This notice explains what personal information we collect when you have a membership card at The Fighting Cocks, Old London Road Cafe or Bacchus, or visit this website, what we do with it, and the choices you have. We've tried to keep it clear and short, and if anything doesn't make sense, just ask us!
Who we are
Lightning Bolt Entertainment Ltd ("LBE", "we", "us") runs the membership cards for The Fighting Cocks, Old London Road Cafe and Bacchus in Kingston upon Thames.
- Company number 13478875, registered in England and Wales
- Registered office: 32 Park Road, Egham, Surrey, TW20 9BJ
- ICO registration number: ZB243740
- Contact: loyalty@lightningboltentertainment.co.uk
Who is responsible for your information
Lightning Bolt Entertainment Ltd is responsible for your information (the "controller") for membership cards at all three venues: The Fighting Cocks, Old London Road Cafe and Bacchus. Some cards, such as Student and Staff Partner cards, can be used at more than one of our venues. Whichever venue your card is for, you can contact us about your information at loyalty@lightningboltentertainment.co.uk.
What information we collect
Your membership:
- your name and email address, which we already hold from your existing membership
- the venue your card is for and the type of membership you have
- your card number or code, the date it was issued, and whether it is active, replaced or cancelled (and, if cancelled, the reason)
- a record of actions our staff take on your membership, such as issuing or replacing a card
Your choices: when you claim your card, we ask you two things with tick boxes: whether you'd like marketing emails, and whether you'd like notifications about your card in your wallet app. Whenever you tick or untick either box, we record your choice together with your IP address, your browser details, the exact wording you were shown, and the time. We keep this as proof of what you agreed to.
When you add your card to Apple Wallet or Google Wallet: the card is stored on your phone. So that we can keep your card up to date, Apple sends us a device ID and a notification token, and Google gives us a reference number for your card. We don't receive your Apple or Google account details.
Location: your card contains the location of your venue, so that your phone can show the card when you're nearby. That happens on your phone. We never learn where your phone is, and we don't know when you open your card.
When you contact us: your email address, what you tell us, and our replies.
When you visit this website: this site doesn't use cookies or analytics. Our hosting provider may record basic technical information such as your IP address and browser type, to keep the site running securely.
How we use it and why
Data protection law requires a lawful reason for using your information. Here's what we use it for, and the reason that applies:
- Running your membership - issuing your card, giving you your discount, replacing or cancelling cards, and sending you emails about your card (such as your claim link). This is necessary to provide the membership you signed up for.
- Keeping your card up to date - using your wallet app's device ID or card reference to update the card on your phone. This is necessary to provide your membership.
- Wallet notifications - sending notifications about your card to your wallet app, only if you've ticked the box. We rely on your consent, and you can withdraw it at any time.
- Marketing emails - news, events and offers from your venue, only if you've ticked the box. We rely on your consent, and you can withdraw it at any time.
- Keeping records of your choices and our actions - so we can show what you agreed to and how your membership has been handled. This is needed to meet our legal obligations and is in our legitimate interests in running the scheme properly.
- Helping you when you get in touch, and preventing misuse - such as fixing problems with your card or cancelling a card that is being misused. This is in our legitimate interests in looking after our members and running the scheme fairly.
We don't sell your information, and we don't use it to make automated decisions that have legal or similarly significant effects on you.
Changing your mind
You can change your marketing and wallet notification choices at any time. Use the unsubscribe link in any marketing email, or email us. Unsubscribing won't affect your membership card or your discount, and we'll still send you essential messages about your card.
Who we share it with
We only share your information with companies that help us run the membership scheme and this website, and only as much as they need:
- Supabase, which provides our membership database. The database is hosted in London.
- Netlify, which hosts this website and our membership pages
- Resend, which sends emails about your card, such as sign-in links
- Mailchimp, which sends the email inviting you to claim your card, and our marketing emails
- Microsoft, which provides our email inbox
- Apple and Google, when you add your card to Apple Wallet or Google Wallet. Their own use of your information is covered by their privacy policies.
We will also share information if the law requires it, or where we need to in order to protect our rights, our staff or our customers.
Transfers outside the UK
Our membership database is stored in London. Some of the companies that help us are based outside the UK, mainly in the United States, and one is in Singapore, so your information may be accessed from, or processed in, those countries. When that happens, it's protected in one of two ways: either the company is certified under the UK-US data bridge, or we use the UK's approved contract terms for international transfers (the International Data Transfer Addendum).
| Company | What they do for us | How your information is protected |
|---|---|---|
| Supabase Pte. Ltd (Singapore) | Stores your membership record, in London | UK International Data Transfer Addendum |
| Netlify, Inc. (US) | Runs this website and our membership pages | UK-US data bridge |
| Plus Five Five, Inc., trading as Resend (US) | Sends emails about your card | UK-US data bridge and UK International Data Transfer Addendum |
| The Rocket Science Group LLC, trading as Mailchimp (US) | Sends our invitation and marketing emails | UK-US data bridge |
When you add your card to Apple Wallet or Google Wallet, Apple or Google hold a copy of your card under their own privacy policies. You can ask us for a copy of the safeguards at loyalty@lightningboltentertainment.co.uk.
How long we keep it
- Membership details: while your membership is active, and for 24 months after it ends or is cancelled.
- Records of your choices: for as long as we keep your membership record.
- Emails to our inbox: for 2 years from when we receive them, then deleted.
- Records of staff actions: for 6 years. When your membership record is deleted, anything that identifies you is removed from these records.
Keeping it safe
We use appropriate technical and organisational measures to protect your information, including restricting access to the people who need it and using secure, reputable providers. Your claim link is personal to you, so please don't forward it to anyone else.
Your rights
You have the right to:
- ask for a copy of the information we hold about you
- ask us to correct information that is wrong or incomplete
- ask us to delete your information
- ask us to restrict how we use your information
- object to how we use your information, including for marketing
- ask us to transfer information you gave us to you or another organisation
- withdraw your consent at any time
To use any of these rights, email loyalty@lightningboltentertainment.co.uk. We'll respond within one month. Some rights have exceptions, and if one applies we'll explain why.
Complaints
If you're unhappy with how your information has been handled, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk/make-a-complaint.
Changes to this notice
We may update this notice from time to time. The latest version will always be on this page, with the date it was last updated at the top.