Policies

Privacy policy

Privacy policy

GENERAL NOTICE 

Crown London’s Members, Guests, and Website Users by providing personal information explicitly consent to this information being governed by this Privacy Policy, the Membership Rules, and any other form of explicit consent provided to Crown London from time to time. 

Should you not agree and wish to vary, modify, limit, or withdraw your consent subject to the Data Protection Act 2018 (DPA 2018), please notify us. 

Please note that emails sent to or received from Crown London are not encrypted, therefore communication via this method is at your inherent risk. Please refer to the “How to Contact Crown London” section of this policy for other available communication methods. This Privacy Policy replaces any previous Privacy Policy.

YOUR PRIVACY IS IMPORTANT

Your privacy is important to us, and Crown London is dedicated to protecting your personal information. This Privacy Policy explains Crown London’s personal information handling practices across the organisation including information about the collection, usage, disclosure and storage of your personal information. 

In addition, information containing how you access personal information we hold about you, how you request varies, withdraws consent, corrects, or erases personal information about you and/or making a complaint if you have concerns on the management of your personal information. 

You can find more information by contacting Crown London, please refer to the “How to Contact Crown” section of this policy.

COLLECTION OF PERSONAL INFORMATION

Crown London collects your personal information in order to perform specific functions or activities and offers services to you including those of our affiliates. Crown London’s functions, activities and services are many and varied and include the casino, Club Membership, concierge services, restaurant and bar, entertainment, marketing, competitions, financial transactions, complaint handling, recruitment, compliance, security, and surveillance.

Personal information is information or an opinion that could identify you. Personal information may include your name, image, date of birth, phone number(s), address, email address, identification, connections, Self-Enrolment National Self Exclusion (SENSE) information, financial information (card details, account, and funds provenance), gaming records, occupation(s), credit history, bookings, behaviour, and any other information provided by you. The type of personal information we collect from you depends on your interaction with us. 

Depending on the transaction, if Crown London does not collect your personal information, we may not be able to provide you with an offer or service.

COLLECTION FROM YOU

It is Crown London’s usual practice to collect your personal information directly from you. For example, you provide your personal information when you apply to become a member of the club, enter the premises as a guest, utilise our website, write to us, participate in a competition, make an enquiry, or make a restaurant reservation.

COLLECTION FROM PUBLIC SOURCES OR THIRD PARTIES

Where relevant, Crown London will collect personal information about you from a publicly available source (such as open-source intelligence) or from third parties, this includes: 

  • Credit reporting bodies (if we request information about your credit history);
  • Third-party Due Diligence providers for an independent view on data intelligence for AntiMoney Laundering, Anti-Corruption and Cybersecurity; 
  • Other casinos; and 
  • Crown London’s related entities (Crown Resorts).

COLLECTING SENSITIVE PERSONAL INFORMATION

Sensitive personal information is information or an opinion about an individual’s racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, criminal and civil offences, records and proceedings (including alleged offences) philosophical beliefs, sexual preferences, health information, genetic information or membership of a trade union. 

Crown London’s general approach is not to collect, use or disclose sensitive information. However, in limited circumstances, Crown London will collect sensitive information where it is necessary for one of Crown London’s functions or activities. For example, Crown London may collect health information from you should you wish to participate in an activity that requires knowing your physical condition in order to safely participate.

COLLECTING INFORMATION REQUIRED BY LAW

Crown London collects your personal information where required or authorised to do so by law or court order, for example, pursuant to (not limited): 

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; 
  • The Proceeds of Crime Act 2002; 
  • The Gambling Act 2005; 
  • The Companies Act 2006; and 
  • The Finance Act 2022.

USING AND DISCLOSING YOUR PERSONAL INFORMATION

Crown London may use and disclose your personal information collected and share it with related entities for a number of different purposes, including: 

  • Identify, contact you and manage our relationship with you; 
  • Inform you about events or promotions at Crown London that you may be interested in; 
  • Manage and administer our services to you; 
  • Conduct and improve our businesses and improve the customer experience;
  • Maintain security and safety; 
  • Prevent or investigate any actual or suspected misconduct, fraud, or unlawful activity; 
  • In relation to your credit worthiness, including obtaining a credit report about you; 
  • Consider any concerns or complaints you may raise against Crown London 
  • Comply with our legal obligations as required by relevant laws, regulations, and codes of practice. 

