What information do we ask you to provide and what do we use it for?
We ask you to provide your first name, email address, date of birth, postcode, MAC address, IP address and geographic location details. By giving us your personal data you are consenting to us processing it for the purposes stated in this Privacy Notice.
| We capture | We use it to |
|---|---|
| First Name | Identify you and associate you with your WiFi account
Personalise communications with you when we send you marketing material that you have opted in to receiving |
| Email Address | Provide a unique WiFi account so that you can log on to WiFi in our pubs
Send you marketing information that you have opted in to receive from us |
| Date of Birth | Verify that you are old enough to receive marketing material related to alcoholic products. |
| Postcode | Understand our customer location in relation to the pub visited, and use this for future customer profiling.
Target you with relevant marketing information that you have opted in to receive from us. |
| Unique Device Identifiers
MAC Address |
Verify how often you visit and use our pubs, websites and web apps by taking this information automatically once signed up to the WiFi service. |
Why do we need to collect your personal data?
We process your personal data to allow you to create a free WiFi account. Additionally, we need to collect it on the basis that we have a legitimate interest in maintaining your Wi-Fi account with information that you have provided voluntarily. We have a legitimate interest in monitoring your device and location information to understand consumer behaviour regarding location and visit frequency. We send you marketing material that you have opted in to receive on the basis that you have given us your consent to do so (aged over 18 only).
How long do we keep your personal data?
Your date of birth is not stored once it has been entered and validated in the initial WiFi signup form.
If you have opted in to receive marketing material, we will keep the remainder of your personal data indefinitely, until you opt-out of marketing, or until you ask us to delete it (see the section below called “What are your rights?”). Once opted out of marketing, your data will be permanently deleted.
If you have not opted in to receive marketing communications, the provider holds the data for a maximum of 2 years in order to continue to seamlessly sign you into your WiFi account.
Who do we share your information with?
If you have not opted in to marketing, your personal data is shared with the following third parties:
| Company | Why do we pass information to them? | What information do we pass to them? |
|---|---|---|
| Daisy Communications Ltd or any other such organisation that we may use from time to time | Daisy provide our free WiFi service. The personal data that they process gives you access to that service. | Email Address, First Name |
If you have opted in to marketing, your personal data is shared with the following third parties:
| Company | Why do we pass information to them? | What information do we pass to them? |
|---|---|---|
| Daisy Communications Ltd or any other such organisation that we may use from time to time | Daisy provide our free WiFi service. The personal data that they process gives you access to that service. | Email Address, First Name |
| Dotmailer Ltd or any other such organisation that we may use from time to time | Dotmailer provide our email platform. The personal data that they process allows personalisation of the email marketing service from which you can unsubscribe at any time. | Email Address, First Name, MAC Address, Date of Birth, Pub registered at |
| CACI or any other such organisation that we may use from time to time | The anonymised personal data that they process helps us to understand consumer demographics and frequency of visits. | Geographic Location and/or Postcode |
| To verify your age if you are registering using your Facebook account. | Facebook User ID | |
| To target you with offers that may interest you based on either your marketing consent or your acceptance of cookies on our websites. See our Cookie policy for details. | Email Address |
Is your personal data processed outside of the UK or EU countries?
Yes, the Facebook platform is based outside of the EU, however they are in full compliance with the General Data Protection Regulation (GDPR) as they hold EU-US Privacy Shield membership. For more information, read the following Privacy Policy:
Facebook – https://en-gb.facebook.com/privacy/explanation
Is any “profiling” performed using your personal data?
Yes, we use the data you provide to evaluate whether an individual is over 18 years of age to determine whether marketing of alcoholic products is appropriate. We also perform profiling for the purposes of understanding consumer demographics in our pubs.
We collect the time and geographic location of your device when you use our pub WiFi. We also collect technical information about each device’s unique identifying codes e.g. its “MAC” address, relevant IP address, operating system and version, web browser and version, and geographic location to verify how often you visit and use our pubs.
What consent options do we offer and how do these affect you?
At the point of registering for access to the free pub WiFi service, consent option/s are given for you to receive marketing information regarding the following:
- News and offers from Stonegate Group and our managed pubs (specifically regarding the pub/s you have visited).
When subscribed, you can opt-out at any time by changing your account preferences when you log in to the free WiFi and unsubscribing from emails, or using the “unsubscribe” link embedded within the emails.
If you do not consent to receive marketing information using the opt-in options provided, you will only be registered to the free WiFi service.
What are your rights?
For more information on your data protection rights refer to our Stonegate Pub Partners Privacy Statement.