Last Updated: December 2018
This document applies to you if you visit our website, our social media pages, our arcades or our offices, or if you are a customer. It also applies to you if you work for an organisation we deal with (for example, for one of our suppliers). It does not apply to you if you work for us or are applying to work for us. When we say “we” and “us”, that means the company Namco UK Limited.
Where we collect information about you, if that information is about you, or can be used to find out about you, it is known as “personal data”.
The law says that we have to tell you what types of personal data we have about you, what we use it for, why we are allowed to use it in that way, and what your legal rights are. That is what this document – called a “policy” – is for. We also have to tell you some other things – those are all covered in this policy.
The rules about personal data are detailed and can be difficult to understand. If you need help understanding anything in this policy, please contact us at firstname.lastname@example.org.
The simple version is this:
- We collect information about you, including contact details (like your email address), when you give us that information on our website, in our arcades, or on social media (for example, Facebook, Instagram, and Twitter).
- We mostly use that information to:
- Tell you about special offers, competitions and other things we think you might like.
- Manage your bookings for bowling games or events.
- Manage your membership.
- Manage gift certificates which you or someone else buys from us.
- Help us to understand more about our customers and what they like.
- We also collect other information – for example, cameras at our arcades (and offices) take videos of people to make sure our premises are safe places and meet our licensing obligations.
- We treat all information we have about you very carefully. We do our best to make sure that information about you does not go to the wrong people or to people who might not look after that information properly.
- If you ask us to do certain things with information about you, we usually have to do what you ask and you do not usually have to pay for this. Those things include:
- Give you a copy of information about you
- Put right any mistakes in the information we have about you
- Stop using or delete information about you
If you want to ask us to do any of these things, or you have any questions or worries, you can contact us at email@example.com. You can also contact the organisation in charge of making sure we do the right things with your personal data – the Information Commissioner’s Office – by clicking here.
This policy is addressed to individuals who visit the premises, websites or social media accounts of NAMCO UK Limited (we, our or us) or our customers, and other individuals that may deal with us, including individuals at our suppliers. In this policy we collectively refer to these categories of individuals as “you”.
If you are applying for a job or you are one of our staff members or workers a different policy will apply, which will be provided to you.
We have set out our policy in full below. For those of you who know what you are after, you can click on the links below to take you to the relevant section.
It is important that you read this policy together with any other data protection or privacy notice that we may provide on specific occasions when we collect or process personal data about you. In this way, you can ensure that you fully understand how and why we are using your data.
Who Is Responsible?
NAMCO UK Limited is responsible for processing your data and will deal with your enquiries if you communicate with us.
We will treat your personal data (which means data from which you can be identified, including your name, address, e- mail address and phone number, as well as technical information about your visit to our website, and the like) in accordance with applicable data protection legislation here in the UK.
It is important that the personal data we hold is accurate and current. Please inform us if your personal data changes during your relationship with us.
How to Contact Us
Our address is 37-39 Kew Foot Road, Richmond, United Kingdom, TW9 2SS. If you have any questions about this policy, or how we process your personal data, write us or send us an email at firstname.lastname@example.org.
If you have a complaint, we ask you to get in touch with us as soon as you can. You can, of course, make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues, at https://ico.org.uk/concerns/.
Changes to This Policy
This policy was last updated on 14 December 2018. You can obtain previous versions by contacting us here.
When you contact us through our website, our social media accounts, or communicate with us, or visit our premises, you may provide us with personal data about you, such as:
- Identity data includes first name, last name, title and date of birth.
- Contact data includes email address and telephone numbers, domestic and billing addresses.
- Communication data includes email address and phone number, and the content of your communications with us by whatever means.
- Financial data includes the details you provide to our payment services provider to pay for our services, including bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Marketing data includes your preferences in receiving marketing from us, your communication preferences, and your market segment (for example, male between the age of 21 and 25.
- Image data includes individual images or general location images in which you might be visible.
- Technical data includes Internet protocol (IP) address; browser type and version; time zone setting and location; browser plug-in types and versions; operating system, platform, cookies and other technology on the devices you use to access our website.
- CCTV includes the images recorded by the CCTV system used at and around our premises.
