Policies

• San Carlo Privacy Policy
• San Carlo Cookies Policy
• San Carlo Gender Pay Gap Policy
• San Carlo Modern Slavery Policy statement

San Carlo Privacy Policy

At Harnbury Holdings Ltd (company number: 02702491) of 1^st Floor, Acresfield, 8-10 Exchange Street, Manchester, M2 7HA, t/a San Carlo (San Carlo), we take your privacy seriously. The following document outlines how we collect, use and protect your personal data across all of our San Carlo websites (including www.sancarlo.co.uk, www.sancarlocicchetti.co.uk, www.sancarlofumo.co.uk, www.signorsassi.co.uk, www.sancarlobottega.co.uk, www.sancarlograncafe.co.uk, www.sancarloalto.co.uk and www.sancarlofiorentina.co.uk) and digital platforms (Websites) and also in our restaurants and when you contact us by phone, email, post or social media.

What personal data is being collected?

Whilst you are using our Websites we may ask you for some personal data, such as your name, email address, address and phone number, demographic information such as your age, gender, location, restaurant preferences and interests when you take part in any of our customer surveys, offers, newsletters and competitions or when you make an online booking or register to join My San Carlo. We may also collect your IP address in order to serve you location specific content and tailor our Websites to you. Where you make payment in any of our restaurants using a credit or debit card, we will collect and hold details of such payment card.

Who is collecting the personal data?

All personal data collected when using our Websites will be collected by Harnbury Holdings Ltd. The personal data we collect from you while you are in our restaurants will be collected by the operator of such restaurant. If you are dining in one of our restaurants which is located in a third party store (for example, Ciccheti in House of Fraser or any of our restaurants located in Selfridges) your personal data will be collected by Harnbury Ltd (company number: 01386303). If you are dining in one of our Signor Sassi restaurants, your data will be collected by Signor Sassi Limited (company number: 04018989). Otherwise, the collection will be carried out by Harnbury Holdings Ltd.

How is the personal data collected?

Personal data is collected across the Websites as you use the relevant sites. Personal data collection takes place during the following actions – making dining reservations, entering competitions, signing up to the San Carlo Newsletter or signing up to the My San Carlo members area. We may also collect your personal data for the purpose of processing payments in our restaurants, when dealing with any customer service queries and if you complete one of our in-store cards to sign up to receive our latest news and offers.

How is the personal data stored / secured?

Your personal data and privacy is of the utmost priority to us. We are committed to ensuring that any personal data/information gathered is securely stored. To ensure no personal data is collected or disclosed against your will or any unauthorised access is gained, we have implemented the necessary physical, electronic and managerial procedures to safeguard and secure the personal data we collect from you. 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 Websites; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. The length of time for which we will securely store any personal data you share with us will depend on the type of personal data and the purpose for which it is being held. The following are indicative periods for which we will retain your personal data:

• where we are holding your personal data as a member of My San Carlo, for so long as you continue to be a member of such club.
• where we are holding your personal data for the purpose of sharing our newsletter with you, for so long as you consent to receive such communications.
• where we are holding your personal data to enable us to carry out a reservation, until such reservation has been completed (i.e. the date on which you dine with us and for such period thereafter as is necessary for our internal administrative purposes), unless you have chosen to join My San Carlo (in which case the personal data will be held for so long as you continue to be a member of such club).
• where we are holding your personal data for payment processing reasons, 3 months following the collection of such personal data.
• where we are holding your personal data for customer service reasons, for such period as is necessary to ensure that your query has been dealt with fully and properly in accordance with our usual standards.

Why do we collect this data?

We would like to collect your personal data in order to provide you with the best possible experience and service and to tailor our communications to you. We will need your name and email address in order to create your My San Carlo account. If you choose to provide us with your age, gender, location and any other demographic or preference information, this personal data will be subject to automated processing to create a profile of you and your preferences which will then be used to seek to tailor our communications to you. If you are not comfortable with this automated processing, please contact us using the details below to let us know. By allowing us to collect your IP address and cookies, your experience on our Websites will be maximised as our sites rely on some of the personal data you supply to function at their optimum level. If you choose to join our My San Carlo club, your personal data will be used to communicate relevant and up to date information about our restaurants (including, San Carlo, Cicchetti, Fumo, Signor Sassi, Bottega, Gran Cafe, Fiorentina and Flying Pizza) to you, which will include: –   Specific restaurant offerings –   New menus –   Competitions –   Events –   New Restaurants –   Location specific news –   Newsletters and promotional emails which we feel will be of interest to you –   Other related information The personal data we collect whilst you are in our restaurants and as part of our provision of customer services will be used for the purpose of providing our services to you. This personal data will not be used for any other purpose.

What is our lawful basis for our use of your personal data?

Where we are using your personal data for direct marketing purposes (including membership of My San Carlo), our lawful basis for such processing will be your consent. Where we are using your personal data to make a booking/reservation, process a payment or provide our customer services to you, our lawful basis for such processing will be performance of a contract.

You may withdraw your consent at any time

As noted above, some of our processing is subject to the lawful basis of “consent”. You are able to withdraw your consent to such processing at any time by either contacting us using the details set out below, following the “opt-out” link in any marketing communications we send to you or (where you are a member of My San Carlo) adjusting your preferences in our members area. Please note that if you withdraw your consent to us using your name and email address then you will no longer be able to benefit from our My San Carlo membership and your account will be deleted.

