This Privacy Notice (“Notice”) describes how Boca Bar Group collects and uses your Personal Data in accordance with the EU General Data Protection Regulation (“GDPR”). It tells you what Personal Data Boca Bar Group collects, why we need it, how we use it and what protections are in place to keep it secure.
“Boca Bar Group” “we” “us” and “our” mean Boca Bar Group Ltd of 17 Victoria Road East, Thornton Cleveleys, Lancashire, United Kingdom, FY5 5HT (registered company number 11801182).
“Boca Bar Group Personnel” means Boca Bar Group’s employees, consultants and agency staff, and people connected to such persons.
“Personal Data” means information about you and from which you could be identified.
Boca Bar Group is the Data Controller in relation to your Personal Data and is committed to protecting your privacy rights.
4.1 Boca Bar Group is not required under the GDPR to appoint a Data Protection Officer and, following a detailed analysis does not consider it appropriate to do so on a voluntary basis. Boca Bar Group has, however, appointed a Data Protection Manager, (“DPM”) who is responsible for overseeing Boca Bar Group’s compliance with the GDPR and any other applicable data protection legislation and regulation.
4.2 The DPM can be contacted at marketing@bocabargroup.co.uk or at the correspondence address for Boca Bar Group set out above.
In some circumstances, we may obtain your Personal Data from you directly including through our website or the services that we provide to you. It may also be the case that we obtain your Personal Data from a third-party source, for example, via social media. In most circumstances, you directly provide Boca Bar Group with most of the data we collect. We collect data and process data when you:
If you provide information to us about someone else you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may process that information in accordance with this Notice.
We may collect and use different types of Personal Data about you, which will vary in type and detail depending on the circumstances and purpose of processing. Please consider the following illustrative and non-exhaustive examples:
We may need to collect and use your Personal Data for a number of reasons, the primary purpose being to provide services to you which may involve the use of your Personal Data. We may also process your Personal Data for effective business management purposes.
Under the GDPR, Boca Bar Group must identify a lawful basis for processing your Personal Data which may vary according to the type of Personal Data processed and the individual to whom it relates.
– Performance of a contract with you:
Boca Bar Group is entitled to process the Personal Data it requires in order to fulfil its obligations under a contract with you.
– When you provide consent:
When you have given clear consent for us to process your personal data for a specific purpose, for example when you sign up to our mailing list or make an enquiry about our services.
– Legitimate interests of Boca Bar Group or a third-party:
Boca Bar Group processes some of your Personal Data on the basis that it is in its legitimate interests and/or the legitimate interests of a third-party to do so. Boca Bar Group’s legitimate business interest in such instances include improving the services we offer, fraud prevention and network/IT security.
We may use your contact details to send you marketing materials, provided we are permitted to do so by law. You always have the right to unsubscribe from any marketing. You can do so by clicking on the relevant link in the next email we send you, or by contacting us/the DPM directly using the details provided.
We may disclose your Personal Data to third-parties (outside of Boca Bar Group and Boca Bar Group Personnel) if, but only when, we have a legal basis to do so or if we need to do so to perform services under a contract with you.
We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that any Personal Data we hold is not accessed by anyone without proper authorisation and only for a legal basis described above.
When we use third-party organisations to process your Personal Data on our behalf, they must also have appropriate security arrangements, must comply with our contractual requirements and instructions, and must ensure compliance with the GDPR and any other relevant data protection legislation.
13.1 The GDPR generally affords individuals a right to access their Personal Data, to object to the processing of their Personal Data, to rectify, to erase, to restrict and to port their Personal Data.
13.2 We will, at all times, respect your Personal Data and seek to be as transparent as possible but please be aware that, in some instances, we may be restricted from even acknowledging that we process your Personal Data.
If you are unhappy with the information provided in this Notice or have concerns about the way in which Boca Bar Group processes your Personal Data you may in the first instance contact us at marketing@bocabargroup.co.uk or at the correspondence address for Boca Bar Group set out above. If you remain dissatisfied, then you may apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk
