Introduction

The Sloane Club (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with us and use our services (“Services”). It also informs you about your privacy rights under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), and how the law protects you.

We will post any modifications or changes to this Privacy Policy on our website: https://www.thesloaneclub.com/

Who we are and how to contact us

Who We Are:

We are The Sloane Club, a private members’ club located in London, UK.

Address: 52 Lower Sloane Street, London, SW1W 8BP, United Kingdom.

How to Contact Us:

Email: dataprotection@sloaneclub.co.uk

Your rights relating to your personal data

Under data protection laws, you have rights regarding your personal data, including:

Access: Request access to the personal data we hold about you.

Correction: Request correction of inaccurate or incomplete data.

Erasure: Request deletion of your personal data where there is no lawful basis for us to continue processing it.

Objection: Object to processing of your data where we rely on legitimate interests.

Restriction: Request restriction of processing under certain circumstances.

Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit it to another controller.

Withdraw Consent: Withdraw consent at any time where we are relying on consent to process your personal data.

How to Exercise Your Rights:

Contact us using the details provided in Section 2. We may need to request specific information from you to help us confirm your identity.

Complaints and regulatory contact

If you have any concerns about our use of your personal data, you can make a complaint to us at dataprotection@sloaneclub.co.uk

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues:

Website: www.ico.org.uk

Phone: +44 0303 123 1113

Marketing communications preferences

You can opt out of marketing communications at any time by:

1. Checking or unchecking relevant boxes on our membership application forms.

2. Updating your personal preferences in your membership account

3. Contacting us at membership@sloaneclub.co.uk

Please note that opting out of marketing communications does not affect transactional communications related to your membership or services you have requested. Where a communication is deemed essential to your membership, it will be sent regardless of your preferences.

What personal data we collect

We may collect, use, store, and transfer different kinds of personal data about you, including:

Identity Data: First name, last name, marital status, title, date of birth, gender, proof of address, photographic identification (including passport or driving licence for membership verification) and social media handles (where relevant).

Contact Data: Home address, mailing address, email address, and telephone numbers.

Financial Data: Payment card details, billing address (Note: We do not store full financial data; it is passed securely to our third-party payment processors).

Transaction Data: Details about payments to and from you, reservations, events booked, events attended, and other services you have purchased from us.

Technical Data: IP address, login data, browser type and version, time zone setting and location, operating system, and platform.

Profile Data: Membership ID, username and password, preferences, feedback, and survey responses.

Usage Data: Information about how you use our website, mobile application, and services as well as your usage of our facilities including frequency of visits.

Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

CCTV Footage: Images captured by our security cameras within and around the club premises for safety and security purposes.

Allergy and Dietary Data: Information about food allergies, intolerances, and dietary preferences.

Health Data: We may collect both personal data and special categories of personal data (e.g. health data) from you in order to perform services relating to our Wellness facility. Any personal data collected from you will be used strictly in relation to your appointment and will not be shared other than as set out in this Privacy Policy.

Aggregated Data:

We also collect aggregated data such as statistical or demographic data for any purpose. This data does not directly identify you.

How we use your personal data

We will only use your personal data when the law allows us to. Common uses include:

Membership Applications and Management:

– Processing membership applications and renewals.

– Verifying identity and eligibility for membership.

– Managing member accounts, including billing and payments.

Service Provision:

    • Facilitating reservations, event bookings, and guest lists.
    • Providing food and beverage services, including accommodating dietary requirements.
    • Providing wellness related services.
    • Managing access to Club facilities and Member-only areas.
  • Marketing and Promotions:
    • Sending newsletters, event invitations, and promotional offers.
    • Personalising marketing communications based on your preferences.
  • Improvement of Services:
    • Analysing usage data to improve our services and member experience.
    • Conducting surveys and seeking feedback.
  • Security and Safety:
    • Using CCTV footage to ensure the safety of members, guests, and staff.
    • Monitoring premises to prevent and detect crime.
    • Managing access to Club facilities and Member-only areas.
  • Legal Obligations:
    • Complying with legal and regulatory requirements, such as HMRC regulations.
    • Responding to requests from law enforcement authorities.

