PRIVACY POLICY
Last updated: September 2026
INTRODUCTION
Propella Group Ltd and its subsidiaries (“Propella”, “we”, “us” or “our”) respect your privacy and are committed to protecting your personal data.
This Privacy Policy explains how we collect, use and protect your personal data when you interact with us, including when you visit our websites or venues, make a reservation, purchase goods or services, enquire about an event or private hire, use guest Wi-Fi at one of our venues, sign up to receive marketing, enter a competition or promotion, or otherwise communicate with us.
It also explains your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
Propella Group comprises Propella Group Ltd and its subsidiary companies. When we refer to “Propella”, “we”, “us” or “our” in this Privacy Policy, we mean the Propella Group company responsible for processing your personal data in connection with the relevant business, venue, website, product or service. Depending on how you interact with us, this may be Propella Group Ltd, one of its subsidiaries, or more than one Propella Group company.
Propella Group Ltd oversees data protection matters across the Group. If you have any questions about this Privacy Policy, the way in which we use your personal data, or wish to exercise any of your legal rights, you can contact us at compliance@propellagroup.com or by writing to Data Protection, Propella Group, 112 Marine Parade, Brighton, BN2 1AT.
You have the right to make a complaint to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection. We would appreciate the opportunity to address any concerns before you approach the ICO, although you are not required to contact us first.
It is important that the personal data we hold about you is accurate and current. Please tell us if your personal information changes during your relationship with us.
Our websites and digital services may contain links to third-party websites, applications or services. We do not control those third parties and are not responsible for their privacy practices. We recommend that you read their privacy information before providing personal data to them.
We may update this Privacy Policy from time to time. The date at the top of this policy shows when it was last updated.
2. THE DATA WE COLLECT ABOUT YOU
Personal data means information about an individual from which that person can be identified, directly or indirectly. It does not include information which has been anonymised so that an individual can no longer be identified.
We may collect, use, store and transfer different kinds of personal data about you. This may include Identity Data, such as your name, title, date of birth or age; Contact Data, such as your email address, telephone number and postal address; Booking and Transaction Data, such as reservations, purchases, event enquiries, payment and transaction information and booking history; Profile Data, such as your preferences, interests, feedback and survey responses; and Marketing and Communications Data, including your preferences about receiving communications from us.
We may also collect Technical and Usage Data when you use our websites and digital services. This may include your IP address, browser and device information, operating system, approximate location, pages viewed, dates and times of access and information about how you interact with our websites.
When you connect to guest Wi-Fi at one of our venues, our guest Wi-Fi provider may collect information that you provide when registering for the service, such as your name, email address, telephone number, date of birth or postcode, depending on the registration method and information requested. We may also collect technical and usage information relating to your device and connection, including device identifiers, IP address, device type, the venue and access point used, connection dates and times, session information, visits to our venues and other network or presence information. This information may be used to provide and secure the Wi-Fi service and, where permitted, to help us understand visits to and use of our venues.
We operate CCTV at our venues and premises. CCTV may capture images of customers, visitors and other individuals in and around those premises. Appropriate signage is displayed where CCTV is in operation. CCTV recordings are normally retained for 30 days, although footage may be retained for longer where necessary in connection with an incident, investigation or legal claim.
We do not generally seek to collect special categories of personal data about customers or visitors. However, you may choose to provide information of this kind where it is relevant to a service you require, for example information about an allergy, health requirement, disability or accessibility requirement associated with a booking. Where we process such information, we will only do so where permitted by law.
We may also use aggregated or anonymised information for statistical, analytical and business purposes. Where information has been anonymised so that it can no longer identify an individual, it is not personal data.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data directly from you when you make a reservation or purchase, submit an enquiry, contact us, connect to guest Wi-Fi, subscribe to marketing, enter a competition or promotion, complete a survey or otherwise interact with us.
We also collect some information automatically when you use our websites, Wi-Fi and other digital services. This may be collected through cookies, server logs, Wi-Fi infrastructure and similar technologies.
We may receive information about you from third parties where you interact with us through their services. These may include restaurant and venue booking platforms, ticketing and event providers, payment processors, Wi-Fi providers, social media platforms and other technology providers.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data where the law allows us to do so. Most commonly, this will be where processing is necessary to perform a contract with you, where it is necessary for our legitimate interests and those interests are not overridden by your rights, where we need to comply with a legal obligation, or where you have given us your consent.
We use personal data to provide and manage reservations, purchases, events and other services; respond to enquiries and complaints; process payments and refunds; operate and secure our websites, guest Wi-Fi and other IT systems; protect our customers, employees, visitors and premises; prevent and investigate fraud, crime and misuse of our systems; understand how our venues and services are used; improve our products and customer experience; administer promotions and competitions; comply with our legal and regulatory obligations; and, where permitted, communicate with you about our venues, events, products and services.
When you use guest Wi-Fi, we process registration, connection, technical and presence information to provide the service, maintain the security and performance of our network, troubleshoot technical problems and prevent or investigate misuse. We may also use information about Wi-Fi usage and visits to our venues to understand customer behaviour, measure venue usage and improve our venues, products and services.
CCTV is used for the safety and security of our customers, employees, visitors, premises and property, and for the prevention and detection of crime and investigation of incidents.
