1.2.1 we, us or our means D. J. Squire & Co., Limited (company number 00316151) with its registered address at Sixth Cross Road, Twickenham, Middlesex, TW2 5PA;
1.2.2 the Internet Services means our Website (as defined below) and the WiFi that we make available to you in our stores;
1.2.3 Website means www.squiresgardencentres.co.uk, help.squiresgardencentres.co.uk, booking.squirescafebars.co.uk, and orders.squirescafebars.co.uk; and
1.2.4 personal information is information that is about you and which identifies you.
2. Who is Responsible For The Personal Information That We Collect?
2.1 We are the controller for the purpose of data protection law in respect of your personal information that we collect.
3. What Personal Information Do We Hold About You?
3.1 The personal information we collect includes:
3.1.1 Information that you provide to us:
(a) your name, image and contact information (including email, telephone and postal address);
(b) your marketing preferences; and
(c) your payment card number (credit or debit card), bank account number, or other financial account number and account details.
This information may be provided:
(a) in the course of communications between you and us (including by phone, email, till transaction or otherwise);
(b) when you, for example, complete our forms (including the Contact Us and Competition entry forms on the Website), surveys, use a store voucher or subscribe to our newsletter;
(c) when you enter into our competitions or prize draws;
(d) when you report a problem with our Internet Services or when visiting our stores; and
(e) via our social media pages, other social media content, tools and applications;
(f) when you book a table in one of our Café Bars or order food;
(g) when you make a booking for an event, Mambo Jambo table or party, or activity;
(h) when you purchase products on-line.
3.1.2 Information we collect from you
(a) cookies are pieces of information stored directly on the device you are using to access our Internet Services. Cookies allow us to recognise your device and to collect information such as your MAC (Media Access Control Address) and IP (Internet Protocol) addresses, internet browser type, the time you connect to our WiFi, the time spent using our Website and the pages visited;
(b) CCTV recordings captured by equipment on our premises; and
(c) photographs and films taken of you and/or your child – we will tell you before we take such photos or films.
3.1.3 Information we receive from other sources
(a) personal information (such as your name, contact details and marketing preferences) which you have provided to a local newspaper or other publication, and where you have agreed for the above personal information to be shared with us for marketing purposes.
4. Information About Third Parties
4.1 In the course of your dealings with us you may provide us with personal information relating to third parties. For example, we may collect the following personal information about other third parties:
4.1.1 if you book a children’s party, we will collect the name and age of your child;
4.1.2 if you book an event, Mambo Jambo table or party, or restaurant table on behalf of someone, we will collect the full name of the person on behalf of whom the table or event is being booked and any other third parties who are attending;
4.1.3 if we deliver a gift or post a gift card on your behalf to a third party, we will collect the full name and postal address of the third party; and
4.1.4 if you purchase products on-line and choose to send them to a different address from the billing address.
5. How Do We Use The Personal Information We Collect About You?
5.1 Your personal information may be used by us, our employees, service providers, and disclosed to third parties for the following purposes. For each of these purposes, we have set out the legal basis on which we use your personal information.
|To communicate with you and other individuals about our products and services.||The legal basis will fall into one of the following four categories, depending on the communication and the purpose for which it was sent:|
• our legitimate business interests in order for us to manage our relationship with you;
• performance of a contract between you and us;
• consent; and/or
• compliance with legal obligations to which we are subject.
|To carry out our obligations arising from any contracts entered into between you and us, and to provide you with our products and services.||This processing is necessary for the performance of our contractual obligations between you and us.|
|To manage and administer our competitions, prize draws and promotions.||This processing is necessary for our legitimate business interests in order for us to manage and administer our competitions, prize draws and promotions, including the provision of any prizes.|
|To provide you with our Internet Services and to notify you about changes to our Internet Services||This processing is necessary for our legitimate business interests in order for us to manage our relationship with you and to provide you with our Internet Services (as requested by you).|
• to facilitate navigation, to display information more effectively, and to personalise your experience while using our Internet Services; and
• to gather statistical information about the usage of our Internet Services in order to understand how our Internet Services are used, in order to continually improve our Internet Services design and functionality and assist us with resolving questions about them.
|To improve our products, services and our staff training.||This processing is necessary for our legitimate business interests in order for us to manage our relationship with you and to improve/develop our products, services and staff training.|
|To manage complaints, feedback and queries||Depending on the context, this processing will be necessary for:|
• the performance of our contractual obligations between you and us;
• us to comply with our legal and regulatory obligations; and/or
• our legitimate business interests in order for us to manage our relationship with you.
|To carry out market research and analysis.||The processing is necessary for our legitimate business interests because it enables us to develop and improve our Internet Services and our products and services offered to you.|
|To carry out satisfaction surveys and analysis.||The processing is necessary for our legitimate business interests because it enables us to develop and improve our Internet Services and our products and services offered to you. For example, we use your postcode data provided on your redemption of our vouchers to help us better understand where our customers are coming from, drive times and which areas we should direct our marketing to in the locality.|
|To provide you with information about other products and services that we offer in accordance with your marketing preferences.||Depending on the method of communication, this processing may be carried out with your consent or in accordance with our legitimate business interests to process your information for direct marketing purposes.|
|To comply with any legal or regulatory obligations (including in connection with a court order).||This processing is necessary for us to comply with our legal and regulatory obligations.|
|To prevent and detect fraud, financial crime and anti-money laundering.||Depending on the circumstances:|
• the processing is necessary for us to comply with our legal and regulatory obligations; or
• the processing is necessary for our legitimate business interests in order to conduct and manage our business.
|The prevention and detection of crime||• The processing of CCTV footage is necessary for our legitimate business interests. We have a legitimate interest in preventing stock loss and the detection of crime and to prevent the misuse of our car parks.|
• The processing may also be necessary in connection with legal proceedings (i.e. the establishment, exercise or defence of legal claims).
• The prevention and detection of unlawful acts. Where the personal information constitutes details of criminal offences or activity, we will process the information on the basis that it is necessary for the prevention or detection of unlawful acts.
|To enforce or apply the contracts concerning you (including contracts between you and us).||Depending on the circumstances:|
• the processing is necessary for our legitimate business interests in order to conduct and manage our business; or
• in connection with legal proceedings (i.e. the establishment, exercise or defence of legal claims).
|Photographs and films in which you and/or your child feature may be used for our marketing, publicity, recruitment and staff training purposes||Depending on the circumstances:|
• this processing is carried out with your consent; or
• for our legitimate business interests in order to raise awareness of our brand, goods and services.
5.2 We may be required to process your personal information to comply with our legal requirements, to enable us to fulfil the terms of any contract that we have with or in preparation of us entering into a contract with you. For example, if you do not provide the relevant personal information to us such as your name and postal address, we will not be able to provide the relevant product to you or another person or our WiFi (as may be requested by you).
5.3 We may be required to process your personal information to comply with our legal requirements in relation to any track and trace procedures for Covid-19 or any other diseases to which these, or similar procedures, may apply.
6. Who May We Disclose Your Personal Information To?
6.1 You agree that we may share your personal information with:
6.1.1 our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, for example we engage third parties to process card payments, deliver our products, provide our Internet Services, to send you marketing and surveys (through our use of third parties such as Campaign Monitor and Survey Monkey) and for data analysis;
6.1.2 in the case of photographs and films taken of you and/or your child, photographers, videographers, marketing, PR and creative agencies, online publications, newspapers and magazines, TV broadcasters and with social media platforms such as Facebook, Twitter, YouTube, LinkedIn and Instagram and such photographs and films may be published and broadcast worldwide;
6.1.3 other professional advisers (including accountants, lawyers, insurers and insurance brokers) that assist us in carrying out our business activities;
6.1.4 police and other law enforcement agencies in connection with the prevention and detection of crime;
6.1.5 other external agencies and organisations (including the National Crime Agency) for the purpose of preventing and detecting fraud (including fraudulent transactions), money laundering and criminal activity;
6.1.6 the relevant agencies in connection with our obligations under the government track and trace procedures for Covid-19 or any other diseases to which these, or similar procedures, apply; and
6.1.7 third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us) or to protect our rights, property or safety of our clients, employees or other third parties.