Legal bases for processing

We rely on the following legal bases to process your personal data:

Performance of a Contract:

• Processing necessary for the performance of a membership agreement or to take steps at your request before entering into such an agreement.

Legitimate Interests:

• Ensuring the security of our premises and services.

• Improving our services and enhancing member experience.

• Promoting our services and events.

• Managing business operations and IT infrastructure.

Compliance with Legal Obligations:

• Fulfilling our legal duties under UK laws and regulations.

Consent:

• Sending direct marketing communications where we have obtained your explicit consent.

• Processing special categories of data (e.g., allergy information) with your consent.

What happens if you do not provide necessary personal data

Where we need to collect personal data by law or under the terms of a contract, and you fail to provide that data when requested, we may not be able to perform the contract (e.g. provide membership benefits or services). In such cases, we may have to cancel your membership or a service you have with us, but we will notify you if this is the case.

Personal data from third-party sources

We may receive personal data about you from third parties, including:

• Referrals: Information from existing members who refer you.

• Public Databases: Verification services to confirm identity and eligibility.

• Payment Processors: Transaction details from payment providers.

• Analytics Providers: Usage data from analytics services like Google Analytics.

Cookies and other tracking technologies

We use cookies on our website to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Please state your consent ID and date when you contact us regarding your consent.

Necessary cookies

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Preference cookies

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Statistics cookies

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Marketing cookies

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Unclassified cookies

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

Managing Cookies:

You can set your browser to refuse cookies or alert you when cookies are being used. However, disabling cookies may affect the functionality of our website.

Disclosure of your personal data

We may share your personal data with:

Service Providers:

• IT and system administration providers.

• Payment processors (e.g. Adyen, Stripe, GoCardless).

• Reservation and event management platforms.

Marketing Platforms:

• Email marketing services (e.g., MailChimp, PeopleVine).

Professional Advisers:

• Solicitors, bankers, auditors, valuers and insurers providing consultancy and legal services.

Regulatory Authorities:

• HM Revenue & Customs, law enforcement agencies, and other regulators.

Affiliated Clubs:

• Partner clubs for reciprocal membership benefits (with your consent). Your data is only shared with reciprocal clubs when you request to visit them. A full list of reciprocal clubs can be found in the Member Portal under the Reciprocal Clubs tab.

International data transfers

Your personal data may be transferred to and processed in countries outside the UK and the European Economic Area (EEA). We ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs): Legal agreements ensuring data protection.

Adequacy Decisions: Transfers to countries deemed to have adequate data protection laws by the UK government.

When interacting with a Reciprocal Club, your data will be processed under the terms of their Privacy Policy.

Data security measures

We have implemented appropriate security measures to prevent your personal data from being:

• Accidentally lost.

• Used or accessed in an unauthorised way.

• Altered or disclosed without authorisation.

Security Practices:

• Encryption: Data encryption in transit and at rest.

• Access Controls: Restricting access to personal data to authorised personnel.

• Regular Audits: Monitoring systems for vulnerabilities and attacks.

• Staff Training: Ensuring employees understand data protection obligations.

Data retention periods

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

Retention Periods:

• Membership Data: Retained for 7 years after membership termination.

• Transaction Data: Retained for 7 years to comply with financial regulations.

• CCTV Footage: Typically retained for 30 days unless required for an investigation.

• Marketing Data: Retained until you opt out or withdraw consent.

Policy regarding children

You may provide us with identity data relating to children where, for example, they are included in a Family Membership or are guests of yours. In providing us with this identity data, you are agreeing that you hold parental or guardian responsibility for that child or that you have been properly authorised by the holder of parental or guardian responsibility for the child, to give us this identity data to use for these purposes. We do not knowingly collect data relating to children without parental or guardian consent.

Third-party links

Our website and communications 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 your data. We are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

CCTV and security

We operate CCTV systems within and around our premises for the safety and security of our members, guests, and staff.

Purpose: To prevent and detect crime, ensure safety, and manage the club effectively.

Data Storage: CCTV footage is securely stored and accessed only by authorised personnel.

Retention Period: Footage is retained for 30 days unless required for an investigation.

Changes to this privacy policy

We keep our Privacy Policy under regular review. Any updates will be posted on this page, and significant changes may be communicated directly to you via email or through our member communications.