- Accident and Incident Data includes details about and accident or incident which has occurred on our premises.
Except to the extent that your ethnicity may be visible on CCTV footage, we do not ask for, or deliberately collect any, special categories of personal data, or information about criminal offences.
We use different methods to collect data from and about you including through:
- Direct interactions with you. You give us your identity data, contact data, financial data, transaction data, marketing data, and communication data by filling in forms or by corresponding with us via our website, by post, by phone, by email, via our social media accounts, face-to-face or otherwise, or respond to a survey or enter a prize-draw.
- CCTV systems at our premises.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources:
- Third party services which we make available to you. When you use services that we make available to you, such as external wi-fi at our locations (for example, The Cloud provided by Sky), you will provide your data to them. As part of your arrangement with that provider, you may permit them to share your email address and other information with us for marketing purposes or for us to provide services which you have requested.
- Marketing data. When you use social media sites such as Facebook, Instagram, Twitter to contact us via that platform or share content with us. Those sites may also provide us with information about you, such as where you send us a message, or like or comment on us or our content. We also receive data about you from our marketing services provider. We do not buy in mailing lists.
- Technical data. You provide this to our hosting providers when you interact with our website or our social media accounts. We also receive information from the following parties:
- Analytics providers such as Google.
- Search information providers based inside the EU.
- Identity data from publicly availably sources such as Companies House and the electoral register in your jurisdiction, or when provided by someone buying a gift card for you (for which we only use your name for personalising the card).
Where possible, we will notify you when we receive information about you from third parties and will inform you about the purposes for which we intend to use that information.
Purposes and Legal Bases for Processing Your Personal Data
The table below describes in more detail the purposes for which we use your personal data. It also identifies the relevant type of data, and the legal bases we rely on for that purpose.
If we have identified multiple legal bases for a particular purpose, please contact us here. if you would like further information.
|Purpose/activity||Type of data||Legal basis for processing (including basis of legitimate interest)||Retention Period|
|To register you as a new customer||Identity Data
|Bowling: bookings kept on the system for 7 days after the booking.
Party/Event: 2 years after the date of the booking
|To process and deliver your order||Identity data
|2 years after the date of the booking
|To manage||Identity data
|Legitimate interest Consent
|Until consent withdrawn or
after 2 years of no interaction
|To enable you to partake in a prize draw, competition or complete a survey||Contact data
|Contract||Until 1 month after the competition/prize draw has closed
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Technical Data
|Until consent is removed or after 2 years.
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical Data
|2 years from the date of collection
|CCTV||CCTV||Legitimate interest – to manage insurance insurance claims
|31 days from the date of recording, unless required for longer insurance or other legal requirement|
|To complete accident or incident reports which are reported to us||Identity Data
Accident and Incident Data
|We follow legal guidance on retention of accidents and incidents.|
|To enable you to use Wifi in our locations through use of ‘The Cloud’ internet wifi||Identity Data
|, via Sky through log in to the cloud wifi||We follow Sky’s The Cloud policy for Wifi in locations which can be viewed here [insert link].|
|To manage your membership (including your card)||Identify Data
Consent (for marketing)
|until your membership is cancelled or
after 2 years of no interaction
|Images posted on social media||Image Data||Consent||Retained on our social media platforms until consent is withdrawn.|
We do not make any decisions which could have a legal effect, or other significant effect on you, based solely on automated processing of your personal data.
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 would like to understand more about any of our purposes, please contact us here. We will notify you to explain if we need to use your personal data for an unrelated purpose.
Failure to Provide Personal Data
Where we need to collect personal data by law, or under a contract we have with you, or we are processing your personal data to fulfil a request you have made, and you fail to provide that data when requested, we may not be able to perform the contract or comply with your request. We will use reasonable efforts to notify you if this is the case at the time.
We hope that you enjoy and value our newsletter and updates, and our marketing material generally. We may send you this information by various means including, email, text message, post, telephone, or social media. We respect your right to choose what marketing messages you receive. You can opt out of any marketing material that we send you at any time by clicking the unsubscribe link in our emails, unsubscribing from our social media accounts, or by contacting us here.
