INTRODUCTION AND SCOPE OF THIS PRIVACY STATEMENT
Ocubis Ltd (Ocubis), Pavilion EC4 Ltd (together collectively “Pavilion”) and the other Group companies (a full list of which can be found here), together “we” or “us”, want to give you the best experience possible. We use the personal information you share with us to make our services and your experience even better. This privacy statement aims to give you a clear view of how we use personal information that you provide, our dedication to protecting it, your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our websites or offices, how we use your personal information and the third parties we will share it with.
We use personal information for various purposes, as described in detail below.
WHO COLLECTS YOUR PERSONAL INFORMATION
Ocubis and the wider Group controls the processing of any personal information collected through marketing cookies used on its website. Ocubis has its registered office at 15 Regent Street, London SW1Y 4LR.
PERSONAL INFORMATION WE COLLECT FROM YOU
“Personal information” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. Ocubis will collect various types of personal information and special categories of personal information about you, including the following (as applicable):
USE OF OUR PRODUCTS AND SERVICES
When you use our services we will ask for personal information (at the moment of collection we will explain what information is required in order for us to provide the particular service, and what information you may choose to provide), such as:
- your email address, postal address and name at first enquiry to create a profile for you;
- your date of birth, home address, proof of address and proof of ID for our Anti-Money Laundering checks;
- your email-address when signing up for one of our contests, free prize giveaways (“Prize Giveaways”) or external newsletters;
- a record of our correspondence with you (including any feedback you have provided on any of our products or services), if you have been in contact with our Sales or Front of House team.
If you become a member of our Pavilion offices (“Member”), we will ask for basic personal information (we will explain what information is required and what information you may choose to provide), such as:
- your name, e-mail address and date of birth
Once you are a Member, you may choose to provide us with additional personal information, such as:
- your interests and preferences
INFORMATION WE COLLECT AUTOMATICALLY
We will also collect personal information about you when you interact with our brand, websites and how you use them, as follows:
- Websites: we will collect information about the Ocubis websites that you visit and how you use them. A visit to one of our websites results in data being sent from your browser to our servers and our CRM system. We will collect personal information in this way, such as:
- your IP address;
- the date and time of the visit and how long you remained on our website;
- the referral URL (the site from which the visitor has come);
- the pages visited on our website; and
- information about the device and browser (such as, browser type and version, operating system, etc).
- Location information: When you use our wi-fi, we will also use various technologies to determine location, such as sensor data from your device that will help us determine where our services are most commonly used throughout the building. You can generally disable sending your location through settings in your device, and we will inform you when we make use of location information.
SOURCES OF INFORMATION
Most of the information we collect about you will be personal information that you have voluntarily provided to us, for example, through our websites, account setup etc. Other sources from whom we may obtain your personal information include:
- our Point of Sale systems (i.e. certain information may be collected about you when you make a manual payment in one of our offices);
- other Group companies; and
- third parties (such as credit reference agencies, law enforcement/regulatory bodies, and companies providing commercially available databases etc.). Some of these third-party sources may include publicly-available sources of information.
HOW WE USE YOUR PERSONAL INFORMATION
The personal information we collect when you first log into our wi-fi will be used for identification and authentication purposes across Pavilion services, so you can use the same account details to log in or access your information from any Pavilion location. It is necessary to process your personal data in this way for the performance of a contract with a Group entity.
In addition, Pavilion will create an account for you with the information needed to provide you with our services. The personal information we collect from the above other sources listed above will be used in the format that it is received, or, where appropriate, may be combined with personal information we obtain from other internal or external sources. We use and analyse this personal information where necessary for the following purposes detailed below:
- Improving our products and services: we will use your personal information to build a profile on you in order to understand how you use our products and services, to develop more interesting and relevant products and services, to improve our website, as well as to personalise the products and services we offer you. We process your personal information in this way as it is necessary for the purposes of our legitimate interests in providing better products and services for you and our other customers.
