Privacy Policy

This privacy policy aims to give you information on how we collect, store, transfer and process your personal data. This privacy policy explains what personal information we may record, why we do so, how you may control the use of your information and how we protect your information.  

DS Holdings (Penarth) Ltd who’s registered office is Office 4 Workspace Penarth, Albert Road, Penarth, United Kingdom, CF64 1FD is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy). We respect your privacy and are committed to protecting your personal data.  

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

  

Updates to the Privacy Policy    

We keep our privacy policy under regular review.  This policy was last updated on 1st June 2024, any future changes to our policy will be reflected here.  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.  

  

Data Protection Regulations  

We comply with the United Kingdom General Data Protection Regulation (EU) and the amended Data Protection Act (2018). Article 5 of the UK GDPR contains the data protection principles which require that personal data shall be:  

  • Processed lawfully, fairly and in a transparent way.  
  • Collected for specified, explicit and legitimate purposes and not used in any way that is incompatible with those purposes.  
  • Adequate, relevant, and limited to what is necessary. 
  • Accurate and, where necessary, kept up to date.  
  • Kept for no longer than is necessary for the purposes we have told you about.  
  • Kept securely.  

 We operate according to the principles of the UK General Data Protection Regulation, the Data Protection Act and the Privacy and Electronic Communications Regulations, regardless of the location of the data subject.  

  

Important Information   

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our Data Protection Officer, Celyn Evans, who can be contacted by:  

Postal address: Office 4,  Workspace Penarth, Albert Road, Penarth, CF64 1FD  

Email address: enquiries@newport-market.co.uk  

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.  

This website is not intended for children, and we do not knowingly collect data relating to children.  

  

Third-parties  

This website includes 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 do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.  

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

  • Identity, Contact, Financial and Transaction Data from Mr Yum (Me &U) or Sum Up a mobile ordering and payment service providers based inside the UK);  
  • Technical Data from analytics providers such as Google based outside the EU.  

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.  

  

  

Data Collection  

How we collect your data  

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 collect data from you if:  

  • You correspond with us by post, phone, email or otherwise.  
  • You visit one of our sites and sign into our free Wi-Fi.  
  • You subscribe to our newsletter.  
  • You submit an enquiry via one of our forms. 
  • You book a ticket for an event.  
  • You book a table or make a reservation enquiry.  
  • You engage with us on social media.  
  • You enter prize draws or competitions.  
  • You choose to complete surveys we send you and/or provide feedback.  
  • You fill in any forms (e.g. if you have an accident at our site or lost property).  
  • You visit one of our sites which have CCTV systems operating for the security of both customers and staff.  
  • You visit one of our sites which may have photography/recording/filming taking place that may be used for promotional material.  
  • You purchase food via an app at any of our vendors.  

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

  • Identity Data includes first name, maiden name, last name, marital status, title, gender, birth date, job title and organisation name.  
  • Contact Data includes billing address, personal email address, business email address and telephone numbers.  
  • Financial Data includes bank account and payment card details.  
  • Transaction Data includes details about payments to and 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 this website.  
  • Profile Data includes bookings made by you, feedback and survey responses.  
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 also collect and use Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.  

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 in to with you (for example, to provide you with 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.  

  

Data Usage   

How we use your 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 in to or have entered in to 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 obligation.  

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.  

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.   

Purpose/Activity   Lawful basis for processing including basis of legitimate interest  
To provide a service to you   Performance of a contract with you  
To process and deliver your booking including managing payments and collecting money due to us   (a) Performance of a contract with you  

(b) Necessary for our legitimate interests (to recover debts due to us)  

To manage our relationship with you which will include:  

(a) Notifying you about changes to our terms or privacy policy  

(b) Asking you to leave a review or take a survey  

(a) Performance of a contract with you  

(b) Necessary to comply with a legal obligation  

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)  

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)   (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)  

(b) 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   Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)  
To use data analytics to improve our website, services, marketing, customer relationships and experiences   Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)  
To make suggestions and recommendations to you about services that may be of interest to you or to offer you promotional offers   Necessary for our legitimate interests (to develop our services and grow our business)  

   

Promotional offers from us  

We may use your Identity, Contact, Technical 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. You will receive marketing communications from us if you have requested information from us or purchased services from us and 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 third party 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.  

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 purchase.  

  

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.  

  

Disclosures of your personal data  

We use some third-party providers to help us run our business. We may share your personal data with the following third parties for the purposes set out in the table above:  

  • TicketSource, acting as a processor who administers online bookings on our behalf.  
  • Eventbrite, acting as a processor who administers online bookings on our behalf.  
  • Design My Night, acting as a processor who administers online bookings on our behalf.  
  • Mr Yum (ME&U) platform acting as a processor who processes payments to enable you to pay for certain services by debit or credit card.  
  • Sum Up acting as a processor who processes payments to enable you to pay for certain services by debit or credit card.  
  • Girl and Boy Studio Ltd ,acting as a processor who provide website design and development services.    
  • Stampede, service providers acting as processors based in the UK who provide IT and system administration services including wifi and email marketing services.  
  • GLTS, service providers acting as processors based in the UK who provide IT communications and technological support  
  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.  
  • 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.  

   

International transfers  

We do not transfer your personal data outside the European Economic Area (EEA).  

If, during the course of business, we engage third parties whose processing of your personal data will involve a transfer of data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:  

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.   
  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.   

   

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.  

   

Data retention  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  

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.  

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and accounting purposes.  

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

   

Your legal rights  

Under certain circumstances, 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.   
  • 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.  
  • 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:  
    • If you want us to establish the data’s accuracy.  
    • Where our use of the data is unlawful but you do not want us to erase it.  
    • 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.  
    • 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.  

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 could 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 could 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.