Privacy & Cookie Notice
Introduction
Luxury Restaurant Guide, the trading name of Vision Marketing Limited, is committed to ensuring your privacy is protected. Our Privacy & Cookie Notice explains how we will use your information, how you can instruct us if you prefer to restrict the use of that information, and the procedures we have in place to safeguard your privacy in accordance with UK’s General Data Protection Regulations of May 2018.
Vision Marketing Limited’s registered number is: 03749057 and our registered office is: Spinnaker House, 48 High Street, Bagshot, Surrey, GU19 5AW.
Luxury Restaurant Guide acts as the Data Controller for all customers who take membership, be it paid or complimentary, of Luxury Restaurant Club. All aspects of Luxury Restaurant Guide website, app and Luxury Restaurant Club are covered by this Privacy Notice.
Luxury Restaurant Guide also acts as Data Processor for a number of other ‘Hotel Partner Clubs’. For those ‘Hotel Partner Club’ members, details of how we process your personal data on behalf of the ‘Hotel Partner Club’ membership you have purchased will be covered by the relevant Hotels own Privacy Notice. Those that we work with are listed below with links to their own Privacy Notices:
Elite Hotels – https://www.elitehotels.co.uk/privacy
Historic Sussex Hotels – https://www.hshotels.co.uk/legal-and-privacy
Coworth Park – https://www.dorchestercollection.com/en/privacy-policy/
The Vineyard Hotel – https://www.the-vineyard.co.uk/privacy-cookie-policy/
The Lanesborough – https://www.oetkercollection.com/privacy-policy/?legal-hotel=the-lanesborough
Mosimann’s Club – https://www.mosimann.com/privacy-policy
We may update our Privacy & Cookie Notice from time to time at our discretion. If we do so, the updated version will be effective as soon as it is accessible. If you are a member and any changes materially affect your rights or obligations, we shall notify you by email of any such changes. Otherwise, you are responsible for regularly reviewing this Privacy & Cookie Notice so that you are aware of any changes to it.
If you have any questions, you can contact us at dpm@luxuryrestaurantguide.com.
Collection and use of Personal Information
We collect personal information when you become a member so that we can fulfil your membership, and in particular as follows:
- Name and address – this is so we can send membership packs out to membership categories where a welcome pack is provided on registration. We may also pass your name and address details to a restaurant or hotel to aide with bookings or customer services issues
- Job title and company details including address and phone number if the membership is to be purchased through your business
- Email address – this is so we can send membership confirmations, member offers and membership updates, along with insights as per the services provided in your membership category. Also, to notify you about changes to our service, or if you are a member through a partner Hotel Club, a change to their service
- Telephone numbers – If there are problems with your membership we may need to contact you. For memberships which do not operate on an auto-renewal basis we will use this to contact you to find out if you wish to renew
- Date of Birth – In some instances we are required to take your date of birth as certain hotel clubs we work with require this information for membership verification. This information is not mandatory and in most instances only used to verify age for membership application purposes. Please note day and month are stored separately to year, if this information is given.
- Dietary Requirements – this information is taken to be shared with restaurants when we assist in making reservations on your behalf, or to hold on file for specific hotel membership. The information is used to ensure the hotel / restaurant is able to provide the best service to you as a customer. This information will be verified verbally at several stages during your membership year and during the booking process when reservations are made, and will be verified to check if still relevant annually on renewal of membership.
- Password – this is stored in an encrypted format to allow access to app and web services and can be changed and updated by you at any point to ensure your security
- Usage information – if you are a member of one of our partner Hotel Clubs we may keep details of your visits at that property in order to manage the Hotel Club; and if you book online we may hold a record of the bookings made
- Contact preferences and permissions
All personal data that you provide to us must be true, complete and accurate. Memberships can be purchased as a gift on behalf of another person but membership will be sent to the purchaser directly for passing to the recipient and we will be in contact with purchaser on or after an agreed date (when the present is being gifted) to request contact details of the member to enable us to fulfil membership. At our request, you shall promptly provide evidence of your identity. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this. Please keep your log-in details confidential. You are responsible for all activity under your membership.
If you contact us, we will collect the personal data you choose to share with us. We may keep a record of the correspondence and we may also record any telephone call we have with you.
Please note, we do not collect any children’s data.
Sensitive Personal Information
We do not proactively collect sensitive personal information, such as health related details. However, our team may ask if you have any special requirements it would be useful for your hotel and restaurant teams to know in relation to future bookings. Should the information you share included details such as allergies or dietary requirements, this information may be considered sensitive personal information under applicable law. Sensitive personal information you voluntarily share with us during the enrolment process is processed on the basis of your consent, which you may revoke at any time by contacting us via email at dpa@luxuryrestaurantguide.com. Please note, we do not use this information for the purposes of marketing or advertising products to you.
