PRIVACY POLICY

Last updated 13 November 2017

1. WHO ARE WE?

This website, the Nightkey Dashboard and our mobile application are operated by Nightkey Limited, a company registered in England and Wales under registration number 09270559 with registered address at 10 Northcliffe Drive, London, N20 8JZ (“Nightkey”, “we”, “us” and “our” being interpreted accordingly).

2. WHAT IS THIS PRIVACY POLICY IS FOR?

This Privacy Policy gives you information about how we will use personal data and other private information that we collect from you as a user of this website, a user of the Nightkey Dashboard, a user of our mobile application or generally as a membership applicant, member or customer (“you” or “your” being interpreted accordingly).

When we refer to ‘personal data’ in this Policy it means any information that relates to you from which you can be identified.

By using our website, the Nightkey Dashboard or mobile application or submitting your personal data you are taken to accept the terms of this Policy, so please read it carefully.

3. WHAT PERSONAL DATA MAY WE COLLECT?

We may collect the following personal data about you:

· personal details you provide (such as your name, date of birth, e-mail address, employer and phone number) when applying or registering as a member or updating your membership profile;

· information about your debit/credit card and bank account information that we may require for the purpose of administering your membership. For further details please also refer to section 7 (Payment Information) below;

· personal details you choose to give when corresponding with us by phone, e-mail or that you provide to us when you visit one of our partner venues or attend one of our member events; and

· other personal or private information about you that you choose to submit to this website, the Nightkey Dashboard or our mobile application.

4. COOKIES

Each of our mobile application, the Nightkey Dashboard and this website uses cookies to distinguish you from other users. This is to provide you with a good user experience when you browse our website or use our mobile application or the Nightkey Dashboard and allows us to improve their features. For detailed information on the cookies we use, please see our Cookie Policy.

5. HOW WE USE YOUR DATA

We may use your personal data in the following ways:

· to acknowledge, confirm and deal with your membership application or registration (and where necessary put you on our waiting list);

· where we are asked to deal with any enquiries or complaints you make;

· where you are a member, to provide you with membership services and administer your membership account;

· only if you have previously consented to this, to provide you, or permit selected third party service providers to provide you, with information about goods or services we feel may interest you as a member or membership applicant. If you are a member, we will only contact you by electronic means (such as e-mail or SMS) with information about goods and services that are similar to those which you previously used through Nightkey. If you are a membership applicant, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only;

· to contact you in connection with user/customer/member surveys and use any information you choose to submit in response;

· to administer our website, mobile application and the Nightkey Dashboard and ensure that they are presented in the most effective manner for you and for your computer or device.

· for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our website, mobile application and the Nightkey Dashboard secure;

· to combine your personal data with other information we collect about you for the purposes set out in this Privacy Policy; and/or

· for other purposes which you have consented to.

6. DISCLOSURE OF YOUR INFORMATION

We may share your personal data with third parties in the following situations:

· making personal data available to selected third parties who act on our behalf to support our operations (for example, card processing or payment services (see section 7 (Payment Information) below) or restaurants, bars or other offer partners to facilitate bookings or services that you may wish to make or use via our services, and credit reference agencies to protect against possible fraud;

· making personal data available to our IT suppliers and contractors (e.g. data hosting providers or delivery partners) when they may need to have access to your personal information to provide IT support or enable us to provide membership services and other goods/services available to members on this website, the Nightkey Dashboard or through our mobile application;

· if we sell our business or our company assets are acquired by a third party, in which case personal data held by us about our members or customers may be one of the transferred assets;

· if we need to disclose your personal data to comply with a legal obligation or to enforce our Member Terms and Conditions, Partner Terms and Conditions, membership rules or other applicable contract terms that you are subject to; and/or

· to protect us, our members, partners or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts, law enforcement organisations or otherwise as required by law.

7. PAYMENT INFORMATION

Any credit/debit card payments and other payments you make through this website or our mobile application will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers in accordance with current industry standards at the time of processing.

We may arrange card or payment data you submit in support of a subscription to be stored for the purpose of processing and collecting any membership or other fees due. If you are put on the membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription.

We or our third party payment providers may also store and use your card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted. For details about the manner in which third party payment providers store your information, please contact us in accordance with section 11 (Contact) below.

You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details to pay for any membership or other fees due or for the purpose of making any future purchases. Please note that your membership benefits may be adversely affected or delayed if you do not re-supply us with your card/payment details promptly when instructed in the event you choose to opt out of us holding your card or payment data.

8. SECURITY

Your personal data may be transferred to and stored at a destination outside the European Economic Area (the “EEA”) such as by our subcontractors in the United States (the “US”) who process your payment details and/or provide IT support services. In accordance with applicable law, we will make all reasonable efforts to ensure that our subcontractors comply with appropriate and applicable security standards required to protect the personal data that they handle.

Please note that the US and certain other countries outside the EEA do not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. By submitting your personal data to us, you agree to the transfer and processing of your personal data outside the EEA for the purposes set out in this Privacy Policy.

Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our website, mobile application or the Nightkey Dashboard, you are responsible for doing everything you reasonably can to keep these details secret. We will not share your password or log-in details with third parties except when it is absolutely necessary and as required under section 6 (Disclosure of your information).

