Privacy Notice

This Privacy Notice sets out the basis on which Hache Burger Connoisseurs Ltd (in administration), operating as Hush Holborn (“we”, “our”) as the data controller will process personal data that we collect and receive from and about the users of our website ( www.hush.co.uk/Holborn ), subscribers to our newsletter or when you use our services (such as telephone booking/reservations/enquires).

​Please read this notice carefully to ensure you understand how we use and treat your personal data and the rights you have in relation to your Personal Data.

Personal Data means any information which identifies or relates to you either on its own or in combination with other information.

We are committed to ensuring that your privacy and Personal Data are protected. This Privacy Notice describes how we collect, keep, use and share your Personal Data through your use of our website or services.

1. PERSONAL DATA WE COLLECT FROM YOU

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Contact Data including email address, postcode and telephone number(s).

• Identity Data including your first name, last name, Technical Data includes internet protocol (IP) address, The data transmitted from your browser includes your IP address, the date and time of the visit, the pages accessed, the access status/HTTP status code, your browser, your operating system and interface and the language and version of the browser software.

• Usage Data includes information about how you interact with and use our website and services, site referrals, browsing pattern, browsing type, general interests.

We do not process any personal data that qualifies as sensitive/special category data or criminal offence/conviction data under data protection laws, nor do we knowingly collect personal data from children.

 

1. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect personal data from and about you including through:

1. Your direct interactions with us. This includes personal data you provide when you:

• Make a reservation or booking directly with us via the ‘Enquire Today’ functionalities on the website, or when you call us directly; this may include your contact details and some special category data when you volunteer this information to us, such as dietary requirements, access requirements.

1. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment and browsing actions. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites that use third party cookies that our Website uses. Please see our cookie policy at https://www.hush.co.uk/cookiespolicy for further details.

 

1. Third parties or publicly available sources. We may obtain the following personal data about you from the following sources:

 

• Seven Rooms: We work with Seven Rooms as an external reservations system in order to collect and process bookings online. They will not share your data with us without your consent. You can access Seven Rooms privacy policy here: ​https://sevenrooms.com/en/privacy-policy/  

• Design My Night:  We work with Design My Night as an external reservations system in order to collect and process bookings online. They will not share your data with us without your consent. You can access Design My Night’s privacy policy here: ​https://www.designmynight.com/privacy-policy  

 

1. HOW AND WHY WE USE YOUR PERSONAL DATA

The law requires us to have a legal reason (known as a ‘lawful basis’) for collecting and using your personal data. We rely on one or more of the following lawful bases:

Where you have provided your CONSENT

We may use and process your personal data where you have consented for us to do so for the following purposes:

• to use non-essential cookies on our website, as further described in our Cookie Policy https://www.hush.co.uk/cookiespolicy

• to share with us your personal data to collect and process bookings online received via a third-party (such as Seven Rooms or Design My Night).

 

Where there is a LEGITIMATE INTEREST

We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

For your and our legitimate interest in providing our services and supporting customers and users with their enquiries:

• For the administration of your reservation and to contact you about your reservation only (for example if changes are needed);

• to manage and respond to queries made by you about our restaurant, food, events or our website; and

• to provide you with technical support.

For our legitimate interests in operating the administrative and technical aspects of our business efficiently and effectively

• to administer and maintain our website and services, including to personalise our website for our users and customers and to enable use of the website, troubleshooting, testing or for statistical purposes;

• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access; 

• for efficiency, accuracy or other improvements of our products, services, business processes, databases and systems, for example, by combining systems or consolidating records we hold about you;

• for the purposes of corporate restructure or reorganisation or sale of our business or assets;

• for cookies that are essential for our website to function properly, as described in our Cookie Notice;

• to aggregate or otherwise anonymise your information, and to permit our service providers to do the same, for our or those providers’ use of the anonymised information for operational, administrative or business improvement purposes;

• to notify you about changes to our services or the availability of our services and website;

• to inform you of updates to our terms and conditions and policies; and

• for other general administration purposes, including to send service messages to you.

 

For our legitimate interests in communicating with you and to assess and respond to complaints, claims and regulators:

• to communicate with you to respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;

• to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.