We may ask you to confirm or update your marketing preferences over time, such as when you ask us to provide further services in the future, or if there are changes in the law or the regulation or structure of our business.
Sharing Your Personal Data
All of our contractors, suppliers and staff (including volunteers, agents, temporary workers and casual workers) who process your personal data on our behalf (and therefore act as our processors) are subject to strict contractual requirements in relation to processing personal data.
Where we are required to disclose your personal data to another organisation that acts as a controller (for example, law enforcement agencies, regulators or as part of court proceedings), we will only do so if required by law, or if you have approved that disclosure.
We only disclose information to a third party where permitted by law, and always only as necessary to achieve a legitimate purpose. We will never share your personal data with any party for its own marketing purposes without your prior consent.
We may disclose your personal data to the following:
- Internal third parties. This includes any of our subsidiaries and parent companies which support our services or have a need to know in order to respond to your enquiries or to meet our commitments to you.
- External third parties in connection with our services – this includes to:
- Our suppliers, sub-contractors and providers of goods or services for the performance of any contract that we enter into with them to support our business. For example, our sub-contractors in technical, payment and delivery services, membership card management systems providers, marketing and advertising service providers, analytics providers, search and social media information and optimisation providers, and archiving and confidential waste disposal contractors.
- Where legally compelled to do so, a court or tribunal, a regulatory authority (such as the Gambling Commission), and law enforcement agencies.
- Our professional advisers, insurers and bank.
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets only for that purpose and subject to appropriate confidentiality agreements.
- If NAMCO or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- To anyone where we have your express prior consent.
The only people who can use your personal data are authorised NAMCO staff, in particular our IT department, or our suppliers which are contractually committed to maintain the confidentiality of your personal data and to treat it in accordance with applicable data protection law in the UK.
If you submit personal data, the information is available only to the NAMCO staff involved in the relevant activity, and to our authorised third parties (as described above) where we have appropriate arrangements in place.
We have a strong commitment to data security. We use all reasonable endeavours to protect personal information from loss, misuse or alteration and we have put in place physical, electronic, and managerial procedures to safeguard and secure the information you provide to us online, or that we store about you. We take appropriate steps to communicate and train our staff in relation to applicable data protection law.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or via the social media accounts that we operate; any transmission is at your own risk.
Use of CCTV data is subject to additional specific rules and protections, as described more fully in our CCTV Policy, which is available on request.
If you would like to know more about our data security measures please contact us here.
International Data Transfers
We will not intentionally transfer your personal data outside the EU without ensuring appropriate safeguards are in place.
For example, we may put in place standard contractual clauses, or, if that is not appropriate, we may seek your explicit consent.
However, we have no control over the routes emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the EU, where they may not be protected by strong privacy or data protection laws.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In certain circumstances, you may ask us to erase your personal data. See your right to erasure noted below.
We may also choose to anonymise your personal data, by making sure that you are no longer identifiable. We can then keep that data indefinitely.
Your Data Protection Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data which we process as a controller. These rights are subject to specific requirements and limitations set out in the applicable data protection legislation.
You have the right to ask us:
- To receive a copy of the personal data we hold about you and to check that it is being lawfully processed.
- To receive a copy of your personal data (or have it passed to a third party) in a common and structured electronic format (where the legal basis for our processing is your consent, or the processing is necessary for the performance of our contract with you).
- To correct your personal data if it is wrong and to complete it if it is incomplete.
- To stop using your personal data for direct marketing.
- To restrict our processing of your personal data – you may want to do this while we consider your request to have it corrected.
- To erase your personal data, but we will retain your data for the purposes of dealing with any claims or where we have any other legitimate reason to retain it.
You also have the right:
- To withdraw your consent to our processing your personal data (where that is relevant) at any time.
- To object to how we are processing it, for example if we are processing it on the basis of a legitimate interest and that does not override your individual rights.
- To complain to the Information Commissioner’s Office about our processing or our response to your requests and objections – www.ico.org.uk/concerns/ or 0303 123 1113.
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 or refuse your request, if your request is clearly unfounded, repetitive or excessive.
What we may need from you – We may need to request proportionate 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. 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.