Data we automatically collect
When you use our website or app, we may automatically collect and store information about your device and your activities. This information could include (a) your computer or other device’s unique ID number; (b) your mobile device’s geographic location; (c) your IP address: (d) technical information about your device such as type of device, web browser or operating system; (e) your preferences and settings such as time zone and language; (f) how long you used the Site and which services and features you used. We collect this information using cookies in accordance with the Cookie section of this Privacy & Cookie Notice and we use the information we collect on an anonymous basis to improve our website, products and services, and for analytical and research purposes.
Use of Personal Data
We will only collect and use your personal data for the following purposes:
- To allow access to and use of our web and app services
- To fulfil orders and purchases made through the website and app
- To communicate with you regarding a “refer-a-friend” nomination scheme
- To keep you up to date with the latest offers, events and information
- To help us make our marketing more relevant to you
- To improve our services and offers
- To meet our legal requirements
Uses Made of Your Personal Data
Your data will be used by Luxury Restaurant Guide to support a range of different activities. These are listed in the table below together with the types of data used and the legal bases we rely on when processing them, including, where appropriate, our legitimate interests. Please be aware that we may process your personal data using one or more lawful basis, depending on the specific activity involved. 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:
Purpose / Activity
- To gain access to the LRG App
Type of Data
- Device Unique ID number
- Mobile device’s geographical location
- IP address
- Technical information about your device such as type of device, web browser or operating system
- preferences and settings such as time zone and language
- how long you used the site and which services and features you used
Lawful Basis for Processing
- Necessary for our legitimate interests (to ensure our app provides the service we offer and promote across advertised platforms and devices and to assist with future development decisions
- Necessary for our legitimate interests (to provide the services as advertised on our website and in our app description)
- To update an existing customer account or create a new customer account either via the website, app or via our membership office
- Identity
- Contact information (address / telephone / email)
- Business information
- Password
- Contact preferences and permissions
- For the provision of membership as requested by you
- To process and deliver your membership including: recording the details of the membership option taken, processing payments and refunds, collecting money owed to us
- Identity
- Contact information (address / telephone / email)
- Business information
- Password
- Contact preferences and permissions
- Transactional information
- To process payments for goods and services
- For the provision of membership as requested by you
- To manage our relationship with you, including: providing you with information, products and services that you have requested from us or that have been requested on your behalf through ‘Refer-a-Friend’ or gift purchases, notifying you about changes to our services, terms and conditions or privacy notice, advising you of new services and offers available to you as a member or asking you to leave a review or take a survey
- Identity
- Contact information (address / telephone / email)
- Contact preferences and permissions
- For the provision of membership as requested by you
- Necessary for our legitimate interests (to grow our business, to keep our website and app up to date, to improve our customer experience and satisfaction and to develop our products and services)
- To recommend products, services, discounts and offers that may be of interest to you, including sending you such information by email, post or contacting you via telephone
- Identity
- Contact information (address / telephone / email)
- Necessary for our legitimate interests (to grow our business and to develop our products and services)
OR
- Consent (see further details in the section Marketing)
Legitimate Interest use of Personal Information
We may also use your personal data for our legitimate interests including to (a) prevent potentially prohibited or illegal activities and enforce our membership terms; (b) better understand our users, diagnose and fix problems you may have; (c) for our general business purposes (d) for regulatory and legal purposes (for example anti-money laundering); and (e) on an anonymous basis, for research purposes.
Who do we share your personal data with
For our legitimate interests, we may disclose your personal information to:
- our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including customer relationship management platform providers, external IT service providers, payment providers, restaurant booking providers, business benefit providers, accountants, auditors and lawyers. A full list of all sub-processors is available here. Please note, we will not disclose your information to any of the relevant third parties listed above for marketing purposes.
- for members of partner Hotel Clubs, we share all personal data of the member with their host hotel in order to fulfil the terms of that aspect of membership for the duration of their Hotel Club membership.
- in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
Under certain circumstances we may have to disclose your personal data as part of our legal obligations under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party’s rights, property, or safety.
We will never sell your details to third parties.
We will contact you on behalf of participating restaurants and hospitality providers, rather than passing your details to the restaurants and hospitality providers directly.
We may provide aggregated user data to advertisers and advertising networks, but such data shall not include any personal information.
