Privacy Policy - KERB Events

Our Privacy Policy

Introduction

Welcome to KERB Events Limited’s privacy policy.

KERB Events Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data if you book an event through us, trade with us via KERB+, or visit our website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Please note that where you represent a business and that business has a relationship with KERB (for example, the business is a client of KERB or a member of KERB+), this privacy policy applies to you to the extent that we collect any personal data relating to you pursuant to our relationship with the business that you represent.

Important Information and Who We Are
The Data We Collect About You
How Is Your Personal Data Collected
How We Use Your Personal Data
Disclosures of Your Personal Data
International Transfer
Data Security
Data Retention
Your Legal Rights
Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how KERB Events Limited collects and processes your personal data, including when you book an event through us, trade with us via KERB+, or use our website.

Our website and services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller

KERB Events Limited is the controller and responsible for your personal data (collectively referred to as KERB, we, us or our in this privacy policy).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the Data Privacy Manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: KERB Events Limited. We are registered in England and Wales under number 12794353, and we have our registered office at Clere House, 3 Chapel Place, London, England, EC2A 3DQ.

Name or title of Data Privacy Manager: Hannah Robson

Email address: hannah [@] kerbevents.com

Postal address: FAO Data Privacy Manager, KERB Events Limited, 1st Floor 4 Tabernacle Street, London, England, EC2A 4LU

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Data protection law requires KERB Events Limited, as controller for your data:

to process your data in a lawful, fair and transparent way;
to only collect your data for explicit and legitimate purposes;
to only collect data that is relevant, and limited to the purpose(s) we have told you about;
to ensure that your data is accurate and up to date;
to ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
to ensure that appropriate security measures are used to protect your data.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 14.09.23 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us in the meantime. Please inform the Data Privacy Manager of any changes to your data at the following email address: hannah [@] kerbevents.com

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We and other organisations within KERB Group Limited (including but not limited to KERB Ventures, Seven Dials Market, KERB Events and KERB+) have a social media presence for the purpose of engaging with you.

If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy policy of every website of forum that you visit or use.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name and last name.
Contact Data includes billing address, postal address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us or goods or services we have purchased from you.
Technical Data includes internet protocol (IP) address, your login data, 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 access our website.
Usage Data includes information about how you use our website or services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Member Data includes information relating to your membership with KERB+, including details of your independent food business, feedback from clients relating to you, copies of documentation relating to health and safety and insurance and information relating to your residency with KERB Ventures.

We refer to the above categories of data in the ‘Purposes for which we will use your personal data’ tables which can be found here.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not typically collect any Special Categories of Personal Data about you (this includes details about your 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 offences. However, please note the following:

Where you are booking an event with us, you may provide us with information relating to the dietary or accessibility requirements of your guests. This information may be considered to reveal information relating to the religious or philosophical beliefs of your guests, or health information relating to your guests. However, we do not store this information by reference to specific individuals, and ask that you do not provide us with the names or other personal information of such individuals.
Similarly, if you are a KERB+ member, information relating to your independent food business may be considered to reveal information relating to your ethnicity, religious or philosophical beliefs or health (for example, if your business specialises in food for individuals with a specific dietary requirement or food associated with a particular ethnicity). However, again, we do not store this information by reference to you specifically, save where this information is manifestly made public by you in connection with your business (this may be the case for example where you consider that your personal information is particularly relevant in connection with the marketing of your business and ask us to include this in promotional material, such as on our website as part of your story).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or engage you to supply services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

Direct interactions. You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- engage us to supply catering for your event;
- subscribe to our newsletter;
- give us some feedback or contact us.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Member Data from KERB+ (a not for profit organisation within the KERB group that manages KERB membership);
Technical Data from the following parties:

- - analytics providers [such as Google based outside the UK];
  - advertising networks [such as Meta, Facebook Pixel, Google, YouTube and others based [inside OR outside] the UK]; and
  - search information providers [such as Google, SemRush and others based [inside OR outside] the UK].

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Different tables apply depending on whether you are a client/prospective client, member of KERB+, supplier, or website user. Please review the table that is relevant to you. Please note that if multiple tables may apply (for example, if you are a client of KERB and also a user of our website).

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the tables below.

Clients/Prospective Clients
Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Third party processing and international transfer information
To handle your enquiry, including liaising with you to understand your requirements	Identity Contact Marketing and Communications	Performance of a contract with you (taking steps to enter into a contract with you)
To register you as a new client	Identity Contact	Performance of a contract with you
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)
To send you our newsletter and other marketing communications [where you have provided your express consent to this] OR [where you have purchased services from us before and have not opted out of receiving communications]	Contact Marketing and Communications	[Consent] OR [Necessary for our legitimate interests (to send marketing communications to our existing clients who may be interested in purchasing services from us in future)]

Members of KERB+ (Although your direct relationship is with KERB+, we may collect personal data from you where your independent food business caters an event for KERB Events Limited)
Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Third party processing and international transfer information
To engage you to cater an event for us or one of our clients, including making payment to you	Identity Contact Financial Transaction Member	Performance of a contract with you (taking steps to enter into a contract with you)
To receive feedback from our clients and event attendees relating to your independent food business	Member	Necessary for our legitimate interests (to assess and understand member performance in order to ensure we meet the needs of our clients and provide the best possible service)
To consider and assess the suitability of your independent food business for a residency with KERB Ventures and liaise with you about this	Identity Contact Member	Necessary for our legitimate interests (to select appropriate independent food businesses for residencies with KERB Ventures)

Suppliers

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Third party processing and international transfer information

To engage you to supply goods or services to us (including where we do so on behalf of our clients), including making payment to you

Identity

Contact

Financial

Transaction

Performance of a contract with you

Website Users
Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Third party processing and international transfer information
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how users use our website, to develop it, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, client relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of clients for our business, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you our newsletter and other marketing communications where you have provided your express consent to this by signing up to receive such communications via our website	Contact Marketing and Communications	Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can manage your marketing preferences or opt out of marketing at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have signed up to receive our newsletter and marketing communications, or purchased services from us, and in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of KERB Events Limited for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service you have purchased from us or in relation to your relationship with us as a supplier or KERB+ member.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on request. Please contact us if you require this information.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

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

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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 a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

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 the best and most secure experience. 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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Other companies in the KERB Group Limited. Your personal data may be shared within the KERB Group Limited for example, if you are a member of KERB+, your personal data may be shared with KERB Events Limited in connection with the actual or proposed engagement of your independent food business at an event. Further, your personal data may be shared with KERB Ventures in connection with an actual or potential residency with KERB Ventures.
Third party providers of payment services including SumUp Payments Limited.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

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 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. 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 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 particular 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 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 the transfer of your personal data to you or to a third party. We will provide to 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.

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 certain services to you. We will advise you if this is the case at the time you withdraw your consent.