1. Introduction

Sourdough South Ltd are committed to protecting the privacy of all customers in the group irrespective of the relationship that you have with us. This Consumer Privacy Policy applies to the personal data that we collect and use for our customers. The companies covered by this policy are Sourdough South Ltd (company number 10627049 – trading as Three Joes) and The Stable Bar & Restaurants Ltd (company number 08231786 – trading as The Stable).

By providing your personal data to us you acknowledge that it will be processed in accordance with this policy.

2. Who is responsible for your data

To facilitate the delivery of our products and services Sourdough South Ltd shares data within the group and is responsible for customer data. Our company registration number is 10627049 and our registered office is 34 Anyards Road, Cobham, England, KT11 2LA. We can also be contacted via email to tellus@stablepizza.com.

3. Personal data we collect about you

We collect personal data for a variety of purposes as outlined in this section. You will provide much of this data to us directly by completing online forms or by communicating with our employees but we also gather some data via the digital interactions that you have with us.

Special Category Personal Data

The GDPR definition of Sensitive Personal Data includes data relating to health and religious beliefs. As a result of you telling us that you have an allergy or a specific dietary requirement you may reveal medical conditions or religious beliefs. Sensitive Data will only be processed in order to deliver the products / services that you purchase from us.

Name and contact details (email address, telephone number and postal address)	When you book a table / function / ticket When you buy products from our online shop (https://gifts.stablepizza.com) When you choose to receive marketing communication When you provide us with feedback or submit an enquiry When you use WiFi
Date of Birth	To confirm that you are over 18 in order to receive licensed goods and services When you choose to provide it for marketing personalisation
Interests	When you choose to provide it for marketing personalisation
Dietary and special needs requirements	When you choose to provide it when booking a table / function
Information about other guests on your booking including details of any children	When you provide them on behalf of others as part of making a table / function / ticket booking
The correspondence that you have with us (eg emails, letters, calls, online chat service)	When you contact us or we contact you.
Your location / visit information	When you use WiFi When you make a booking
Your food / drink transaction details	When you book a table
CCTV Recording	When you visit Sourdough South Ltd locations
Information about how you use our websites including IP address and Google Analytics.	When you browse our websites
Device Information	When you use our WiFi or leave us feedback

4. How and why we use your personal data

We use your personal data to provide the following services:

• To deliver your bookings. When you book with us we will use your information to confirm and deliver your booking and any payments you have made and to send a follow up email for your valued feedback.
• To deliver products that you purchase. When you buy from our online store, we will use your information to deliver your purchases, confirm your order and payments you have made and to send a follow up email for your valued feedback.
• To keep you informed of our products, services, offers and promotions. We may send you marketing communications about our food, drink and events if you have indicated that you are happy to receive these (e.g. when you opt in to marketing when you book from us).
• We will monitor opens / clicks and offer redemption on marketing emails to assess engagement.
• To personalise and improve your customer experience. We may use your personal data in order to tailor our services to your needs and preferences and to provide you with a personalised customer experience.
• To optimise the performance of our websites. We may also collect information on how you use our websites including the pages that you visit and the search criteria that you perform in order to optimise the performance of the website and personalise content that you see.
• To meet our legal obligations. We are required to keep certain records for legal reasons – for example invoices that we issue. We will keep and use this data in line with our legal requirements.
• We use CCTV to deter and detect crime and civil offences, to support court action and comply with our legal licensing requirements. We also use CCTV to provide a safe environment for our staff and customers. We use CCTV to facilitate entry / exit from buildings and improve customer service.
• For market research and to deliver business insight to help us ensure that our products and services remain relevant.

5. Transfer of Data outside the EU

All of the Sourdough South operations covered by this policy are based in the United Kingdom, however, it may also be processed by companies operating outside of the EEA who work for us or for one of our service providers. We will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Policy.

6. Sharing your personal data

We may engage third party companies and individuals to facilitate our Services to you such as payment, data storage or website related services. These third parties may have access to your personal information only to perform these tasks on our behalf and they are obliged through contract not to use your personal information for any other purpose or to disclose your personal information to any third party without our express consent.

7. The legal basis for processing your Data

We rely on the following reasons for using your data.

1. Compliance with a legal obligation / regulatory authority.
2. Performance of a Contract. In order to deliver the service that we have agreed to provide you with (such as a table booking)
3. Legitimate Interest. In order to improve customer experience and develop our products & services
4. Consent – where you have specifically consented to us using the data.
5. Retention and Security of your data

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
• For as long as we provide products and/or Services to you and then for as long as someone could bring a claim against us; and/or
• Retention periods only for as long as necessary and in line with legal, accounting and regulatory requirements or guidance.

Your consent to the use of your personal information for such purposes remains valid after the termination of our relationship with you to the extent permitted by applicable law so long as you do not request otherwise, where permitted.

9. Your Rights

You have certain rights in relation to the personal information we hold about you. Some of these rights only apply in certain circumstances. In order to exercise these rights please contact us using the contact details below. Please note that we will require proof of identity as part of this request and most rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights. Requests are free of charge however we reserve the right to charge a small fee to cover administrative costs should we consider any request to be excessive, unfounded or unreasonable.

• Right of Access. You have the right at any time to ask us for a copy of the data that we hold about you and how it is used.
• Right of Correction or Completion. If the data that we have collected is inaccurate you have the right to update it.
• Right of Erasure. In certain circumstances, you have the right to request that Information we hold about you is erased. This usually applies if the data is no longer necessary for the purpose that it was collected for, or you withdraw your consent for its processing and request its erasure.
• Right to Object to or Restrict Processing. If you wish to challenge our need to process your data on legitimate interest grounds or if you wish to withdraw your consent.
• Right of Data Portability. You have a right to request that we transfer your data to another data processor.

10. Cookies

Like many other business we use cookies on our website. Cookies are small pieces of information that are stored on your computer or mobile device that record how you use the site.

11. Updates to our Privacy Policy

We may make changes to this Privacy Policy from time to time, when we do we will publish the updated version on our websites.

12. Contact information and preferences

If you have any questions about this policy or how your data is processed, please contact us at Sourdough South Limited, 23 West Street, Fareham PO16 0BG marking it for the attention of the DPO or via email to tellus@stablepizza.com.

You can unsubscribe from our marketing communication at any time by clicking the unsubscribe link at the bottom of any of our marketing communications. Alternatively, you can email tellus@stablepizza.com.

We want to make sure that the personal data we hold about you is accurate and up to date and so if any of the details are incorrect you can click the update preferences link at the bottom of any of our marketing communications. Alternatively you can email tellus@stablepizza.com.

Should you have any concerns about this policy or the way that we are processing data you have the Right to Lodge a Complaint with the Information Commissioner’s Office. Please look at www.ico.org.uk for more detail.

This policy was last updated on 18th September 2020