Last updated 9th May 2018

Clue HQ Brentwood respects your privacy and is committed to protecting your personal data in line with latest legislation.

1.0   

What is this Privacy Policy for?

1.1. This privacy policy is for this website [www.cluehqbrentwood.co.uk] and other services used by Cowen Edutainment Ltd trading as Clue HQ Brentwood] whereby personal data is gathered in some way and stored and governs the privacy of its users who choose to use said services and how the law protects you.

 

The website and services whereby you can sign up (newsletters, bookings and photo service) are not note intended for children under the age of 16.  We do not knowingly collect personal information from children under 16.  If you are under that age please do not use or provide any information on this website or any of the other services we use.  If you believe we might have any information from or about a child under 16, please contact us at [email protected]

The aim of this privacy policy is so you are fully aware of how and why were are using yoru data.

1.2. Controller – this privacy policy is issued on behalf of Cowen Edutainment Limited which is a limited liability company that trades under the name Clue HQ Brentwood.  Should  “we”, “use” or “our” be mentioned in this privacy policy then wea are referring to this company.  It is this entity that is the data controller for your data and responsible for this website and newsletter under the regulations.
1.3. Contact Details – Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to info at cluehqbrentwood dot co dot uk

Our full details are
Cowen Edutainment Ltd
Paul Cowen, Data Protection Officer
Email: info at cluehqbrentwood dot co dot uk
Postal Address: 104 Piggotts Way, Bishops Stortford, Herts, CM23 3QU

Telephone Number: +44 7494 499379

 

2.0   

The Data We Collect

2.1. 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).
2.2. We may collect, use, store and transfer the following personal information about you:

·        Identity Data, which includes your first and last name

·        Contact Data, which includes your email and postal address, your telephone number, your mobile number

·        Technical Data, which includes your internet protocol (IP) address, your login data, your 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 accept this website

·        Profile Data, which includes your username and password, purchases or orders made by you.

·        Usage Data, which includes information about how you use our website, products, and services

·        Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences

We do not collect any Special Categories of Data about you such as 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). Nor do we collect any information about criminal convictions and offenses.

 

 

3.0   

How Personal Data is Collected

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

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

    • Book online for escape games using our booking provider (Bookingbug)
    • Buy vouchers from us using our Voucher provider (Vouchercart)
    • Subscribe to our newsletter
    • Request a photo is sent to you post game using our photo provider (Buzzshot)
    • Use our online chat service
    • Email us
    • Speak to us on the phone to make an enquiry or booking
    • Contact us via our social media channels
      • Facebook Messenger
      • Twitter Message
      • Respond to automated chat messages via Facebook Messenger
      • Linked In Private Message
  • Automated technologies: As you interact with our website or emails we may automatically collect Techical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs or other similar technologies.  Examples of this include
    • Google Analytics
    • Facebook or Google Tracking ID’s
    • Web statistics provided by our hosting company Hostgator and throught the proprietary Cpanel

 

 

 

4.0    Use of Cookies
4.1. This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

 

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information [ http://www.google.com/privacy.html ].

 

Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

 

5.0   

How We Use Your Personal Data

5.1. We will use the personal data you provide to us in the following circumstances:

 

·       Where we need to complete the contract we are about to enter into or have entered into with you.  An example of this would be that after you make a booking we will email you details of said booking and if there are issues will call or send a text message to keep you alerted.

·       Where it is necessary for our legitimate interests (or those of a third party) and, if you are based in the European Union, your interest and fundamental rights do not override those interests.

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

5.2. Purposes For Which We Will Use Your Personal Data

Set out below in a table format is a description of the ways we plan to use your personal data, and which of the legal basis we rely on to do so.  We have also idenfified 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.

 

Purpose/Activity Type of Data The lawful basis for processing including the basis of legitimate interest
Registration as a new customer during booking process (a)   Identity

(b)   Contact

Performance of agreed contract with you of provision of entertainment service.
To manage our relationship with you which will include notifying you about any changes to our terms or privacy policy (a)   Identity

(b)   Contact

(c)   Profile

(d)   Marketing and Communications

a)     Performance of a contract with you

b)     Necessary to comply with legal obligation

c)     Necessary for legitimate interests to keep our records updated

d)     Consent – ongoing from May 24th onwards explicit consent will be requested where we request Identity and Contact information and becomes possible due to upgrades to services we use in line with GPDR legislation.

