We, at Marston’s PLC, care about and respect your privacy. We’d like to explain what personal information we have about you and how we use it, as well as letting you know about our practices with regard to your privacy so that you know exactly what is happening with your data and what we are doing to keep it safe.
We are Marston’s PLC! You may also know us as Marston’s Beer Company, Marston’s Inns & Taverns, Revere Pub Company or one of our other trading divisions or group companies from time to time. Where we refer to “we” or “us” in this policy, we mean PLC or any company or division in our group.
If you have any questions about this policy or your privacy, you can find us or get in touch at Marston’s House, Brewery Road, Wolverhampton, WV1 4JT. Our telephone number is 01902 711811.
We have appointed a Data Protection Officer for Marston’s PLC who can be contacted via DataSecurityInformation@marstons.co.uk
We are registered in England & Wales with Company No. 31461 and our VAT number is GB100019352.
Data Protection within the UK is currently governed by the General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (“Data Protection Laws”) and we conduct our activities in line with these.
- Your name, age & contact details (including phone numbers, emails and addresses);
- Your opinions, feedback, comments or views;
- Your banking details or payment card information;
- Your business details (which may include contact details, job titles and other information you would be expect to share when engaging in business with us);
- Your login details (including username and password);
- Your image within photography;
- Special Request data which may include special category data such as Disability & accessibility requirements, dietary requirements or other information that may be deemed sensitive; and
- Your employment history and application data (including CV’s).
- Internet protocol address (IP address);
- Browser type and version;
- Time zone setting;
- Browser plug-in types and versions;
- Operating system and platform;
- The URL Clickstream to, through and from our site (including the date and time);
- Products you viewed or searched for;
- Page response times;
- Download errors;
- Length of visits to certain pages;
- Page interaction (scrolling, clicks, mouse-overs etc);
- Methods used to browse away from the page; and
- Phone numbers used to call our customer services team.
- Names, addresses, contact details/business details if necessary through the course of business;
- Financial information, such as the results of a credit check; and
- Advertising preferences & analytical information (in particular from social media websites, pixels, clickstream data, cookies and Google Analytics).
- When you use our websites or a form is filled out on our websites (including from analytics);
- Correspondence via phone, email or otherwise with one of our team members;
- When you register to use our site or services;
- When you subscribe to our products or services;
- When you place an order with us;
- If you have an accident at one of our sites;
- When you or an analytics provider provide us with your marketing preferences (including where we use the services of social media platforms to determine your potential interest in a product or service);
- When you sign a contract or agreement with us;
- To participate in a discussion board or other social media function on our sites;
- To enter a competition, promotion or survey that we are running;
- When you report a problem with one of our websites;
- When you apply for a job with us;
- When we require a credit check in conjunction with your application; and
- When you visit our offices.
- For the administration and support of a contract such as an order of goods, a trade agreement, an operations agreement or a service you’ve requested;
- For the administration of a job application;
- To conduct a credit check in line with your application (if required);
- To request ongoing credit reference services to ensure your ongoing suitability for credit terms (if required);
- To respond to an enquiry, feedback or complaint you may have sent to us;
- To improve the products or services we offer;
- To administer our websites including troubleshooting, data analysis, testing, research, statistical and survey purposes. Also to keep it safe, secure and accessible;
- To administer a promotion, offer or competition that you may participate in;
- To notify you about any changes to our services; and
- For the communication of marketing materials (including e-mail, advertisements on social media, and in certain circumstances, phone calls);
- For absolute clarity we do not intend our marketing materials to be received by anybody under the age of 18 due to the nature of our business. Your personal data may be used to determine whether you meet this criteria.
