Privacy Policy

WHO is the CONTROLLER of your personal data?

THE LIVERPOOL PUB LIMITED (collectively referred to as “we”, “us”, or “our” in this privacy policy) is
the controller of your personal data.

Our Contact Details:
If you have any questions about this privacy notice or our processing activities, we can be contacted
by emailing us through our ‘Email’ link on the Website.
It is important that you read this privacy notice together with our Cookie Policy and our terms of
use.

HOW and WHAT data do we collect about you?

We respect your privacy and are committed to protecting your personal data. This privacy notice
describes how we look after your personal data when you:

visit our website (“Website”);
use social media profiles where you have agreed for data to be shared with us (“Social Media Platforms”); or
generally engage with us including by contacting us via our Website, email or telephone with an enquiry, taking part in a competition or purchasing products or services from us (“Engagement”).

Personal data, or personal information, means any information about an individual from which that
person can be identified. We collect this information directly from you during any Engagement with
you, as well as automatically through your use of our Website and indirectly from the third party
providers of the Social Media Platforms or from third party marketing platforms. Depending on the
nature of our interaction with you, we collect different categories of information about you from
time to time which we have grouped together as follows:

Identity Data	name, username, title and place and date of birth and personal characteristics including age and gender
Contact Data	billing address, delivery address, email address and telephone numbers
Profile Data	preferences, feedback, survey responses and interests including activities noted on Social Media Platforms (for example, Facebook likes/groups)
Technical and Usage Data	information about how you use our products, services, Website and the Wifi Services such as internet protocol (IP) address, cookies, mobile device ID, any login data, browsing history, browser type and version, time zone setting and location, viewed pages with date and time stamp (log information), browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website
Marketing and Communications Data	preferences in receiving communications and marketing from us
Location Data	GPS-based location information from your use of our Website, the Wifi Services or Social Media Platforms via your smartphone(s), tablet(s) or other devices

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 process any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade
union membership, information about your health or genetic and biometric data). Nor do we
process any information about criminal convictions and offences.
We do not knowingly collect personal data relating to children and have age verification processes
on our Website and as part of the Wifi Services. Further, we do not market our products or services
to anyone under the age of 18.

WHY do we collect your personal data?

We collect the above categories of personal data about you for the following purposes:

To communicate with you – this includes where we manage our relationship with you, where
we respond to enquiries, where we invite you to events, or where we make suggestions to you
about various products and services that you could benefit from;
To maintain and optimise our Website – this includes where we need to solve performance
issues, including troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data, to improve the availability of the Website and to secure the
Website against fraud;
To protect our business and prevent or detect crime – this includes the use of CCTV;
For data analytical purposes in order to improve our products/services, marketing, customer
relationships and experiences;
To improve our marketing strategies by creating profiled audience segments so that we can
send relevant tailored offers and content, use data management platforms or receive
information from Social Media Platforms; and
To satisfy our legal obligations and to defend and exercise our legal rights.

We will only use your personal data for the purposes above, unless we reasonably consider that we
have another appropriate reason and that reason is compatible with the original purpose. 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.
Further information on the circumstances in which we collect your data is available in Appendix 1 of
this privacy notice.

What is our LEGAL BASIS for collecting your Data?

Under data protection laws, we must have a legal basis under which we process your personal data.
When we collect and use your information, we do so under one of the following:

We have a legitimate interest as a business;
To perform a contract we have with you;
To comply with a legal obligation; or
If you have given us your consent.

Legitimate Interest as a business means conducting and managing our business to enable us to give you the best service and to promote and grow our business. 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 will not use your personal data for activities unless we have a compelling interest which is not overridden by the impact on you (unless we have your consentor are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party, such as entry into a promotion or subscription to a particular
service, or to take steps at your request before entering into such a contract.

Compliance with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to, such as antimoney laundering legislation.

With your consent, this can only be relied on by us as a legal basis for processing where your consent
has been freely given, is unambiguous and clear (i.e. you have actively opted into a service we provide
by ticking a box). If you provide us with your consent to process your data at any point on our Website
or on a Social Media Platform, you can withdraw it at any time, and we will stop all processing
activities that were based on consent as a legal basis for processing. Please note we may still process
the data if we have another lawful basis for processing (in most instances, this will be for a more
limited purpose e.g. back-up storage or to record a withdrawal).

