PRIVACY POLICY

We are 72 Hove Ltd. We operate the sites Third Avenue and Catch & Grill. Your personal data may be obtained and used from time to time by one of these two, and some personal data held by 72 Hove Ltd will be shared with 32 Brighton Ltd for the purposes and on the terms set out in this Privacy Policy (“Policy”) The companies are as follows:

72 Hove Ltd, 72 Church Road Hove, East Sussex BN3 2FP

COMPANY NO: 12668698

VAT NO: 401 3320 68

32 Duke Street

32 Duke Street

Brighton BN1 1AG

COMPANY NO: 12668114

VAT NO: 401 3323 62

ABOUT THIS POLICY

This policy is designed to meet the requirements of the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications Regulations (PECR) and the Data Protection Act. All personal data must be:

Under the Data Protection Act 1998, the General Data Protection Regulation (from 25 May 2018) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (and any laws which amend or replace these) (“Data Protection Law”), you have certain legal rights associated with information about you (“personal data”) and organisations which use (or “process”) your personal data have certain obligations.

More specifically, “Personal data” means information about a living individual which allows them to be identified, either from the data by itself or when the data is combined with other information held by the person who has it.

Each of our companies is a data controller under the Data Protection Law. We will use personal data we obtain about you in accordance with this Policy.

We are committed to ensuring that your privacy is protected, and your personal data is handled in a safe and responsible way. This Policy is provided to aid you in understanding what we do with any personal data that is obtained from you. We endeavour to protect your privacy and any information we hold on you will be used only (i) for the purposes we originally collect it for (as explained in this Policy) and (ii) for other purposes which are compatible with those original purposes. We will update this Policy from time to time to explain how we use your personal data, including any new “compatible” purposes we decide to use your data for.

If you have any questions about this Policy, wish to correct any information we may hold on you, or want to exercise any of your rights under Data Protection Law, please contact the Group’s Data Protection Manager:

Info@catchandgrill.co.uk

Or write to us at the address of the site you have been dealing with. Our addresses are set out above.

You have the right to make a complaint about our use of your personal data at any time to the Information Commissioner’s Office (“ICO”). The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk). If you do have a question about our use of your personal data, we would appreciate the chance to try to help you before you approach the ICO. Please feel free to contact us in the first instance using the Data Protection Manager’s contact details above.

HOW DO WE COLLECT INFORMATION?

We may collect personal data about you in the following ways: you use a website relating to one of our restaurants. you make a booking for one of our restaurants (in person, on the telephone, or via the internet) you make enquiries on our website, including using our contact forms to ask us a question, or asking us to add you to our mailing list to receive special offers and information. you (or an agency or recruiter acting on your or our behalf) provide us with your details in relation to working with us. you contact us using social media. you use a third-party website or app to book a table –for example, OpenTable, Design My Night you provide us with information when you visit the restaurant, which may include your name and contact details, or information about your preferences

WHAT INFORMATION DO WE COLLECT?

We may collect the following information: Name, Job title, email address, Telephone number, Preferences and interest,s Other information relevant to event enquiries, Other information pertaining to special offers, Social media profile and online identifiers, Location data for web (including social media-based) enquiries, Billing information when taking deposits or securing bookings, Dietary requests, Survey responses, Health and allergy information,

If you work with us or apply to work with us, we may collect:

Any information you provide to us on or in relation to a CV, including personal and contact details, employment, educational and salary history Any information you provide to a recruiter or agency References from previous positions You may submit your CV if you’re interested in working for us to

bensamandi@yahoo.co.uk

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested:

We may not be able to agree, enter in to or perform a contract we have or are trying to enter into with you or a person or organisation associated with you (for example, booking a table or arranging an event for you) If you are an employee, contractor, or applicant for a position with us, we may not be able to consider your application, provide you with payor benefits, or administer a contract for services or contract of employment with you. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (or any purpose which is not incompatible with those purposes), including for the purposes of satisfying any legal, accounting, or reporting requirements.

