Privacy Policy

Restaurant 1925 respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important Information and Who We Are

1.1 Purpose of This Privacy Policy

This privacy policy aims to give you information on how Restaurant 1925 collects and processes your personal data through your use of this website, including any data you may provide when you make a booking or reservation, sign up for our newsletter or promotional texts, or purchase a voucher or other goods.

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 or fair processing 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.

1.2 Controller

HAAR Restaurant Limited is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

1.3 Contact Details

Our full details are:
Full name of legal entity: HAAR Restaurant Limited
Data privacy manager: info@deanbanks.co.uk
Postal address: Restaurant 1925, The Caledonian Hotel, Princes Street, Edinburgh, EH1 2AB
Phone: 07401 760638

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

1.4 Changes to Your Personal Data

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

1.5 Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data 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:

• Identity Data: includes first name, maiden name, last name, and title.

• Contact Data: includes billing address, delivery address, email addresses, and telephone numbers.

• Financial Data: includes payment card details.

• Transaction Data: includes details about payments you have made, products and services you have purchased from us, and bookings and/or reservations you have made with us.

• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Usage Data: includes information about how you use our website and services.

• Marketing and Communications Data: includes your preferences in receiving marketing from us (e.g., newsletters or promotional texts) and your communication preferences.

We also collect, use, and share 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 or indirectly 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 Aggregated 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 policy.

We do not collect any Special Category Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), except where you have included information about your health (e.g., dietary requirements) when making a booking or reservation. Nor do we collect any information about criminal convictions and offences.

3. How Is Your Personal Data Collected?

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

• Direct Interactions: You may give us your Identity, Contact, and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

  • Make a booking or reservation;

  • Sign up for our newsletter or promotional texts;

  • Purchase products or services from us;

  • Request marketing to be sent to you;

  • Enter a competition, promotion, or survey; or

  • Give us feedback.

• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, Meta Pixel, and other similar technologies. Please see our Cookie Policy for further details.

• Third Parties: We may receive personal data about you from various third parties, including:

  • Identity, Contact, and Transaction Data from providers of restaurant booking services such as ResDiary.

  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services such as Stripe or Bluerunner.

  • Marketing and Communications Data from our marketing platform, Klaviyo, when you opt-in to receive newsletters or promotional texts.

4. How We Use Your Personal Data

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

• Where we need to perform the contract we are about to enter into or have entered into with you (e.g., for reservations or purchases).

• 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. Legitimate interests mean the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

• Where we need to comply with a legal or regulatory obligation.

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 via email or text message through Klaviyo. You have the right to withdraw consent to marketing at any time by contacting us or using the unsubscribe options provided in our communications. Where you have provided us with information about your health when making a booking or reservation, we may use this to record all relevant details about your booking or reservation and take steps to ensure your requirements are met. We have processes in place to limit our use and disclosure of such data other than where permitted by law.

4.1 Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use 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.

Purpose/Activity

Type of Data

Lawful Basis for Processing Including Basis of Legitimate Interest

To record your reservation or booking and/or otherwise register you as a customer

(a) Identity
(b) Contact
(c) Marketing and Communications
(d) Special Category Data (e.g., dietary requirements)

Performance of a contract with you

To process and deliver orders you make with us, including:
(a) Manage payments, fees, and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, which will include:
(a) Notifying you about information relevant to your reservation or booking
(b) Notifying you about changes to our terms or privacy policy
(c) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) 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 and to study how customers use our products/services)

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 reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation

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 deliver targeted advertisements through Google Ads and Meta Pixel based on your interactions with our website

(a) Technical
(b) Usage

Necessary for our legitimate interests (to grow our business and promote our services effectively)

To send you newsletters and promotional texts via Klaviyo (if you have opted-in)

(a) Identity
(b) Contact
(c) Marketing and Communications

Consent

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 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 above.

4.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We use Klaviyo to send newsletters and promotional texts to customers who have explicitly opted-in to receive these communications. You can withdraw your consent at any time by clicking the "unsubscribe" link in our emails, replying "STOP" to our texts, or contacting us directly.

4.3 Promotional Offers from Us

We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have opted-in to receive newsletters or promotional texts and have not subsequently opted out.

4.4 Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside HAAR Restaurant Limited for marketing purposes.

4.5 Opting Out

You can ask us to stop sending you marketing messages at any time by:

• Clicking the "unsubscribe" link in any email newsletter.

• Replying "STOP" to any promotional text message.

• Contacting us at info@deanbanks.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.

4.6 Cookies and Tracking Technologies

We use cookies, Meta Pixel, Google Analytics, and Google Ads to collect Technical and Usage Data to enhance your experience and deliver targeted advertisements. 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 and tracking technologies we use, please see our Cookie Policy.

4.7 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 us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that 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.

5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Other companies within the HAAR Restaurant Limited group of companies, where processing functions are centralized.

• Trusted third-party service providers and professional advisors where this is necessary to provide a service to you, such as:

  • ResDiary for restaurant booking services.

  • Stripe or Bluerunner for payment and delivery services.

  • Klaviyo for email and SMS marketing services.

  • Google for Analytics and Ads.

  • Meta for Pixel tracking.

  • System administration service providers and auditors.

• HM Revenue & Customs, regulators, and other authorities who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

6. International Transfers

Some of our third-party service providers (e.g., Google, Meta, Klaviyo) may transfer your personal data outside the United Kingdom (UK) or European Economic Area (EEA), such as to the United States. We ensure that any such transfers are conducted in compliance with UK GDPR and the Data Protection Act 2018, using appropriate safeguards such as Standard Contractual Clauses to protect your data.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized 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.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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.

For example:

• Reservation data is retained for up to 2 years for operational purposes.

• Marketing data (e.g., for newsletters or promotional texts) is retained until you unsubscribe or withdraw consent.

In some circumstances, you can ask us to delete your data: see below for further information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

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

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios, such as if you want us to establish the data’s accuracy or where you have objected to our use of your data.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data (e.g., for marketing via Klaviyo). This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at info@deanbanks.co.uk.

9.1 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.

9.2 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 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.

9.3 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 several requests. In this case, we will notify you and keep you updated.

Amendments to the Privacy Policy

Any changes made to our privacy policy will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.