Owner and Data Controller
Robin Kay
Barts London Trading Ltd
Chelsea Cloisters, 87 Sloane Avenue, London, SW3 3DW
We value your privacy at Inception Group, and we are committed to making it as easy and transparent for you to manage and understand how we use your data. In line with GDPR regulations concerning data protection, Inception Group’s privacy policy below outlines how we collect, store and process your data. It also describes the choices available to you regarding our use of your personal information, and how you can access and update this information. If you have any questions, comments or complaints, or if you would like to request copies of your data, delete or opt out of all data services, please contact: privacy@inception-group.com
Full details are found below but in brief:
What we collect:
Name
Email address
Phone number
Visit and purchase history
Website data
How we collect information about you
The information you provide when contacting us via email, phone or through our website
The information you provide when using third party suppliers to make a reservation
The information you provide when contacting us through social media
Information collected through use of our website
We use your information to:
Carry out our obligations arising from any contract or agreement made between you and us
To improve and personalise your guest experience
Keep you informed of events and experiences we think you may be interested in
Administer our site and for internal operations such as troubleshooting, data analysis and to keep our site safe and secure
For security purposes
Where our processing is based on legitimate interests as described above these legitimate interests are to make sure you receive updated information on Inception group's business activities. Where you have previously used our services or expressed an interest in us we consider you have a legitimate interest in our business.
Sharing your information.
We will never share or sell your information with a third party.
Marketing
Where you are one of our clients, or have agreed to be contacted for marketing purposes we may use your details to contact you from time to time concerning events and promotions from Inception Group. You can unsubscribe at any time and details of how to unsubscribe will be included in each electronic mail we send you.
You also have the option of unsubscribing at anytime thereby disabling any such further communication by emailing your request to privacy@inception-group.com
Your rights
At anytime you have the right to:
To request access to or a copy of any data we hold about you
To ask us to delete your personal data
To withdraw consent to our processing of your personal data
To ask us to start or stop sending you marketing messages
To restrict processing of your personal data
Any request must be made in writing to privacy@inception-group.com and we will respond within one month in line with the relevant legislation
Owner contact email: privacy@inception-group.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Cookies; Usage Data; first name; last name; date of birth; email address; phone number.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Remarketing and behavioral targeting, Contacting the User, Managing contacts and sending messages, Displaying content from external platforms, SPAM protection, Interaction with external social networks and platforms, Handling payments and Managing support and contact requests.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Wordpress Stats (Automattic Inc.)
Wordpress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
-
Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: date of birth; email address; first name; last name.
Phone contact (this Website)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.
Personal Data processed: phone number.
-
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
-
Handling payments
Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
-
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
-
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
-
Managing support and contact requests
This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Freshdesk (Freshworks, Inc.)
Freshdesk is a support and contact request management service provided by Freshworks, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
-
Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
-
SPAM protection
This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI (Japan)
or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
-
SevenRooms
This type of service allows this website to secure the desired reservations. Additionally, if the user has given permission to Inception Group to send emails to that user's address, Inception Group may then contact the client with special announcements or offers. If permission is not given, the user's email address will not be passed on to Inception Group.
As a SevenRooms provider, Inception Group want to provide you with the best possible service so that you will visit them again. Inception Group may use its SevenRooms System to take note of your special requests, allergies, special occasions or other pertinent information that will help them serve you better during your next visit. If Inception Group chooses to note your preferences, that information may be typed into its SevenRooms System manually just as a provider might write a note on an index card. This data belongs to Inception Group, since it is a product of their relationship with you. SevenRooms does not access or use this information, and it is not shared with any other SevenRooms provider or third party, other than, perhaps, a provider under the same ownership. SevenRooms does create backup copies of all information stored on the SevenRooms System for Inception Group, to assist in the restoration process in the event of data loss.
SevenRooms will never sell, rent, loan or otherwise distribute any of your personal information (including but not limited to your name, email address, phone number or any other identifiable information about you) to any third party without your prior expressed written consent, although SevenRooms will pass certain information on to Inception Group.
SevenRooms does use aggregate data (based partly on IP addresses of website visitors) collected through its website to analyse website usability, system performance and usage trends. While this data, in its aggregate form only, may be shared with third parties with whom SevenRooms works to analyse it, the data will only be shared under the strictest terms of confidentiality and will never contain any personally identifiable information pertaining to any user of the SevenRooms Website.
Notwithstanding anything to the contrary in this privacy policy, SevenRooms may be required to disclose user and personal information in response to inquiries by formal law enforcement, or in cases permitted by the United State's CAN-SPAM Act of 2003 (CAN-SPAM), the European Union's Safe Harbor Provisions ("Safe Harbor"), Japan's Personal Information Protection Act ("PIPA"), or other related privacy laws and regulations.
Upon making a booking, if a User chooses to provide the mandatory booking information via Facebook, Twitter or Linkedin login, the following data will be processed to secure the booking: Name, Surname, Email Address, Phone Number and Date of Birth.
-
Managing contacts and sending messages
Propeller Communications LTD ("Propeller")
Propeller provides an email service, automation and marketing platform.
Personal Data collected: email address, first name, surname, phone number, date of birth and booking information and purchase history.
Place of processing: UK - Privacy Policy.
-
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Website, if not stated otherwise within this document.