means and based on your consent or a contract, you may request that your data be provided to you in a structured, commonly used format.
12.7 Right to Withdraw Consent
Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time. This will not affect the lawfulness of any processing carried out prior to withdrawal.
12.8 Right to Lodge a Complaint
You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection supervisory authority, at any time. You can contact the ICO at www.ico.org.uk or by calling 0303 123 1113.
12.9 Post-Mortem Instructions
You have the right to give instructions regarding the storage, disclosure, and deletion of your personal data after your death. These instructions will apply solely to the processing activities carried out by Strongarm Hospitality.
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13. HOW TO EXERCISE YOUR RIGHTS
To exercise any of the rights listed above, please contact us by:
Email: enquiries@strongarmhospitality.com
Post: Strongarm Hospitality, Mayfair, London
We may ask you to verify your identity before processing your request. We will respond within one calendar month of receiving your request, as required under UK law.
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14. UPDATES TO THIS POLICY
We may update this Privacy Policy from time to time. We encourage you to review it periodically. The date of the most recent revision will always be displayed at the top of this page.