To deliver relevant informational and promotional messages to you and measure/understand the effectiveness of such messages and to find out more about what customers want. (a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(f)    Technical

Necessary for our legitimate interests (to inform our customers, to improve our offerings and to grow our business and inform our marketing strategy).
Consent – ongoing from May 24th onwards explicit consent will be requested where we request Identity and Contact information and becomes possible due to upgrades to services we use in line with GPDR legislation.
To use data analytics to improve our website, services, marketing, customer relationship and experiences a)     Technical

b)     Usage

Necessary for our legitimate interests (to define who are customers are, where they are coming from, how they are finding us and to develop our business and inform our marketing strategy)
To gather feedback on our services a)     Identity

b)     Contact

Necessary for our legitimate interests (to ensure we are delivering a good experience and respond appropriately to negative comments).  To bring about new experiences that will delight our customers.
5.3. Marketing

We strive to provide you with choices regarding certain personal data uses particularly in marketing and advertising.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you will find of interest to you.  We believe we are doing you a disservice if you enjoy your experience with us by not also telling you about new offerings that you can enjoy, special offers and promotions or useful related information.

You will receive occasional marketing communication from us if you have filled in an opt in form, purchased services from us, requested information from us or requested for us to send you group photo and, in each case, you have not opted out of receiving that marketing.

 

Opting Out

You can ask us to stop sending you marketing messages at any time by clicking the “unsubscribe” link at the bottom of any email.

 

When you out out of receiving these marketing messages, this will not apply to personal or profile data provided to us because of a service purchase unless you explicitly request that this happens.  We store customer data in our booking system to allow you to easily rebook at any time.  No credit card or payment information is stored within our booking system.

 

Transfer of Data

We  may from time to time have a requirement to transfer your data between providers say for example we change to a new booking software or email provider then information would be transferred across safely and securely.
Alternatively, we may seek to acquire other busiensses, merge parts of our business or sell to new owners.  If a change were to happen to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

 

6.0   

Contact & Communication

6.1. Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.

 

This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.

7.0   

External Links

7.1. Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites, similar to; www.websitename.co.uk.)

 

The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

 

8.0   

Adverts and Sponsored Links

8.1. This website may contain sponsored links and adverts. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.

 

Clicking on any such adverts will send you to the advertisers website through a referral program which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computers hard drive. Users should therefore note they click on sponsored external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

 

 

 

9.0   

Email Newsletter

9.1. This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.

Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and

Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website’s email newsletter program.

 

Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list].

This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

 

In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.

 

10.0         

Data Security

10.1. This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.

Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and

Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website’s email newsletter program.

 

Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list].

This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

 

In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.

 

 

11.0         

Accessing, Correcting and Deleting Your Information

11.1. EU Residents: Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your person data.  Please click on the links below to find out more about those legal rights:

·        Request access to your personal data

·        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 your personal data

·        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

·        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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 the processing of your personal data

·        Object to the 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 situation which 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

·        Request restriction of processing your personal data

·        Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

·        Request transfer of your personal data

·        Request the transfer of your personal data to you or a third party. We will provide 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.

·        Right to withdraw consent

·        Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide specific products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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

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

 

 

 

 

 

12.0         

Social Media Platforms

12.1. Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

 

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

 

Shortened Links in Social Media

This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo).

 

Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

 

13.0         

Glossary

13.1. EU Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and most secure experience to keep you informed and engaged without being a nuisance or unwelcome. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

 

 

14.0          Resources & Further Information
14.1. •          Data Protection Act 1998

·        The General Data Protection Regulation(GDPR) (EU) 2016/679

•          Privacy and Electronic Communications Regulations 2003

•          Privacy and Electronic Communications Regulations 2003 – The Guide

•          Twitter Privacy Policy

•          Facebook Privacy Policy

•          Google Privacy Policy

•          Linkedin Privacy Policy

•          Mailchimp Privacy Policy

•          Web Design Wales

•          Website Privacy Policy

•          Project Planner Template

 

15.0          Edited & customised by: Cowen Edutainment Ltd, Trading as Clue HQ Brentwood, 104 Piggotts Way, Bishops Stortford, Herts, CM233QU