6.2 We may also disclose your personal information to other third parties, for example:
6.2.1 in the event that we sell or buy any business or assets we will disclose your personal information to the prospective seller or buyer of such business or assets; and
6.2.2 if we or substantially all of our assets are acquired by a third party (or are subject to a reorganisation within our corporate group), personal information held by us will be one of the transferred assets.
7. Where Will We Transfer Your Personal Information?
7.1 We will process your personal information in the UK and both within and outside the European Economic Area (EEA). Where we transfer personal data outside the EEA, we will implement appropriate and suitable safeguards to ensure that such personal information will be protected as required by applicable data protection law. We will also take into account the impact of Brexit on data protection legislation, the incorporation of the GDPR into UK law as UK-GDPR, and transitional measures post 1.1.21 agreed between the UK and EU.
7.2 These measures generally include either:
7.2.1 transferring personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission under Article 45(1) of the General Data Protection Regulation; or
7.2.2 transferring personal information where the recipient has agreed to a European Commission approved data transfer agreement in the form of the standard contractual clauses under Article 46(2) of the General Data Protection Regulation.
7.3 Please contact our Finance Director using the contact details in section 2.2 above if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
8. How Long Will We Keep Your Personal Information?
8.1 We will keep your personal information for a period of up to 7 years after you provide your information to us, subject to the following exceptions:
8.1.1 records of incidents, injuries or accidents in store: 4 years from the date of the accident, injury or incident is recorded by us;
8.1.2 CCTV recordings: up to 40 days from the date of recording;
8.1.3 competition and prize draw entries will be kept until the end of the competition or prize draw and the fulfilment of any prize(s);
8.1.4 we will keep your marketing preferences for as long as you wish to receive marketing communications from us;
8.1.5 the personal information collected when you connect to our WiFi (email address, marketing preferences, MAC and IP addresses and time connected to the WiFi) will be kept for 12 months;
8.1.6 if you have opted out of receiving direct marketing from us, we will keep a record of such opt-out;
8.1.7 we will keep your Café Bar booking details for a period of up to 3 months in order to comply with our obligations under government track and trace or similar procedures; and
8.1.8 photographs and films taken of you and/or your child will be kept for 3 years.
8.2 Please note that all of the above retention periods may be extended where we need to preserve and use personal information for the purposes of bringing or defending a legal claim. In such cases, we will continue to hold and process your personal information for as long as is necessary to deal with the legal proceedings.
8.3 For further information as to our retention periods, please contact our Finance Director using the contact details as set out section 2.2 above.
9. Your Rights
9.1 You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights.
9.2 If you wish to exercise any of the below rights, please can contact our Finance Director by using the contact details in section 2.2.
|Summary of your rights|
|Right of access to your personal information||You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.|
Any access request is free of charge. We may require further information in order to respond to your request (for instance, evidence of your identity and information to enable us to locate the specific personal information you require).
|Right to rectify your personal information||You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.|
|Right to erasure of your personal information||You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.|
|Right to restrict the use of your personal information||You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.|
|Right to data portability||You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means.|
|Right to object to the use of your personal information||You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party) including for profiling; and (ii) if you object to the use of your personal information for direct marketing purposes, including profiling (to the extent it relates to direct marketing).|
|Right to withdraw consent||You have the right to withdraw your consent at any time where we rely on consent to use your personal information.|
|Right to complain to the relevant data protection authority||You have the right to complain to the relevant data protection authority, which is in the case of us, the Information Commissioner’s Office, where you think we have not used your personal information in accordance with data protection law. The ICO’s contact details are: Information Commissioner’s Office, Wycliff House, Water Lane, Wilmslow, Cheshire, SK9 5AF.|
10. Third Party Links
10.1 Our Internet Services 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 how they handle your personal information. When you leave our Internet Services, we encourage you to read the privacy notice of every website you visit.
12. Cookies Policy
Last updated in June 2021.