|What are we trying to achieve?||What personal Data is involved?||Our lawful basis for processing|
|To respond to your feedback, enquiry, comment or complaint||Identity Contact||Necessary for our legitimate interests (to ensure resolution to your reason for contacting us so that business can continue in a manner you’d expect)|
|To fulfil your order for products or services, including where you sign up for an online account with us||Identity Contact Financial Transactional Technical||Performance of Contract|
|To take steps to or make you a party to a business agreement (such as a Tenant, Retailer, Lessee, Free Trade Customer or other similar arrangement)||Identity Contact Financial Transactional Marketing preferences||Performance of Contract Necessary for our legitimate interests (to conduct initial or ongoing credit reference checks, to offer you beneficial information (particularly on our current promotions), to recover outstanding monies from you)|
|To administrate a competition, survey, or review that you are party to (and to notify you of any such changes that may affect you)||Identity Contact||Performance of contract Legal Obligation (competitions) Necessary for our legitimate interests (to action the responses to surveys or reviews to improve our products and services)|
|To conduct troubleshooting, data analysis, testing, research, system maintenance, support, reporting and hosting of data||(a) Identity (b) Contact (c) Technical||Necessary for our legitimate interests (to run our business in the best possible manner, providing administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Legal obligation|
|To administrate a job application||Identity Contact Profile||Performance of Contract Legal Obligation|
|To fulfil marketing communications via email, SMS or in certain circumstances telephone||Identity Contact Profile Marketing and Communications||Consent Performance of Contract/Necessary for our legitimate interests (telephone – to provide marketing services to other businesses so that we can communicate our current offers and promotions. To improve our relationship with you and ultimately grow our business)|
|To deliver relevant website content and advertisements (including on social media websites) to you and analyse feedback so that we can measure the effectiveness of the materials To also suggest products and services we believe you will be interested in||Identity Contact Profile Usage Marketing and Communications Technical||Necessary for our legitimate interests (to show how customers interact with our advertisements, use our products/services, so that we can improve the advertisements, our relationship with you, products and services, ultimately to improve and grow our business)|
|We do not intend our marketing materials to be received by anybody under the age of 18 due to the nature of our business. Your personal data may be used to determine whether you meet this criteria.|
- Business Partners, suppliers and sub-contractors where they are performing a contract we have entered into with them;
- Advertising networks and support teams of this function to select and serve the relevant ads to you (particularly where we may share some of your details with a third party to enable delivery of more suitable advertisements to your social media homepage);
- Analytics and search engine providers that assist us in optimising our site;
- Website & website services hosts including payment processors;
- Credit reference agencies;
- Agencies that assist in sending our marketing communications; and
- Authorities or organisations where there is a legal obligation for us to do so or for the prevention of fraud; and
- We may share your email address with our third party who then utilise the feature, looking at demographics and other traits like interests taken from information that you have uploaded onto Facebook in order to bring our advertisements to the people who might be interested in them most.
- Specifically in relation to targeted marketing, there is no further data held by Marston’s as a result of completing this type of project. Our goal is to reach our current and prospective customers with information and offers that may be suitable for them - not to gather as much information as we can about them. We may receive anonymous statistics and trend identifications as a result of the project however. Our third party that assist us in these services delete any data within 2 weeks of the initial commencement of the project.
- Right of Access to your personal data
- Right to rectification of your personal data
- Right to erasure of your personal data
- Right to object to processing of your personal data
- Right to restrict processing of your personal data
- Right to data portability
- Website Hosts – In this instance ADZ Creative and Digital Ltd (media) are the host of this website;
- Merchant Services providers;
- Providers of accident management systems, insurance managers and claims handlers;
- Agencies providing distribution services for marketing materials and or service information, whether electronic or in hard copy;
- Credit reference agencies;
- HMRC, regulators or other authorities as necessary;
- Providers of prizes or incentives in relation to competitions, promotions or surveys;
- Share registration and management service providers;
- IT Systems and administration services providers;
- Advisors or agencies acting on our behalf such as solicitors, auditors, insurers, and collections agencies;
- Right of Access to your personal data – This is usually called a ‘Subject Access Request’. You can request a copy of personal data to see what we hold about you and to check why & how we are processing it and that we are processing it lawfully. We may be required to suitably redact (obscure) elements of the requested detail to protect the rights and personal data of other individuals.
- Right to rectification of your personal data – If you recognise any of the personal data we hold on you to be incorrect or incomplete you can request it to be corrected. In certain circumstances, we may require proof of accuracy of any new data being submitted.
- Right to erasure of your personal data – If you believe there is no fair reason for us to hold an element of your personal data, you can ask us to remove or delete this from our records, On occasion you may want to exercise this right on a successful objection to processing (see definition below). If for any reason, for example, to comply with a legal obligation, we cannot delete your personal data we will action your request as far as possible and provide to you a reason as to why we cannot fully comply with your request.
- Right to object to processing of your personal data – If we rely on legitimate interest as our legal basis for processing or the legitimate interest of another third party, you can object to our processing if you feel it impacts your fundamental rights and freedoms. We will reassess the legitimate grounds we have for processing your data and on occasion we may demonstrate that they are sufficient in overriding your rights and freedoms. Specifically in relation to direct marketing, please see the section above entitled ‘Marketing’.
- Right to restrict processing of your personal data – You can ask us to temporarily pause the processing of your personal data in certain circumstances. For example:
- If you have objected to our processing of your personal data, but we are assessing whether our legitimate grounds override your rights and freedoms.
- If you want to ensure that it is correct or complete before we continue to use it.
- If we are processing the data unlawfully but you do not want us to delete it.
- If you ask us to keep the data where we no longer need it, as you require it to establish, exercise or defend legal claims.
- Right to data portability – This applies to automated information originally received on the lawful basis of consent or performance of contract. You can ask for a copy of the related data and for it to be transferred to a third party of your choosing in a commonly used, machine readable format.