Some or all of your personal data may be stored or transferred outside of the European Union (the EU) for any reason, including for example, if our email server is located in a country outside the EU or if any of our service providers are based outside of the EU. You are deemed to accept and agree to this by submitting personal data to us. If we do store or transfer your personal data outside the EU, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU and under applicable laws.
Marketing
We may also use your personal data for our legitimate interests to send you marketing emails, texts or postal messages and materials about our services. You can choose to no longer receive such marketing materials from us by notifying us at dpm@luxuryrestaurantguide.com, selecting unsubscribe on the bottom of all email communications, or within your account. If you do unsubscribe from marketing materials, it may take up to 5 business days for your new preferences to take effect.
We shall therefore retain your personal information in our records for marketing purposes for a period of five years after the last interaction with us. Where there has been a period of five years with no interaction your personal data will be retained only for cross-checking of new data and archiving purposes.
If you are an existing customer, we will only contact you by electronic means, telephone or post with information about goods and services similar to those which were the subject of a previous sale to you.
When you place an order
We collect and use information from individuals who place an order on our website or mobile app in accordance with this section and the section entitled Collection and use of Personal Information.
Information collected when you place an order
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable) and VAT number (if applicable).
If you do not wish to provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: compliance with legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.
Additional information
We also collect additional information from you, such as your phone number, company type and job function.
We use this information to manage and improve your customer experience with us.
We will also use this information to tailor any follow-up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing’.
If you do not supply the additional information requested at checkout, you will not be able to complete the order as we will not have the correct level of information to adequately manage your account.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: The ability to provide adequate customer service and management of your customer account.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use Stripe, a third party payment processor.
Your payment will be processed by Stripe, who collect, use and process your information, including payment information, in accordance with their privacy notice.
You can access their privacy notice via the following link:
https://stripe.com/gb/privacyhttps://stripe.com/gb/privacy
Please note Vision Marketing Limited does not store your payment information.
Transfer and storage of your payment information: Stripe’s services in Europe are provided by a Stripe affiliate – Stripe Payments Europe Limited (“Stripes Payment Europe”) – an entity located in Ireland. In providing Stripe Services, Stripe Payments Europe transfers personal data to Stripe, Inc. in the US.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy notice below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Transfers of your information outside the European Economic Area
This section sets out how we comply with information that is transferred and stored outside the European Economic Area (EEA) in the circumstances set out earlier in this notice.
We transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Currently, the only non-EEA country where Vision Marketing Limited share your information with is the United States.
Every provider we use has self-certified their compliance with the EU-U.S. Privacy Shield.
The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
You can check this directory to verify and obtain further information about Privacy Shield registered vendors: https://www.privacyshield.gov.list.
Cookies
As is common with most sites, we will from time-to-time use ‘Cookies’ to help us gather information from people who visit our website. A cookie is a small data file that our server sends to your browser when you visit the site. You can delete cookies at any time or you can set your browser to reject or disable cookies. If you have a setting that does disable cookies some functions of our website may not work properly.
Most web browsers allow some user control of most cookies through browser settings. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
We do not connect the information collected through cookies with other information that is personally identifiable, unless required or permitted to do so by law or to enforce the Terms and Conditions.
Security
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored in secure servers on our CRM system in the UK. Any payment transactions are encrypted using SSL technology. Where you have chosen a password, you are responsible for keeping this password confidential. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Your rights
You have the right to obtain from us a copy of the personal data that we hold for you, and to require us to correct errors in the personal data that we process for you if it is inaccurate or incomplete. We welcome these requests and aim to respond within 72 working hours of receipt. You also have the right at any time to require that we delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, please contact us at dpm@luxuryrestaurantguide.com.
Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive. Also note, if we action a deletion of your details from our records you run the risk of being re-added in the future.
If you have any complaints in relation to this Privacy & Cookie Policy or otherwise in relation to our processing of your personal data, please contact us. You also have a right to lodge a complaint with the Information Commissioner, see www.ico.org.uk if you feel that we have not handled your information in line with legislative and regulatory requirements.
Retention
Members of the Luxury Restaurant Club, or an associated partner Hotel Club, where membership lapses, shall still be granted general access to the Luxury Restaurant Guide. This level provides access to the website and app along with associated booking and search services but does not afford the customer access to any privileges or benefits at restaurants or hospitality providers. General access shall be granted indefinitely but, where there has been a period of five years without interaction between the Luxury Restaurant Guide and the customer, the customer information is retained only for cross-checking of new data and archiving purposes.
General
This Privacy & Cookie Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.
Last updated: July 2024