Sharing your data

We do not sell your personal information to any 3rd party organisations. We do, however, share your data with certain third parties in order to provide our highest quality service to you, this includes: our marketing agents, our email mailing list provider, our IT service provider, our payment processor and our online booking provider. In addition, we may make the following disclosures of your personal data to third parties where required:

• 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.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of Harnbury Holdings Ltd (or any company within our group), our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

International Transfers

We do not transfer your personal data outside of the European Economic Area.

Checking your details

If you wish to amend or verify the details you have submitted to us you may do so by contacting us via the email address or address given below. Our security procedures mean that we will request proof of identity before we reveal information.

Deleting your data

If at any point you no longer want to receive communications from Harnbury Holdings Limited and you wish to permanently delete your personal data records we will, subject to not requiring such personal data to be retained for any legal or other valid reason, facilitate this without undue delay upon receiving your communication. This action can be instigated at any time by the following methods (please note that if you do make such a request by phone, we will also require confirmation of this in writing for our records): Phone – 0161 839 8865 Email – info@sancarlo.co.uk Post – Harnbury Holdings Ltd 1st Floor Acresfield, 8-10 Exchange Street Manchester, M2 7HA

Your rights in respect of your personal data

In addition to your right for your personal data to be deleted (as set out above) you have various other rights in respect of your personal data, as follows:

• a right of access to a copy of the personal data we hold about you;
• a right to object to processing that is likely to cause or is causing damage or distress to you;
• a right to prevent processing for direct marketing;
• a right to object to decisions being taken by automated means;
• a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
• a right to claim compensation for damages caused by a breach of the Act.

If you wish to exercise any of these rights, please contact us at info@sancarlo.co.uk or Harnbury Holdings Ltd, 1st Floor Acresfield, 8-10 Exchange Street, Manchester, M2 7HA or by phone to 0161 839 8865.

We may make changes to this policy

Any changes we make to our privacy policy in the future will be posted on the Websites and notified to you the first time you access the Websites following such change.

Your right to make a complaint in respect of our use of your personal data

You have the right to complain to your relevant supervisory authority in respect of our use of your personal data. If you are a UK resident, your complaint would normally be addressed to the Information Commissioner’s Office. Please contact us before you escalate your complaint.

Contacting us

We are always pleased to hear from our customers. We are always grateful for any time you spend providing us with the knowledge we need to ensure our customers are completely satisfied – we want to work with you and want you to recommend us to your friends, family and associates. If you have any questions or feedback about this statement, or if you would like us to stop processing your personal data, please do not hesitate to contact us and will be delighted to answer any questions you may have. You can either contact us by clicking here. Calling 0161 834 6226 Or, writing to us at: San Carlo Harnbury Holdings Ltd, 1st Floor, Acresfield, 8-10 Exchange Street Manchester, M2 7HA Our data protection officer is Joanna Simpson and she can be contacted in writing at joanna@sancarlo.co.uk or by phone on 0161 834 6226.

San Carlo Cookies Policy

As is common practice with almost all professional websites our Websites use cookies, which are tiny files that are downloaded to your computer, to improve your experience on our Websites. This policy describes what information they gather, how we use such information and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of our Websites’ functionality. For more general information on cookies see allaboutcookies.org

How We Use Cookies

We use cookies for a variety of reasons which are detailed below. Unfortunately in most cases there are currently no industry standard options for disabling cookies without completely disabling the functionality and features they add to our Websites. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You will be given the opportunity to opt in/opt out of certain cookies (including those that collect personal data about you) we use but as mentioned above opting out could disable the functionality and features they add to our Websites. Once you have agreed to opt in we will always provide you with the opportunity to opt out at any time. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of our Websites and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of our Websites. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

Our Websites offer newsletter, email subscription services and My San Carlo members area and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users/members. When you submit personal data to us through a form such as those found on contact pages, competitions, bookings or comment forms cookies may be set to remember your user details for future correspondence or relevant content sharing.

Third Party Cookies

We also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site. Our Websites use Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use our Websites and ways that we can improve your experience. These cookies will track things such as how long you spend on our Websites and the pages that you visit so we can continue to produce engaging content and maximise the San Carlo experience For more information on Google Analytics cookies, see the official Google Analytics page. Third party analytics are used to track and measure usage of our Websites so that we can continue to produce engaging content. These cookies may track things such as how long you spend on our Websites or pages you visit which helps us to understand how we can improve our Websites for you. You may also encounter cookies related to the WordPress Content Management System, which is essential for correct functionality. We would also capture your IP address upon completion of a contact form on the site (competition/booking) as well as every time you access our Websites. In the latter case, this would be in a non-personally identifiable way.

Cookie List

Below is a list of the cookies used on the San Carlo site:

[cookie_audit columns=”cookie,duration,description”]

Local Storage

Our Websites also use Javascript Local Storage. This doesn’t store personal data just your viewing preferences.

More Information

If you are looking for more information, please contact us through one of the following: Phone – 0161 839 8865 Email – info@sancarlo.co.uk Post – Harnbury Holdings Ltd 1st Floor Acresfield, 8-10 Exchange Street Manchester, M2 7HA

San Carlo Gender Pay Gap Policy

To view the San Carlo Pay Gap Policy statement, please click here 

San Carlo Modern Slavery Policy statement

To view the San Carlo Modern Slavery Policy statement, please click here