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect your personal data against unauthorised/unlawful access or loss, destruction or damage, but we cannot 100% guarantee the security of data that you provide to us online.

9. YOUR DATA PROTECTION RIGHTS

Certain applicable data protection laws give you a right to receive information about the personal data we hold on you. You may also have the right to ask us not to process your personal data for marketing purposes or where the processing of your personal data is causing unwarranted damage or distress. You may also have the right to ask us to delete or correct any personal data that we hold about you which is inaccurate or no longer relevant.

If you wish to exercise any of these rights please contact us as described in section 11 (Contact) below. Any access request may be subject to a small fee to meet our costs in complying with your request. We may also need to ask you for further information to verify your identity before we can respond to any request.

10. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page.

This policy replaces all previous versions and is correct as of November 2017. We reserve the right to change the policy at any time. Please check back frequently to see any updates or modifications.

11. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to info@nightkey.co.uk or by post to our address listed above and marked as for the attention of the ‘Privacy Officer’.

COOKIE POLICY

1. WHO ARE WE?

This website, the Nightkey Dashboard and our mobile application each uses cookies, pixels or similar tracking technologies (“Cookies”) to distinguish you from other users, providing you with the best possible user experience when you browse our website or use the Nightkey Dashboard or our mobile application. Cookies also allow us to improve the features on our website, the Nightkey Dashboard and our mobile application.

This Cookie Policy describes the Cookies we may use on this website, the Nightkey Dashboard or on our mobile application as well as the purpose of the Cookies. You should also check our Privacy Policy regarding how we use your personal data when you use our website.

BY USING OUR WEBSITE, THE NIGHTKEY DASHBOARD OR OUR MOBILE APPLICATION, YOU CONSENT TO US USING COOKIES AS DESCRIBED IN THIS POLICY.

3. WHAT ARE COOKIES?

Cookies are small pieces of data that are stored on your computer or other device when you access a website or mobile application. Pixels, also known as web beacons or web bugs, are small blocks of code on webpages and in emails that do things like allow another computer server to measure viewing of a webpage. These are often used in conjunction with Cookies. Cookies enable our computer servers to collect information from your computer or device about how you interact with our website, the Nightkey Dashboard or mobile application. You can find more background information about cookies at: www.allaboutcookies.org.

4. HOW WE USE COOKIES

We use Cookies to help us better understand how our website, the Nightkey Dashboard and our mobile application are used and to provide you with a more user-friendly experience when you access our online services. For example, using information about your previous visits to our website, the Nightkey Dashboard and our mobile application, we can tailor content to match your particular interests when you revisit our website, the Nightkey Dashboard or our mobile application or use any services on them.

Cookies will never be used by us to collect your sensitive personal data or financial details, such as credit card information. You can disable Cookies by adjusting the settings on your web browser (e.g. Internet Explorer, Safari, Chrome or Firefox) although this may affect your ability to fully utilise our website, the Nightkey Dashboard or our mobile application.

We may also use Cookies for the following purposes:

· Authentication: to recognise you if you are signed in to our website, the Nightkey Dashboard or our mobile application;

· Security: We may use Cookies to enable security features on our website, the Nightkey Dashboard or our mobile application and help us detect any security threats or potential illegal activity;

· Performance: Some Cookies may collect information about user visits to our website, the Nightkey Dashboard or mobile application, for example which web pages or links visitors use most often. We might also use these performance Cookies to highlight services which we think will be of interest to you based on your previous use of our website, the Nightkey Dashboard or mobile application. To help us monitor visitor traffic to our website, the Nightkey Dashboard and our mobile application and understand how our website, the Nightkey Dashboard and our mobile application are used, we have enabled third party software tools (including ‘Google Analytics’) to collect data about our website traffic. Visitors have the ability to opt out of Google Analytics and other third party software tool features we use. For further information about the software tools we use, please contact us in accordance with section 7 (Contact) below. Performance cookies like these do not routinely collect information that personally identifies a visitor by name so the impact on your personal privacy should be minimal; and/or

· Functionality: Some Cookies allow our website, the Nightkey Dashboard or mobile application to remember information from your previous visits, such as contact details you previously submitted. For example, when you complete an online form (such as when you register for a service) we will use a cookie which (if you agree) will help remember your details if you use the same computer or device to complete another form on our website, the Nightkey Dashboard or mobile application without you having to re-enter them. These Cookies may also be used to provide information you request such as publications or newsletters.

5. STRICTLY NECESSARY COOKIES

Some Cookies are essential in order to enable you to navigate our website, the Nightkey Dashboard or mobile application or to enable you to receive a particular service you have requested. Such Cookies are regarded as ‘strictly necessary’ and we do not need to ask your permission to use them.

6. THIRD PARTY COOKIES

Our website, the Nightkey Dashboard or our mobile application may also allow third parties to download Cookies to your computer or device. For example, if you choose to ‘share’ content from our website, the Nightkey Dashboard or our mobile application with friends through a third party site such as Facebook or another social network, you may be sent Cookies from these third party service providers over which we have no control. If you choose to share such content, you should check the relevant third party services provider’s terms/policies for more information about cookies that they use.

7. CONTACT