- Processing your Membership and other services: we use relevant personal information described above (including your name, address and payment details) to process and deliver your Membership, and to notify you of the charges each month. In addition, we may use your age, year of birth or confirmation that you are above a certain age to ascertain whether you meet the minimum age in your country for services and whether you are considered to be a minor for data protection and/or marketing law purposes. It is necessary to process your personal in this way for the performance of a contract with Group entity.
- Preventing fraud: we will also use your personal information to assess your creditworthiness and to prevent fraud. For this purpose, we may need to share your personal information with our credit rating providers (see “how we share your personal information” below). This is necessary for the purposes of our legitimate interests in ensuring we are not the victim of fraud and to protect our legal rights set out in the Terms and Conditions.
- To provide customer support: if you contact our Customer Service (or vice versa), we will use personal information such as your Membership information and contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract with a Group entity or if it is required for us to comply with any legal obligations. If it is not necessary to process your personal data for either of these reasons we will process it as it is necessary for the purposes of our legitimate interests in ensuring we can provide the best service possible.
- To engage with you in relation to the offices you decide to join.: we will use your personal information to provide you with the services you have requested from us, such as promotions, membership of the Pavilion offices, events, etc. This will, if applicable, include the use of your personal information for submission and publication (on our website or a third party’s) in relation to contests, Prize Giveaways and promotions and using your contact details for events. We will process your personal information in this way if it is necessary for the performance of a contract with a Group entity. If it is not necessary for the performance of such a contract, we will process it as it is necessary for the purposes of our legitimate interests in providing these services appropriately and ensuring they function correctly. To the extent that we process location data, we do this on the basis of your consent to receiving these services, and we will not process location data before you have provided your consent to us doing so.
- Pavilion Membership: if you choose to become a member of our Pavilion offices, we will use your contact details to send you a welcoming email to verify your username and password for wi-fi, to communicate with you in response to any inquiries and to send you service related announcements, for instance if there is due to be maintenance. We will also use your registration information to create and manage your account. This processing is necessary for the performance of a contract with a Group entity in relation to the Pavilion offices. In addition, we will use any information you provide voluntarily to us in free text boxes to understand your preferences and to improve our products and services. It is necessary for the purposes of our legitimate business interests to undertake this analysis and to provide you with the best services possible.
- Marketing: when you sign up to receive Pavilion newsletters, create a Pavilion account on becoming a Member, provide feedback on a service online, by email, phone or using our website, we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place on our CRM system (Hubspot). We create your profile in accordance with your preferences in order to provide you with the best personalised experience, to send you personalised marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.
- What kind of information: the way you interact with our brand across all the different channels described above (e.g. the Pavilion website, social media and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best Pavilion experience possible. To learn about you and your interests, we analyse your interactions with our brand using various kinds of information, as set out above. In particular, we may combine the information we collect with information we lawfully obtain from third parties. This is necessary for the purposes of our legitimate interests in ensuring that we provide you the most appropriate offers for services and to personalise your experience. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalised marketing messages about Pavilion products or services, events, Prize Giveaways and promotions. In some instances we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how customers use our products and services, and experience our brand. This is necessary for the purposes of our legitimate interests in analysing our brand and determining how to improve our services.
- What kind of channels: we will send direct marketing communications to you via the channel you choose, such as email, post, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalised marketing communications.
- What kind of messages: the messages we will send you will be personalised and tailored to your individual preferences and interests. We use analytics in order to generate such personalised messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our products and services, events, Prize Giveaways or promotions and Pavilion news. We personalise these messages on the basis of that it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with Pavilion, including by sending you personalised messages.
- Re-targeting: our websites and apps use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our offices and our services, advertisements from us on partner websites. We believe that the display of personalised, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyse the information we collect about your interactions with each Pavilion platform as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behaviour. We will process your data for re-targeting purposes with your explicit consent. Please click here for further information on cookies and instructions on how to disable re-targeting. Note that our sites generally are not configured to respond to web browser do-not-track signals.
- Ads: we also work with non-Ocubis companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect personal information about your visits to our websites or apps and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of cookies for marketing purposes. Please click here for further information on cookies and instructions on how to change your cookie preferences.
- Conducting analytics: we will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our customers and ensuring that our products meet the needs of our customers. The specific ways in which we carry out this analysis include:
- data science/analytics, whereby we combine information (such as personal information and/or sensitive personal information we have obtained through your browsing history) we hold on a large scale in order to:
- learn more about our customers and their preferences;
- to identify patterns and trends amongst our customers;
- enhance user experience on our websites;
- provide information, content and offerings tailored to our customers’ needs;
- for general research and statistical purposes; and
- for aggregated reporting purposes within the Group;
- develop new products and services;
- monitor performance of our products and services and/or improve our technology;
- to be able to send you personalised marketing messages;
- to display online ads to you;
- to analyse the open/click through responses to our email messages.
- data science/analytics, whereby we combine information (such as personal information and/or sensitive personal information we have obtained through your browsing history) we hold on a large scale in order to:
- Analysing our business: we will use your personal information (including by anonymising and aggregating it with other customers’ personal information) for sales, supply chain and financial analysis purposes, to determine how Pavilion is performing and where improvements can be made and where necessary to report back to our parent or affiliate group companies. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.
- We will ask for your consent if we wish to use your personal information for purposes other than those listed in this privacy statement and as required to do so under applicable law. We will not use your personal information for other purposes before we have received such consent.
HOW WE SHARE YOUR PERSONAL INFORMATION
We treat your personal information with care and confidentiality and do not share it with third parties other than as set out below:
With other Group entities
Each Group entity that you interact with will share limited personal information which you provide when you sign up (your name, email address and contact number) with other Group entities for authentication purposes and centralised business administration. This is necessary for the performance of your contract with a Group entity.
Each Group entity may share information we keep in your profile with other Group entities if both entities are responsible for your personal information, or if the other entities are acting as our service providers and processing your personal information on our instructions or on our behalf. This sharing is to ensure that each Group entity has access to all data for which it is responsible, in order that it can comply with its legal obligations.
Each Group entity will also share your other personal information, as well as anonymised and aggregated information, with other Group entities. They will use this personal information for trend analysis, which is necessary for the purposes of their legitimate interests in analysing their performance.
The local office handling your Membership will share information about your purchases when paying from our offices with Ocubis. Ocubis will share information collected through cookies used on the Pavilion website with the local Pavilion office handling your Membership. We will collect and share information from marketing cookies on the basis of your consent. If you do not give your consent, we will only use functionality cookies. We will collect and share information from functionality cookies to meet our legitimate interests in ensuring that our website functions correctly and that we keep our records accurate and up to date. For more information about the types of cookies we use click here.
A complete list of Group entities can be found here.
WITH SERVICE PROVIDERS
We will share limited the personal information you provide when you sign up for Pavilion membership (your name, email address, password and date of birth) with our wi-fi service providers for the purposes of identification and authentication, so that you can log on to your Pavilion wi-fi account quickly and with the ease and speed you expect from us from any Pavilion office.
We will also share your personal information as necessary and only for the purposes and on the lawful grounds described above with various third parties who process your personal information on our behalf, such as hosting, payment and fraud management providers, credit scoring agencies and analytics platform providers. We require that these service providers and other third parties adhere to strict rules when processing your personal information, including to only use your personal information in accordance with Pavilion’s instructions and the applicable laws.
WITH SOCIAL NETWORKS
Our website will, in certain circumstances, provide you with social plug-ins from various social networks. If you choose to interact with a social network such as Facebook or Twitter (for example by registering an account), your activity on our website will also be made available to that social network. This is necessary for the performance of your contract with a Group entity which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings. If you would like to prevent this type of data transfer, please log out of your social network account before you enter one of our websites. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal information, what rights you have and how you can maintain suitable privacy settings for your needs.
WITH LEGAL AND LAW ENFORCEMENT
Pavilion will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Pavilion’s property and legal rights, to protect the personal safety of Pavilion website users or by order of a valid injunction from a court or law enforcement agency.