 

Where necessary to comply with our LEGAL OBLIGATIONS

We will use your personal data to comply with our legal obligations:

• to keep a record relating to the exercise of any of your rights relating to our processing of your Personal Data;

• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);

• to anonymise or delete your Personal Data when it is no longer required for the purposes described in this Privacy Notice;

• to comply with court orders or other notices where we are required to do so to comply with the law; and

• to handle and resolve any complaints we receive relating to our processing of your Personal Data as described in this Privacy Notice.

 

1. DATA SHARING

Hush Holborn (operated by Hache Burger Connoisseurs Ltd (in Administration) will not share your information with any third party except as stated in this Privacy Notice. We conduct extensive assessments before engaging any company that will process that data on our behalf to ensure that they have appropriate technical and organisational measures in place that provide adequate protection of your Personal Data. Anyone who is processing Personal Data on our behalf is bound by contractual obligations to keep Personal Data confidential and secure, and to use it only for the purposes as instructed by us. We do not allow our third-party service providers (as sub-processors) to use your Personal Data for their own purposes.

We may share your Personal Data:

• with our service providers that we use to support and provide our business, such as technical service or operation providers, to the extent needed to enable and provide the Services to you. Our suppliers include IT service providers (cloud services, hosting, data management, data analytics and software development providers), analytics providers (such as Google Analytics) and professional services providers (legal, insurers, administrators, accounting providers etc),

• with our successors, if we are involved in e.g. a merger, acquisition or asset sale, giving you notice of this,

• if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies, and/or to protect and defend ourselves or our users' rights and interests.

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1. DATA SECURITY

We maintain technical and physical safeguards that are designed to protect the security and integrity of your Personal Data, and to guard it against accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls and virus checking procedures.

If you suspect any misuse or loss of or unauthorised access to your Personal Data, please let us know immediately by contacting us using the details provided at the end of this Privacy Notice.

Our website may from time to time contain links to and from other websites. If you follow a link to any of those websites, please note that those sites ought to have their own privacy notices or applicable policies. Please check those privacy notices/policies before you submit your Personal Data to those websites.

 

1. DATA STORAGE AND RETENTION Storage

If we collect your Personal Data, the length of time for which we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain Personal Data in an identifiable format for longer than is necessary for the purpose for which it was originally collected unless:

·the law requires us to hold your Personal Data for a longer period, or delete it sooner;

·you exercise your right to have the data erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;

·you exercise your right to require us to retain your Personal Data for a period longer than our designated retention period; or

·we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible.

 

1. INTERNATIONAL TRANSFERS

 

Some of the third parties described in section 4 (Data Sharing) above are based outside the UK (and, in certain cases, outside Europe) so their processing of your personal data will involve a transfer of data by us outside the UK. Those countries may not have similar data protection laws to the UK and so may not protect the use of your Personal Data to the same standard. In accordance with applicable data protection laws, we implement measures to address this, including by relying on standard contractual clauses or declarations by regulators or governments (e.g. adequacy decisions) to ensure that any transferred personal data remains protected and secure.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data outside of the UK.

1. AUTOMATED DECISION MAKING

We do not undertake any automated decision making through your use of the website or services which have a legal or significant effect on you will be taken about you using purely automated means, however we will update this Notice and inform you if this position changes.

1. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have a number of rights in relation to your Personal Data.

You have the right to:

• update and correct the personal information on your account.

• request all personal information that we hold that relates to you,

• request restriction of the processing of that data and to request that we delete that data. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request.

• to object to our continued processing of your personal data.

• data portability.

If you have a complaint about the way in which we use your personal information you have the right to complain to the Information Commissioner www.ico.gov.uk. You can contact us with questions about the personal information we hold about you using the contact information provided in the “Contacting Us” section of this Privacy Policy.

Changes to our Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our business. All such changes will be posted to the Sites and if we consider it to be appropriate we will notify subscribers of any material changes by e-mail.

Contacting us

Hache Burger Connoisseurs Ltd (in administration), operating as Hush Holborn is the Data Controller in respect of any Personal Data that you submit to us or that we collect from or about you. We are a limited company registered in England and Wales (Limited company no. 04329994) with registered offices at C/O Interpath Ltd, 10 Fleet Place, London, EC4M 7RB. If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Notice, or our Sites, our contact details are as follows:

Hache Burger Connoisseurs Ltd (in administration) at 10 Fleet Place, London, EC4M 7RB or by e-mail hacheburger@interpath.com.

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