Our privacy promise

We collect:

• All information you choose to submit to us by signing up to offers, news or a competition, by sending us emails or texts, by adding posts to any of our websites or apps, by completing feedback surveys, by interacting with us on social media, by speaking to us, booking with us or registering an account with us.
• Full details of the purchases you make on our websites, through our mobile apps and in our outlets. These include the time, date and location of purchase; the things you buy from us; any vouchers, discounts or other alternative means of payment you may use, as well as relevant payment cards such as a credit or debit card.
• Any giftcard or other unique identification numbers we may issue to you from time to time.
• Information on what you view, click on and access in and through our marketing emails and text messages, websites and mobile apps. We also collect this information when you use our WIFI networks to access the internet. We may collect the time and geographic location of your device when you do so. For websites, this information may also include where you came to our outlet from, and where you went when you left it. We also track how often you visit and use our websites and mobile apps.
• Technical information about the devices you use to access our websites and mobile apps. We also collect this information when you use our WIFI networks to access the internet. We collect 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. 
• Your social media content where this is in the public domain. This information can include posts and comments, pictures and video footage.
• Information collected independently by online advertising networks (for example Google) through whom we place advertisements. The information we obtain varies from network to network. It often summarises the actions of lots of people, and so does not enable us to identify you individually. It relates to what you view, click on, and access through websites in their network, including the subject matter of the site you started at and where you subsequently go. It may also include their analysis of your behaviour across the wider internet and a profile of you.
• Profile information and insight from organisations that already hold information on you, such as credit reference agencies and ‘customer insight companies’. They give us their views on your household, your status, as well as your possible preferences and behaviours. 

We use the information we collect for many different things:

• To provide you with our websites, mobile apps and WIFI networks.
• To power our security measures and services for example, so we can recognise your username and password, as well as reset them if you happen to forget what they are.
• To enable us to run competitions and offers for which you have signed up.
• To gather feedback from you about our brands, websites, mobile apps, other services and activities from time to time. We may invite you to provide this feedback on occasion, for example by emailing you. We may use independent research and feedback providers to do so on our behalf. 
• To contact you from time to time about things you have told us you want to hear about, for example our brands’ news, offers and new competitions.
• To respond to any questions, suggestions, issues or complaints you have raised.
• To respond to any social media posts or other public comments you make about us, our brands, websites, mobile apps, services or other activities.
• To communicate with you about operational changes to our products, services, websites and mobile apps, for example if we were to withdraw one of our apps, or change this privacy policy.
• To perform any contract we have with you including to collect any debts we may be owed.
• To gather statistics about how you and other people use our outlets, websites and mobile apps, WIFI networks and what you think of our adverts, offers, news, competitions, social media and other digital content. We then analyse these statistics to understand if these things appear interesting and meet most people’s needs, or if they should be improved, and if so, what design or other changes (e.g. around the nature and timing of communications) would be most beneficial both for our customers and for our business. 
• To monitor use of our websites and mobile apps to see if they are being abused or threatened. 
• To protect you and our business against other potential criminal behaviour, e.g. fraud or ID theft.
• To understand you better and, in particular, your habits, where you are from time to time, your personal circumstances and those of your family or household, and the things you may like, dislike and be interested in. If we hold accurate information about you, we are better placed to send you tailored offers, news and information that we think you may be interested in.
• To maintain administrative and statutory records about our business
• To enable us and our third party service providers to plan and manage our day-to-day business and related services as effectively as possible, for example in predicting likely sales volumes so we can meet demand.
• To enable us to understand what our customer and user base looks like across all our businesses, from our smallest to our largest outlet. We do this by combining your information with information about our other customers and users of our websites, mobile apps and our WIFI networks, so we can spot trends and common factors amongst everyone.
• To enable us to conduct focussed market research based on those trends and factors, which we can then use to further improve our products and services for all of our customers.
• In the process of anonymising your information so that you are no longer identifiable to us.
• To test new systems and processes as we roll them out (but generally only in anonymous form).
• To analyse whether the money we spend on marketing advertising, on TV, billboards, online and in search engines represents good value for us or not.

We do so in part by matching information common to the various different sources of information we have about you, to build a bigger, richer picture.  

We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the Data Protection Act 1998.

We share the information we collect with: 

• All of our group companies, brands and outlets including new ones we might acquire in the future. Our Group portfolio of brands can be found here: www.mbplc.com/ourbrands
• Other people and businesses who help us provide our websites, mobile apps, WIFI networks and related services to you, for example, information technology companies who design and host our websites, payment services companies who enable you to use credit or payment cards with us, and data insight specialists.
• Rewards companies which you have signed up to, in order for you to receive the rewards and benefits they offer.
• Any new business partners we may have over time, for example if we enter into a joint venture, reorganisation, business merger or sale of part of our business, the other party may receive some or all of your information.
• Our professional advisors for example our lawyers, insurers and insurance brokers when they need it to provide advice to us or help us obtain insurance.
• The Police, local authorities, Her Majesty’s Revenue and Customs (HMRC), the Courts and any other central or local government bodies where they request it and we may lawfully disclose it, for example for the prevention and detection of crime.
• Other people who make a subject access request to us, where we are allowed to do so by law.

We also may share the information we collect where we are legally obliged to do so, for example e.g. to comply with a court order.

We take the security of your information very seriously. We comply with the Data Protection Act 1998 which requires us to have in place appropriate security measures at all times, including where we share your information with our suppliers and partners.

Please take care of your own information. For security tips and tricks when using the internet, WIFI and smartphones or tablets, please check out www.getsafeonline.org

We can only keep your information for as long as necessary for the purposes set out above. This restriction is set by the Data Protection Act 1998. The precise length of time we hold your information for varies depending on the individual circumstances. 

If you want to understand your information rights in full, please check out the website for the Office of the Information Commissioner at https://ico.org.uk/ The Information Commissioner regulates most UK data and information laws, including the Data Protection Act 1998, and make a wealth of user-friendly information available on their website. 

If you want to talk to us about your rights, please feel free to get in touch. See the “About us” section below for our contact details.

We will need to update this policy from time to time as our business changes. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for the flags on our websites and materials which indicate we have changed this policy. If you continue to use our services after we have changed our policy, we will take it that you accept the changes. 

Mitchells & Butlers plc. Our registered company number is 4551498 and our registered address is 27 Fleet Street, Birmingham, West Midlands, B3 1JP. We are registered with the Office of the Information Commissioner in the UK. Registration number: Z8628617.