WITH YOUR CONSENT
We will share your personal information with other third parties (different from those described above, for example, affiliated companies providing external services or products) in other limited circumstances. In these instances we will, where required by applicable law, obtain your consent to share your personal information in this way.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We are committed to protecting your personal information and implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.
RETAINING YOUR PERSONAL INFORMATION
We may keep your personal information for two years from your last interaction with us, such as the date your account was deleted, your last purchase, the last time you used one of our websites or in some other way contacted or interacted, unless a longer or shorter retention period is required by law, is necessary in the course of legal proceedings or is otherwise needed for a particular purpose under applicable law.
The following are examples to illustrate how Pavilion keeps your personal information for as long as necessary for a particular purpose:
- we may keep your personal information collected during a purchase for as long as required by tax laws;
- we may keep your personal information for a shorter period if you ask us to delete your personal information. In such a case, Pavilion will aim to delete your personal information within a maximum period of one month from the date of the request;
- information collected in connection with promotions will be kept for no longer than one month following the end of the promotion.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
Unless stated otherwise, we store and process your personal information in the European Union. There will, however, be occasions when we need to transfer your personal information outside of the European Economic Area (“EEA”) to a country is not regarded under European Law as providing the same level of data protection as the country in which you normally use our products and/or services. For example, the personal information you provide when you sign up for an Pavilion membership will be stored in the European Union, and also by other Group entities and our cloud services providers located outside the EEA for the purposes of authenticating your account and business administration. In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as Pavilion, so your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the contact details below.
INFORMATION ABOUT CHILDREN
As a general rule, we do not intentionally collect personal information about children under the age of 16. If we become aware that we have inadvertently collected personal information about children under the age of 16, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it.
Where we know a child is above the age of 16, but considered a minor under applicable law, we will obtain parental/guardian consent prior to using that child’s personal information.
LINKS TO OTHER WEBSITES AND SERVICES
Our websites may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks).
We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Fair play and transparency are important to us. We are open about the personal information we collect and have implemented mechanisms to enable you to exercise any rights you might have with respect to your personal information.
Where we have obtained your consent in relation to any matter in relation to your personal information (e.g. your consent to receiving direct marketing messages or your consent to the placement of cookies on your device), you can withdraw this consent at any time by contact us using the contact details set out below or changing your cookie settings.
ACCESS TO, DELETION, AND CORRECTION OF PERSONAL INFORMATION
You can send us a request for access to this information at no cost using the contact details set out at the end of this privacy statement.
After receiving your request and sufficient information to verify your identity we will provide you with a copy of the personal information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such personal information is being used, its recipients and the origin of the information.
You may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information. You may also write to us at any time to object to our use of your personal information, restrict our use of your personal information, or request that we provide your personal information in a usable electronic format and transmit to a third party (right to data portability). We will comply with these requests in relation to your personal information in line with applicable law.
OPTING OUT AND UNSUBSCRIBING FROM MARKETING MESSAGES
All our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. You may also opt out for particular channels (for example email or phone) as indicated in the message received in such channel.
If you would like to opt out of receiving Pavilion marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you could contact our:
Data Protection team
by E-mail at : Data.Protection@Ocubis.co.uk
or by post at:
The Legal Department
15 Regent Street
Note that if you choose to opt out of receiving marketing messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalised or non-personalised marketing messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.
CHANGES TO THIS POLICY
Pavilion has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our online privacy statement in order to ensure that it is free of errors and clearly visible on websites, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. We may update this privacy statement from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites and/or mobile apps along with an updated version of the privacy statement
If you have any questions about our use of your personal information, how to exercise your rights or about our privacy statement you are welcome to contact us at:
Online at http://lpavilion.wpengine.com
DATA PROTECTION TEAM
by E-mail at: Data.Protection@Ocubis.co.uk
if you prefer to contact us by regular mail, please send your request to the following address:
The Legal Department
15 Regent Street
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority using their website.
LAST UPDATED: May 2018