The principal purposes for which we process personal data and the lawful bases on which we rely are:
Purpose
Type of Data
Lawful Basis
To operate and protect our websites, systems and business
Identity, Contact, Technical and Usage
Legitimate interests in operating our business, providing IT services, maintaining security and preventing fraud; legal obligation where applicable
To use CCTV to protect people, premises and property
CCTV images and associated information
Legitimate interests in safety, security and the prevention and detection of crime
To understand how our websites, venues and services are used and improve them
Technical, Usage, Profile, Booking and Transaction
Legitimate interests in understanding our customers and developing our business; consent where required
To administer competitions, promotions and surveys
Identity, Contact, Profile
Performance of a contract; legitimate interests
To send marketing communications
Identity, Contact, Profile, Marketing and Communications
Consent or legitimate interests where permitted by law
To comply with legal, regulatory, tax and accounting requirements and deal with legal claims
Relevant personal data
Legal obligation; legitimate interests
We may process personal data for more than one lawful basis depending on the particular purpose and circumstances.
We will only use personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another compatible purpose. If we need to use personal data for an unrelated purpose, we will notify you where required and explain the legal basis which allows us to do so.
5. MARKETING AND COOKIES
We may send you information about our venues, events, products, services, offers and promotions where permitted by law.
Where consent is required, we will ask for it before sending electronic marketing. In some circumstances, we may contact existing customers about our own similar products and services where permitted by law and where you have been given an opportunity to opt out.
Where you have agreed to receive marketing from Propella Group, this may include information about venues, events, products and services operated by companies within the Group. We will make the scope of this clear when your information is collected.
Connecting to guest Wi-Fi does not, by itself, mean that you have agreed to receive marketing from us. If we offer you the opportunity to receive marketing when you register for guest Wi-Fi, this choice will be presented separately.
You can stop receiving marketing communications at any time by using the unsubscribe option provided in the communication or by contacting us. Opting out of marketing will not prevent us from sending communications which are necessary in connection with a booking, purchase or other service you have requested.
Our websites use cookies and similar technologies to operate correctly, maintain security, remember preferences, understand how our websites are used and, where applicable, support analytics and advertising.
Some cookies are necessary for our websites to function and may be used without consent where permitted by law. Where consent is required for cookies or similar technologies, we will ask for it before using them. You can manage your choices through the cookie controls provided on our websites and through your browser settings. Further information about the cookies and similar technologies we use is available in our Cookie Policy.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may share personal data within Propella Group where necessary to operate our businesses, provide central services, administer systems, manage customer relationships and provide products and services.
We also use third-party service providers to support our operations. These may include providers of website hosting and IT services, guest Wi-Fi and network infrastructure, restaurant and venue reservation systems, event and ticketing systems, payment processing, customer relationship management systems, email and marketing services, analytics, communications, cloud storage, CCTV and security services.
We may share information with professional advisers including our accountants, auditors, insurers, bankers and solicitors, and with HM Revenue & Customs, the police, courts, regulators and other public authorities where required or permitted by law.
We may also disclose personal data in connection with a proposed or actual sale, acquisition, investment, merger, restructuring or transfer of all or part of our business or assets.
Where another organisation processes personal data on our behalf, we require it to protect that information, maintain appropriate security and process it only for the purposes for which it has been provided and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
Some of the service providers we use may process personal data outside the United Kingdom.
Where we transfer personal data internationally, we will ensure that the transfer is made in accordance with applicable data protection law and that appropriate safeguards are in place. These may include transferring information to a country recognised by the UK as providing an adequate level of protection or using approved contractual safeguards and any additional protections required by law.
You can contact us if you would like further information about the safeguards applying to international transfers of your personal data.
8. DATA SECURITY AND RETENTION
We have appropriate technical and organisational measures in place to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. We limit access to personal data to employees, contractors and service providers who have a legitimate business need to access it, and those persons are required to handle personal data securely and confidentially.
We maintain procedures for dealing with suspected personal data breaches and will notify affected individuals and the ICO or another relevant regulator where we are legally required to do so.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to meet legal, regulatory, tax, accounting, security and reporting requirements.
The appropriate retention period depends on the nature and sensitivity of the information, the purposes for which it is processed, the potential consequences of unauthorised use or disclosure and any applicable legal or regulatory requirements. Where personal data is no longer required, it will be deleted, securely destroyed or anonymised.
We maintain more detailed retention periods within our internal Data Retention Schedule and further information can be provided on request.
9. YOUR LEGAL RIGHTS
Under UK data protection law, you have a number of rights in relation to your personal data. Depending on the circumstances, these include the right to request access to the personal data we hold about you; request correction of inaccurate or incomplete information; request erasure of your personal data; object to certain processing; request restriction of processing; and request the transfer of certain personal data to you or another organisation.
Where we rely on consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.
You have an absolute right to object to the processing of your personal data for direct marketing purposes.
These rights do not apply in every circumstance and we may be entitled or required to continue processing personal data despite a request. If this applies, we will explain the reason to you.
To exercise any of your rights, please contact us using the details in section 1. We may need to request information from you to confirm your identity and ensure that personal data is not disclosed to somebody who is not entitled to receive it.
You will not normally have to pay a fee to exercise your rights. However, we may charge a reasonable fee or refuse to act where permitted by law, including where a request is manifestly unfounded or excessive.
We will respond to requests within the time limits required by applicable data protection law.
10. CHILDREN
Our general websites and guest Wi-Fi services are not designed specifically for children.
Some Propella Group businesses, venues, events or activities may be attended by children or young people. Where we need to collect personal data relating to a child for a particular service or activity, we will provide appropriate privacy information where necessary and apply suitable safeguards having regard to the age of the child and the nature of the processing.
11. CONTACT AND COMPLAINTS
If you have any questions about this Privacy Policy, wish to exercise your legal rights or have concerns about the way in which we process your personal data, please contact:
Propella Group Ltd
Email: compliance@propellagroup.com
Postal address: Data Protection, Propella Group, 112 Marine Parade, Brighton, BN2 1AT
You also have the right to make a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection