Privacy Policy

Introduction

G-A-Y Group Limited (“G-A-Y”) respects your privacy and is committed to protecting your personal data. The purpose of this Privacy Policy is to explain how we will use any personal data we collect about you, the rights you have over any personal data we hold about you, and to tell you about the policies and procedures that we have in place to respect your privacy and keep your personal data secure.

 

Contents:

  1. Important Information and who we Are
  2. what data do we collect about you?
  3. How is your personal data collected?
  4. How do we use your personal data?
  5. How do we share your personal data? 
  6. Where do we transfer your data?
  7. How long do we keep your personal data?
  8. How do we protect your personal data?
  9. What are your legal rights?

 

  1. Important Information and who we Are

 

Purpose of the Privacy Policy

This Privacy Policy applies to you if you visit any of our venues, G-A-Y Bar, G-A-Y Late, Heaven London or G-A-Y Manchester (collectively the “G-A-Y Venues” and each a “G-A-Y Venue”), purchase a ticket online for an event or service at a G-A-Y Venue, apply for a guest list at a G-A-Y Venue, apply for a membership of the G-A-Y Venues or of a club night that we promote, subscribe to receive G-A-Y newsletters, Popcorn newsletters or Heaven Live newsletters or any other newsletters we may offer from time to time, hire a G-A-Y Venue, use our products or services at the G-A-Y Venues, over the phone, online, through our mobile applications or otherwise by using any of our websites or interacting with us on social media (collectively, our “Services”).

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

 

The Data Controller – Who we are

G-A-Y Group Limited is the controller and responsible for your personal data (the “Company”, “we”, “us” or “our” in this Privacy Policy). The Company is owned by JJ Is G-A-Y Limited and has one subsidiary, Heaven (London) Limited (the “Group”). The Company is the controller and responsible for all websites in the Group. 

 

Our contact details

If you have any comments or questions about this Privacy Policy or our data processing practices, please address them to us at privacy@g-a-y.co.uk or address the letter for the attention of our Data Protection Manager, who can be contacted at Heaven Nightclub, 11 Villiers Street, London, WC2N 6NG.

 

Your details and any changes

We need to ensure that the data that we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

 

Third Party Links

We sometimes provide you with links to other websites or mobile applications, but these websites and mobile applications are not under our control. We are only responsible for the privacy practices and security of our Services. We are not responsible for the privacy policies, content or security of any linked websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit.

In some instances, a third party may operate or host a competition on our website or mobile application, and collect your personal data. In those cases, where we are not the operator or host of the competition, we have no control over the personal data collected and accordingly urge you to review the third party’s privacy policy before participating.

  1. what data do we collect 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).

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

 

From time to time we may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

The only Special Category of Personal Data we collect about you is information you provide to us about your health (for example when you are buying tickets for wheelchair accessible spaces or when we are investigating an accident which may have happened at a G-A-Y Venue). We do not collect details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic or biometric data. Nor do we collect any information about criminal convictions and offences, other than those offences committed or allegedly committed at a G-A-Y Venue where it is in our legitimate interests to do so and is in order prevent or detect an unlawful act where it is necessary in connection with any legal proceedings or prospective legal proceedings, to obtain legal advice, or is otherwise necessary for the purposes of establishing, exercising or defending legal rights. 

  1. How is your personal data collected?

 

Sources of personal data

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

 

We may also receive personal data about you from third parties and public sources as set out below. 

We may combine any personal data about you that we receive from you and from third parties.

  1. How do we use your personal data?

All personal data that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We, or third party data processors acting on our behalf, will only use your personal data in the following circumstances:-

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you vial email or text message or taking a photograph of you in which you can be identified at a G-A-Y Venue. You have the right to withdraw consent to marketing at any time by contacting privacy@g-a-y.co.uk.

With your explicit consent we process personal data about your health to provide you with tailored services such as wheelchair accessible space and to help us investigate an accident which may have happened at a G-A-Y Venue. 

Purposes for which we will use your data

We have set out below, in a table format, a description of the ways we, or our third party processers acting on our behalf, plan to process your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at privacy@g-a-y.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a member and contact you about members’ events

 

 

(a) Identity

(b) Contact

(c) Profile 

 

  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to administer membership communications, to contact members in case of lost and found membership cards).

 

To provide free, guestlist access to G-A-Y Venues

  1. Identity
  2. Contact

 

  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to ensure we have the correct details for guestlist operation, to contact guest with details of any changes to the event)

 

To verify identity of our members for security purposes

  1. Identity
  2. Contact
  3. Profile

 

  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to protect the safety of the G-A-Y Venues and our staff and customers)

 

To process your ticket order

  1. Identity
  2. Contact
  3. Transaction

 

 

 

  1. Necessary for our legitimate interests and those of promoters’ ticket agents (to ensure only those customers who have bought tickets from promoters’ ticket agents access the venue, to fulfil contract between customer and ticket agent) 

To obtain contestants’ consent to abide by Porn Idol rules

  1. Identity

 

  1. Necessary for our legitimate interests (to ensure all contestants understand and abide by competition rules and to record the agreement, to provide evidence in the event of legal proceedings) 

 

To enable us to pay suppliers

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (keeping financial records for good business governance to allow us to pay suppliers)

 

Use of CCTV and/or bodycams to prevent and detect crime

  1. Identity

 

