LUMA CLUBS LTD T/A TOY ROOM
This Privacy Statement applies to the processing by LUMA CLUBS Ltd. (our guests) personal data. LUMA CLUBS Ltd. takes your privacy very seriously and treats all your personal data with great care. LUMA CLUBS LTD. acts in accordance with the applicable data protection legislation.
When you visit our website, make a reservation, contact us, we collect information from and about you. Some of the information we collect may be classed as personal data under data protection legislation, that is, “any information relating to an identified or identifiable natural person”. It may be collected any time you submit it to us, whatever the reason may be.
This Privacy Statement describes which personal data is collected and for which purposes this personal data is processed by LUMA CLUBS LTD It also states which rights you have under applicable data protection legislation.
PARTICULARLY IMPORTANT INFORMATION
WHO WE ARE: For the purpose of applicable data protection legislation, the data controller of your personal data is LUMA CLUBS LTD (Trading as Toy Room) 8-9 Argyll Street, London W1F 7TH
2. COLLECTING YOUR PERSONAL DATA
The LUMA CLUBS Ltd collects information about you in the following ways.
Information you give to us. This includes personal data collected:
Through our Website when you register, login, commence or require call back.
When you contact our reservations team to make a booking When you have provided your consent, in order to: o attend our showcases, seasonal events
subscribe to any of our marketing communications
complete customer surveys enter competitions or provide feedback.
When we do business with you, which will usually include: o Full or partial contact details including names and addresses (including business details if you are making a corporate booking, telephone and email details.
If you have special requirements, then it may also be necessary to collect details about diet or disability or any other preferences that you may have.
We collect payment card information from you should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.
From our overseas guests we may also collect passport details.
Information Automatically Collected. This includes information and personal data collected:
Through our Website. We automatically log information about you and your computer or mobile device when you access.
Through CCTV at our properties. We operate CCTV systems at our properties. These are in operation and video recordings may be made. This activity is carried out for security and service reasons for the better management of premises.
3. WHY DO WE PROCESS YOUR PERSONAL DATA?
Your personal data will be stored in (i) centralized systems which are under the control LUMA CLUBS Ltd. and accessible by authorized staff LUMA CLUBS Ltd.
We use the information we collect about you to process your bookings, answer your queries, with your consent, we will contact you via our marketing and sales channels (email only) about other related products and services we, or our group business, provide which we think may be of interest to you. Our marketing communications are generally sent by email.
We mainly collect, store and process personal data at two different stages:
i. Before you decide to visit or book with us
When you visit our Website (www.toy-room.com ), we collect information about your use of the Website. This includes both information we collect directly from you, and information we collect about your behavior. This information may constitute 'personal data' under applicable law.
ii. When you visit or have visited us
When you make a reservation, you will have to provide us with your name, email address, phone number, the date of your booking and a credit card info or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation.
Overview of activities under stage (i) and (ii):
We may at each of the stages outlined above use your personal data but only when and to the extent 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 or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where you have provided your consent.
For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow us to process this data:
4. SHARING YOUR DATA
We may share your personal data as follows:
Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
Our Third-Party Service Providers. We may share your personal data with our third-party service providers who provide services such as payment processing, information technology and related infrastructure provision, business support (operational and administrative), customer service, the processing and delivery of marketing communications to you, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data. Third parties are subject to confidentiality obligations and may only use your personal data to perform the necessary functions and not for other purposes.
Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Privacy Statement. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Privacy Statement; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
We do not share your data with any third parties outside of the above processing arrangements and we do not share your data with any business external to our group for their own marketing purposes. From the data we collect, you should only ever receive marketing communications from our own brands and hotels.
5. YOUR RIGHTS
The GDPR provides the following rights for individuals:
Right to revoke consent
If we process personal data based on your consent, you have the legal right to revoke such consent at any time. We will then cease the relevant processing activity going forward.
Right of access to your information
If you want to know what personal data we have collected or process about you, you may request us to provide a copy of your personal data by sending an email office@ toy-room.com We will ask you to identify yourself. We will not provide you with a copy of your personal data to the extent that the rights and freedoms of others are or may be adversely affected.
Right to rectification and erasure of data, and restriction of processing
If you believe that our processing of your personal data is incorrect, inaccurate, unlawful, excessive, incomplete, no longer relevant, or if you think that your data is stored longer than necessary, you may ask us to change or remove such personal data or restrict such processing activity, by sending an email to email@example.com
Right to data portability
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format, in accordance with Article 20 of the General Data Protection Regulation.
Right to object
You have the legal right to object, on grounds relating to your particular personal situation, at any time to processing of your personal data. Furthermore, you have the right to object at any time to our processing of your personal data for direct marketing purposes or to profiling. You can do this by either (i) opting out by using the option we provide in the relevant direct marketing message (e.g. firstname.lastname@example.org ), or (ii)or (ii) by sending an email email@example.com or (iii) writing to:
LUMA CLUBS LTD
8-9 Argyll Street
For the sake of clarity: without prejudice to the foregoing we are at all times entitled to send you messages that do not constitute direct marketing, i.e. service messages.
General information relevant for all requests and queries
Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under applicable mandatory data protection law.
7. PROTECTION AND STORAGE OF YOUR DATA
We have used and will continue to use reasonable endeavors to protect your personal data against loss, alteration or any form of unlawful use. Where possible, your personal data will be encrypted and stored on a virtual private server that is secured by means of state of the art protection measures. A strictly limited amount of people has access to your personal data.
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.
9. RETENTION OF INFORMATION
We will only retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Statement. This may be up to 4 years, unless a longer retention period is required or permitted by law (which is typically the case in the context of our obligations under tax law).
Should you choose to unsubscribe from our mailing list, please note that your personal data may still be retained on our database to the extent permitted by law.
We are committed to resolve any complaints about our collection or use of your personal data. In case you have any questions in relation to this Privacy Statement or our practices in relation to your personal data you may send an e-mail to office@ toy-room.com We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
We have done our best to make sure that this Privacy Statement explains the way in which we process your personal data, and rights you have in relation thereto. We may change this Privacy Statement from time to time to make sure it is still up to date and we will notify you if we make any material updates. We may also notify you in other ways from time to time about the processing of your personal information.