Privacy policy.

What is the purpose of this document?

We are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about, in accordance with the EU General Data Protection Regulation (GDPR). It applies to all guests, visitors, suppliers and employees. Known through this document as “data subjects”.

21Soho is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

This notice applies to data subjects. This notice does not form part of any contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on speciﬁc occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Test and Trace Data Collection

We are collecting your contact details to assist the NHS Track & Trace system to help contain clusters or outbreaks of COVID-19.

We will store your data securely for 21 days and once this time has passed, the data will be destroyed to comply with General Data Protection Regulations. We will collect your name, contact number, date of visit, arrival time, and where possible, departure time.

We will only share your data with the NHS Track and Trace service only where it’s necessary, either because someone who has tested positive COVID-19 has listed this premises as a place they have visited recently or because this venue has been identified as the location of a potential local outbreak of COVID-19.

If you are contacted by NHS Test and Trace Contact tracers will:

• Call you from 0300 013 5000

• Send you text messages from NHStracing

• Ask you to sign into the NHS Test and Trace contract tracing website

Data protection principles:

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

The kind of information we hold about you:

Personal data, or personal information, means any information about an individual from which that person can be identiﬁed. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

Details such as name, title, addresses, telephone numbers, and personal email addresses. Date of birth. Gender. Marital status. Emergency contact information. TAX or insurance details. Bank account details, payroll records Driving licence. Grievance information. CCTV footage and other information obtained through electronic means such as door access records. Information about use of our IT and communications systems. Photographs.

We may rarely also collect, store and use the following “special categories” of more sensitive personal information:

Information about your race or ethnicity, religious belief. Information about your health, or medical needs. How is your personal information collected?

We collect personal information about data subjects through various means. Primary methods are at the point of check-in, booking, and reservation. Either directly from data subjects or from a third party acting on our behalf (for example through a booking agency, travel agent or corporate account). Other means are supplier or account creation or payment process and loyalty or rewards programs.

How we will use information about you We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4. Where you have given us explicit consent to do so.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your vital interests or someone else’s vital interests.

Situations in which we will use your personal information We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties Administering the contract, we have entered into with you.

Business management and planning, including accounting and auditing.

Making decisions about grievances.

Making arrangements for the termination of a contract.

Dealing with legal disputes.

Complying with health and safety obligations.

To prevent fraud or abuse.

To protect our systems and networks.

To conduct data analytics studies to review and better understand customer satisfaction and needs. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety or advanced guest information).

Change of purpose:

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information:

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justiﬁcation for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Principles of GDPR:

We will use your personal data only in-line with the following principles:

1. Lawfulness, fairness and transparency

2. Purpose limitation

3. Data minimisation

4. Accuracy

5. Storage limitation

6. Integrity and conﬁdentiality We process personal data in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures”.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise speciﬁc rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing:

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require approved third parties to respect the security of your data and to treat it in accordance with the law.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, or where we have another legitimate interest in doing so, or when we have your explicit consent.

Which third-party service providers process my personal information?

“Third parties” includes approved and regulated third-party service providers (including contractors and designated agents) and other entities within our group.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for speciﬁed purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We may share your personal information with other entities in our group, as part of our regular reporting activities, system maintenance, support and back-up.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security:

We have put in place measures to protect the security of your information. An overview of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information conﬁdentially, legally and secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of conﬁdentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulﬁl the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, please contact: hello@21-soho.com or for more information. You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply in such circumstances.

What we may need from you:

We may need to request speciﬁc information from you to help us conﬁrm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent:

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a speciﬁc purpose, you have the right to withdraw your consent for that speciﬁc processing at any time. To withdraw your consent, please contact our data privacy manager. Once we have received notiﬁcation that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer:

We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact them here: hello@21-soho.com

You have the right to make a complaint at any time to the Information Commissioner’s Ofﬁce (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice:

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any changes. We may also notify you in other ways from time to time.