  1. Necessary to comply with a legal obligation
  2. Necessary for our legitimate interests (to prevent and detect crime and to protect the safety and security of visitors to the G-A-Y Venues and those who work there)

Use of CCTV for investigations

  1. (a)Identity

 

  1. Necessary to comply with a legal obligation
  2. Necessary for our legitimate interests (to investigate health and safety and other incidents which have happened at G-A-Y Venues, to provide evidence in the event of legal proceedings)

Photographs of crowds/events at G-A-Y Venues

 

  1. (a)Identity

 

  1. Necessary for our legitimate interests (to capture footage of artists performing at G-A-Y which feature crowd in the background)

To manage access to specific areas of the G-A-Y Venues

  1. (b)Identity
  2. Contact
  1. Necessary for our legitimate interests ( to manage access to backstage or VIP areas) 

To manage our relationship with promoters 

  1. Identity
  2. Contact
  3. Financial 
  4. Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep records of promoters of events at the G-A-Y Venues, contact them in connection with business matters and settle any sums due on the maturity of an event)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Providing you with information about our Services

(d) Contacting you about administrative matters

(e) Managing and responding to any queries or complaints you make or correspondence you send us

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to provide a better service, to correspond with you where you have requested a response and obtain your feedback to improve our services, to resolve any disputes in the early stages to protect our business, to help us to return lost property to its rightful owner).

 

 

To deliver relevant marketing communications to you in order to market our Services including, where applicable, processing your registration and creating custom marketing audiences on third party websites such as Facebook 

(a) Identity

(b) Contact

(c) Technical

(e) Profile

 

Necessary for our legitimate interests (in order to effectively market our Services and ensure they operate in a commercially suitable way which is tailored to your use and interests)

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business, to confirm delivery of a prize)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content to you 

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. 

 

You may receive marketing communications from us if you have joined one of our memberships or have requested information from us or if you have provided us with details when registering for a guestlist and have opted in to receiving marketing. 

 

Third party marketing

We will get your express opt-in consent before we share your personal data with any company outside of the Group for marketing purposes.

 

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact privacy@g-a-y.co.uk. 

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. How do we share your personal data?

We may share your personal data with other companies in the Group.

We will share your personal data with the data processors that help us to provide the Services. These include:-

We will also disclose your personal data to third parties in the following circumstances:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

Save as expressly detailed above in this section, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent.

  1. Where do we transfer your data? 

 

Your personal data may be transferred to, and processed in a location outside of the European Economic Area (EEA).

Many of our external third party processers are based outside of the EEA so their processing of your personal data will involve a transfer outside the EEA. 

Some countries outside the EEA do not have laws that protect your privacy rights as extensively as those in the United Kingdom. However, if we do transfer your personal data to other territories, we will put in place appropriate safeguards to ensure that your personal data are properly protected and processed only in accordance with this Privacy Policy. Those safeguards include imposing contractual obligations of adequacy or requiring the recipient to subscribe to or be certified with an ‘international framework’ of protection. You can obtain more information about the safeguards we put in place by contacting us at privacy@g-a-y.co.uk.

 

  1. How long do we keep your personal data?

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including 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. 

We shall retain the following data for the following periods:-

 

 

 

 

 

 

We will retain your personal data for longer if we believe we may need them in order to respond to any claims, to protect our rights or the rights of a third party, and we will retain your personal data for longer if we are required to retain them in order to comply with applicable laws.

We will always retain your personal data in accordance with data protection law and never retain your personal data for longer than is necessary. If you have any questions about our retention policy contact privacy@g-a-y.co.uk. 

  1. How do we protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We cannot guarantee the security of your personal data when you transmit it to us. For example, if you email us your personal data, you should be aware that email is not a secure transmission method. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to us and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.

Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

  1. What are your legal rights?

 

You may contact our Data Protection Manager by email at privacy@g-a-y.co.uk at any time, to:

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

Your request must include your name, email address and postal address and we may request proof of your identity. Please allow at least seven working days for us to process your request.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Objection to legitimate interest processing

Where you object to processing personal data based on legitimate interests we can continue to process such data if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or where the processing is taking place for the establishment, exercise or defence of legal claims.

 

Withdrawing your consent

Where we are processing your personal data based on your consent, you may change your mind and withdraw your consent at any time.

You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email.

You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us at privacy@g-a-y.co.uk. In addition, you can unsubscribe from being a member and withdraw your consent to us processing the personal data which we hold for you as a member by notifying a manager at the venue at which you originally applied for membership.

 

The consequence of you withdrawing consent might be that we cannot do certain things for you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

 

We use cookies and web beacons on our websites. Third parties also view, edit, or set their own cookies or place web beacons on our websites. Cookies and web beacons allow us and third parties to distinguish you from other users of the website.

The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law

 

Right to lodge a complaint with a supervisory authority

You may also make a complaint to a supervisory authority for data protection matters. In the UK, this would be the UK Information Commissioner’s Office (https://ico.org.uk/). If you live in another EEA country, you may complain to the supervisory authority in your country. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

 

Changes to our Privacy Policy

We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your personal data. We recommend that you consult this page frequently so that you are aware of our latest Privacy Policy and can update your preferences if necessary. Your continued use of our Services shall constitute your acceptance of any revised Privacy Policy.

This Privacy Policy was last updated on 21 May 2018.

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