New West End Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

The Controller is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Controller at privacy@newwestend.com. If you would like to update your marketing preferences or unsubscribe from our newsletters, please use the option to manage your preferences at the bottom of our newsletters or contact privacy@newwestend.com with details of your request.

Changes to the privacy policy

This version was last updated on 5 April 2022 and historic versions can be obtained by contacting us by e-mailing privacy@newwestend.com. We may change this policy from time to time by updating this page so please revisit and reread it periodically.

Third-party links

This website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Please note that New West End Company does not warrant, represent, endorse, or hold responsibility over any external sites that may be linked to and from this site.

How your personal data is collected

1. Direct interactions

You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you subscribe to our newsletters and e-mail updates, give us feedback, or ask us a question via info@newwestend.com, insights@newwestend.com, or other e-mail addresses used by New West End Company.

2. 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, pixels, server logs and other similar technologies. Please see our cookie policy for further details.

3. Third parties or publicly available sources.

We may receive personal data about you from various third parties as set out below.

Personal data that we may collect

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 personal data about individuals in the following circumstances:

1. As a visitor to New West End Company website
   • IP address
   • Browser settings
   • Cookie data
2. As an employee of a member of New West End Company
   • Full name
   • Company name
   • Business address
   • Business e-mail
   • Business phone number
   • IP address
   • Marketing preferences
   • E-mail analytics data (tracking marketing e-mail open and read status)
   • Profile data (feedback and survey responses)
3. As a member of West End Club loyalty scheme
   • Full name
   • Company name
   • Business address
   • Business e-mail
   • Business phone number
   • Marketing preferences
   • Profile data (feedback and survey responses)
4. As a supplier of goods and services to New West End Company
   • Full name
   • Company name
   • Business address
   • Business e-mail
   • Business phone number
5. As a member of the public visiting the West End

With regards to members of the public visiting the West End, we and our third-party suppliers collect the following personal data:

1. New West End Company on-street security team
   • Personal information such as video footage on CCTV recording and body-worn cameras, data on visitor logs, data relating to incidents at business premises
   • As part of the Restorative Justice programme, the New West End Company on-street security team may engage with alleged offenders to collect their personal information, as well as gather insights into why they committed the alleged offences
   • As part of the programme to protect vulnerable people from stalking and coercive behaviour, the New West End Company on-street security team may engage with victims to offer support and, sometimes, ask to provide their names and contact information.
2. New West End Company on-street dog patrols
   • Images of the public from a distance and in such a way as to make the subject unidentifiable
3. Safer Business Network (SBN)
   • SBN is an organisation supporting business communities in London and addressing their crime and anti-social behaviour needs
   • SBN collects personal information of offenders to collate intelligence on criminal activity and maintain an exclusion scheme within business premises in the West End

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 notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. 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.

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:

Opting out

You may opt out of our e-mail communications at any time by following the Manage Preferences link at the bottom any marketing communications e-mail sent to you by New West End Company or, in absence of the Manage Preferences link, by contacting privacy@newwestend.com to request an opt-out.

If you personally amend your communications preferences using the Manage Preferences link, the change will come in effect instantaneously.

If you make an e-mail request for us to update your preferences manually or to make any changes to your personal data, we will first assess your request and will contact you again further as soon we have identified your data and the purpose for which we hold it, but within the 30-day mandated time limit. We will then provide you with details of our decision and your further rights if we are unable to meet your request.

Disclosures of your personal data to third parties

We do not, and will not, sell any of your personal data to any third party. However, in the normal course of business, we may receive your personal information from third parties or share your personal information with third parties within the boundaries set out by law and our regulatory obligations and without violating your interests and fundamental rights.

Third parties that may provide us with your personal information:

• Publicly available repositories of personal data, e.g. your social media pages or your company’s public website.
• Our commercial partners, where there is a legitimate interest to share your personal data and where your interests and fundamental rights do not override this interest.

Third parties that may receive your personal information from us:

• Databases to manage your personal records (i.e. CRM software).
• Applications that are used to send our marketing communications and store your communications preferences to help us improve our engagement with you.
• Applications that are used to collect survey data from you or your personal data for participating in a prize draw or raffle.
• Analytics providers (e.g. Google Analytics) that collect information about how you use our website and social media pages to help us improve them.
• Law-enforcement agencies would sometimes receive from us the personal information of victims of alleged stalking or coercive behavior, where the New West End Company’s on-street security team engaged with the victim and collected personal information from them in order to reasonably safeguard them.

We require all our third-party service providers 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.

Some of the processing we undertake is carried out outside the EEA.  In these circumstances, we take steps to ensure that there are adequate controls in place to protect your personal data This may include the use of approved contract clauses or data processing addendums with the purpose of providing adequate safeguards to your personal data. When using any new data processors, we will undertake appropriate transfer impact assessments to make sure your personal data enjoys a level of protection essentially equivalent to that under the UK data protection regime, and, in cases, where such protection is insufficient, introduce additional measures to protect your data. More information about these protection mechanisms can be found here.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, 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. If you have any concerns about the security of your personal data, please contact privacy@newwestend.com.

Data retention

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 requirements.

Important information and who we are

This privacy notice aims to give you information on how New West End Company collects and processes your personal data through your employment in a New West End Company’s member business, through your participation in the West End Club loyalty scheme, through your engagement with New West End Company’s security team, or through the use of this website, including any data you may provide when you sign up to our newsletters or take part in a prize draw.

It is important that you read this privacy notice together with any other privacy notice 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 notice supplements the other notices and is not intended to override them.

Controller

New West End Company (registered company number 4039488) is the controller and responsible for your personal data (collectively referred to as “New West End Company”, “we”, “us” or “our” in this privacy notice).

Contact details

Our full details are:

• Full name of legal entity: New West End Company PLC
• Name or title: Company Secretary
• E-mail address for general inquiries: info@newwestend.com
• E-mail address for data privacy inquiries: privacy@newwestend.com
• Postal address: Heddon House, 149-151 Regent Street, London W1B 4 JD

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 our Data Protection Officer by e-mailing your inquiry relating to data privacy to privacy@newwestend.com in the first instance.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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 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 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.
• To 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Not to be subject to a decision based solely on automated processing with no human involvement, including automated profiling, which produces legal or similarly significant effects concerning you.

If you wish to exercise any of the rights set out above, please contact privacy@newwestend.com for further details.

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 the 30-day mandated time limit. 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.