YOUR RIGHTS

You are entitled to request the following from any of these above mentioned sites; these are called your Data Subject Rights and there is more information on these on the Information Commissioner’s website www.ico.org.uk

• THE RIGHT TO BE INFORMED –

The right to be informed about how your personal information is being used and processed (as described in this policy)

• RIGHT OF ACCESS –

The right to ask us for copies of the personal information we hold about you

• RIGHT TO RECTIFICATION –

The right to request the correction of inaccurate personal information we hold about you and to have incomplete personal information completed

• THE RIGHT TO ERASURE (also known as the Right to be Forgotten) -

The right to request that we delete your data, or stop processing it or collecting it, in certain circumstances

• RIGHT TO RESTRICTION OF PROCESSING –

The right to request that we restrict processing of your personal information in certain circumstances.

• RIGHT TO DATA PORTABILITY –

The right to ask that we transfer electronic data that you have given to us to you, or another organisation in certain circumstances.

• RIGHT TO OBJECT –

The right to object to processing of your personal information in certain circumstances.

• THE RIGHT TO STOP DIRECT MARKETING messages, and to withdraw consent for other consent-based processing at any time.

• THE RIGHT TO COMPLAIN to your data protection regulator - in the UK, the Information Commissioner’s Office. We encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have. If you have any general questions about your rights or if you want to exercise your rights or have a complaint, please contact us; contact details are listed above.

HOW WE USE YOUR DATA:

We may share with our sister restaurants (Third Avenue, Catch & Grill, 32 Duke Street) We may share your information (such as meal or seating preferences and special occasions) with other restaurants in the same restaurant group. This is to enhance the hospitality experience that we provide you when you dine with us such as any allergies, seating preferences and to improve our table and shift planning.

TO PROVIDE SERVICES

We use personal data collected from or about you for our own internal records, to provide you with specific services that you may have requested. We may use your personal details to inform you about additional services that may be of interest to you or to respond to a specific enquiry.

TO IMPROVE SERVICES

We may use the information to improve our products and services.

MARKETING

If you get in touch with us via our website or leave a comment / fill in a paper form, we will ask for your permission to provide you with special offers and promotions which may save you money and information about our food and restaurants by e-mail [or text message]. When we do so, we will give you the opportunity to decide which restaurants you want to hear about [and what sort of information we should provide –for example, special offers and promotions, new menu items, or new restaurants we open]. We will provide you with the option to stop receiving special offers and information from us by electronic means [either] by using an “unsubscribe” link [or responding to a text message].In some cases, we won’t ask you for explicit consent ourselves to send you information about our restaurants. Where you’ve dined with us or organised an event at one of restaurants, we may send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.We may also obtain information for these purposes from third-party applications and websites (for example, Design My Night or Opentable) which are legally entitled to share your information with us for these purposes.You always have the right to ask us to stop sending any kind of marketing information which is directed to you individually.

Please contact our [Data Protection Manager], whose details are above and let us know if you do not want to hear from us. Please be aware that we may retain personal data about you even after you’ve told us you don’t want to receive marketing information from us. We may do this simply to ensure that we don’t inadvertently add you to our mailing lists again. We may also retain your data because we have another lawful basis for using it under the Data Protection Law(for example, if you dine with us again or organise an event at one of venues, you work with us, or we need to use your information for legal reasons).We may always use your personal data for marketing analysis without contacting you, in order to assess trends, measure traffic to our website and social media channels.

WORKING WITH US

If you apply or your details are submitted to us in connection with a role we have available, we will use your information to consider your suitability and fitness for a position and to take and consider references. We will use this information to assess your application. We may also keep it in our records for future reference. During any period of work with us, we will provide you information separately about how we use your data to administer the relationship between us and the purposes for which we may use your data if you stop working with us.

SOCIAL MEDIA

If you interact with us on social media, we may “like”, share, re-tweet or otherwise respond to your posts or interactions with us and we may use information about our social media interactions to understand our customers better and promote our restaurants.

SUPPLIERS AND CONTRACTORS

If we obtain goods and/or services from you and/or an organisation you’re associated with, we may use your personal data to contact you or your organisation to administer the relationship between us. We have set out below categories of data we process and, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

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.

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes physical addresses, email address and telephone numbers, user data associated with third party apps and websites (e.g. usernames or other identifiers for an app you use to book a table).

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have supplied to or purchased from us.

Technical Data includes internet protocol (IP) address, any login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any of our websites.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses on any website we operate (and similar information shared with us by third-party apps or websites you use, for example to book a table with us).

Usage Data includes information about how you use our website, restaurants or other products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Category Data is data subject to special protection under Data Protection Law, including information disclosing your race or ethnicity, religious or political beliefs and health information