Further information on the relevant purposes and linked legal basis are set out in Appendix 1 of this
privacy notice.
Where we need to collect personal data due to a legal or regulatory obligation, or in relation to the
performance of a contract, and you do not 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). We will notify you of this at the time.

WHO do we share your personal data with?

In order to ensure that we provide the best service to you, we may from time to time have to share your personal data with the parties set out below for the purposes and on the legal basis as set out in the table in Appendix 1:

first and third party advertising companies and media agencies for marketing and research
purposes;
marketing agencies based within and outside the EEA and UK who provide promotional and
prize fulfilment services on our behalf;
our data storage provider(s) based within the EEA and UK who securely stores consumer
data obtained through competitions on our behalf;
third party providers of social media platforms (including Facebook);
courts, parties to litigation and professional advisers where we reasonably deem it
necessary in connection with the establishment, exercise or defence of legal claims;
a purchaser or parties interested in purchasing any part of our business.

We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. Where third parties act as processors on our behalf, we only permit them to process
your personal data for specified purposes and in line with our instructions.

International transfers

Our external third parties may be based outside the UK or the EEA. Whenever we transfer your
personal data out of the UK or the EEA, we ensure that the same level of protection is afforded to it
by ensuring at least one of the following safeguards are put in place:

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. For further
details, see European Commission: Adequacy of the protection of personal data in non-EU
countries;
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. For
further details, see European Commission: Model contracts for the transfer of personal data
to third countries; and
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. For further details, see European Commission: EU-US
Privacy Shield.

How SECURE is my data?

We 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. 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 are subject to a duty of confidentiality.
Unfortunately, no transmission of information over the internet can be completely secure, and you
should also note that the security of information depends in part on the security of the computer
you use to communicate with us and the security you use to protect account information and
passwords, so please take care to protect this information.
Our Website includes 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, plug-ins or applications and are not responsible for their privacy
statements. We encourage you to read the privacy notice of every website you visit and third party
service/application that you use.

How LONG will my personal data be used for?

We will only retain your personal data to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements. Further retention details for
specific aspects of your personal data are noted in Appendix 1.
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.

What MARKETING and PROFILING activities do we carry out?

We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We may use your Identity Data, Profile Data, Technical and Usage Data
and Location Data to form a view on what we think you may want or what may be of interest to you
and to understand your purchasing trends. This profiling activity is used as part of how we decide
which products, services and offers may be relevant (we call this marketing).

You will receive tailored marketing communications from us if you have:

requested information from us;
purchased goods or services from us; and/or
provided your details for the purposes entering a competition or registering for a promotion

You will not receive marketing communications from us in any of the above scenarios if you have
opted out of receiving that marketing. Where you have not opted out, you will only receive
marketing communications from us in the above scenarios if the marketing is confined to online
advertisements or marketing that is not direct to you. We will only send direct electronic marketing
(e.g. via emails or SMS), where we have your express opt-in consent.
You can ask us, or third parties acting on our behalf, to stop sending you marketing messages at any
time by emailing us through our ‘Email’ link on the Website . Where you opt out of receiving these
marketing messages, we will no longer conduct any marketing unless you opt-in again at a later
point. Please note that where we have another lawful basis for processing, we will continue to
process personal data for other purposes – for example, we may process information provided to us
in connection with an Engagement on the basis of contract necessity.
You can also set your browser or device to refuse all or some cookies including advertising cookies –
please see our separate Cookie policy or more detail on this.
Please note that other than the profiling activities described here, we do not carry out any
automated decision making processes which could have a legal or significant impact on you

What are my RIGHTS?

Under certain circumstances, you have various rights in relation to your personal data under data
protection laws. If you wish to exercise any of these rights, please email us through our ‘Email’ link
on the Website.
You will not have to pay a fee to access your data or exercise any of your other rights, but please
note that we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.
In order to respond to any request in relation to your data access rights, we may need to request
specific information from you to help us confirm your identity. We may also contact you to ask you
for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
You have the right to:

Object to processing of 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 overrides your rights and freedoms

You also have the right to:

Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you;
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, or where you
have successfully exercised your right to object to processing (see box above);
Request restriction of processing of 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;
Request the transfer of your personal data to you or to 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. 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; and
Withdraw consent at any time where we are relying on consent to process your personal
data. 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
services to you. We will advise you if this is the case at the time you withdraw your consent.

You also 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 using the details at the start of this notice.
This version was last updated in January 2020.

Click to view Appendix 1