DISCLOSING YOUR PERSONAL INFORMATION

We understand how important it is to keep your personal information private. We will use and disclose your personal information for the purposes it was collected and where you would reasonably expect us to. However, we will also disclose your personal information when: 

  • You agree to the disclosure; and 
  • The disclosure is required or authorised by law. To the extent permitted by law, we may also disclose information about you to: 
  • Crown London’s related entities; 
  • Third parties who provide services to Crown London from time to time such as mail house providers, customer research agencies/systems, collection agencies, advertising agencies and our advisers; 
  • Government agencies and regulatory bodies including the Gambling Commission as part of our statutory obligations; and 
  • Other casino operators, to identify credit worthiness, the prevention and detection of crime, the apprehension and prosecution of offenders and mitigation.

DISCLOSING YOUR PERSONAL INFORMATION OVERSEAS 

For international customers, Crown London may share your personal information with overseas recipients located in countries where Crown London or an associated entity, has staff or a business, including without limitation, providing DPA 2018 compliance equivalent. 

For international gaming patrons, we may also share your personal information overseas in relation to the assessment of your credit worthiness. 

MARKETING

Where applicable Crown London will use your personal information to contact you via mail, mobile, email, telephone or online informing you about news, special offers, products and services that you might be interested in. 

We do this where you have consented to receive such information, or it is related to the purpose for which we collected your personal information. This service is optional, and you can contact us to update or withdraw your marketing preferences at any time, which Crown London endeavours to act as reasonably practicable, including at the time of providing your information should you select not to this will occur with immediate effect. 

In instances whereby your information was obtained by or passed onto a third-party provider, in accordance with this policy, you may be required to contact them directly in order to update or withdraw your marketing preferences. Crown London does not market to any excluded persons including persons registered on SENSE. 

RESTAURANT RESERVATIONS

Crown London and affiliated booking engines, OpenTable, Seven Rooms and ResDiary collect your personal information in order to secure reservations at Crown London 27 Restaurant & Bar. 

If you do not provide this information, you cannot make a reservation at Crown London. If you agree to marketing contact then your personal information may be disclosed to associate entities. 

SURVEILLANCE

Crown London is subject to Closed Circuit Television (CCTV) video and audio recording systems, the CCTV system operates throughout the premises, including the perimeter of the Crown London property. The CCTV system assists in providing a safer working environment for our staff, members, guests, and visitors whilst maintaining security and safety at all times.

Crown London ensures that the processing of CCTV video and audio recordings is reasonably practicable as required by law and regulations. Sharing of details of suspected, illegal or improper conduct with the Gambling Commission, public authorities, and other casinos may occur.

FLEET SERVICE - Incident Recording Device (Dash Cams) and GPS Tracking Device

Dash cams and GPS tracking devices are in operation in our fleet service vehicles to assist in the protection and safety of persons and property, prevention or detection of criminal activity, defence of legal claims and assist in our drivers’ training and performance. 

Member and Guest information is not captured by these devices. 

SECURITY OF PERSONAL INFORMATION 

Crown London takes steps to protect the personal information it holds against loss, interference, unauthorised access, use, modification, or disclosure and against other misuses. Your personal information is held on Crown London premises in secure systems or offsite using trusted third-party providers, this includes information being transferred and stored outside of the UK Jurisdiction. 

Crown London takes all reasonable steps to ensure adherence to this Privacy Policy by its employees and service providers to maintain the confidentiality of any personal information held by Crown London in strict adherence to the general obligations of the DPA 2018. 

Our security safeguards include: 

  • Staff training on their obligations with regard to your information; 
  • Ensuring appropriate data handling and security arrangements are in place, when we disclose and/or store information or use third parties to handle or store data;
  • System security such as encryption, firewalls, intrusion detection systems and surveillance; 
  • Complex security such as CCTV and audio surveillance; and 
  • Destroying personal information when no longer required. 

ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION

Subject to some exemptions, you may ask Crown London to provide you access to the personal information that we hold about you. To do so, please notify us. On request, we will provide you with our Data Subject Access Request form for you to complete. A Photo ID verification may be required to identify you. 

Once Crown London has collected your personal information, and your identity has been verified, your information will be made available to you within a month unless, an extension is required. The exception being where we are not required to give you access pursuant to a derogation in the DPA 2018. In each instance, you will be notified accordingly. 

Where applicable, we will inform you in advance of any fees required by Crown London to find the information requested. If you find that your personal information is inaccurate or out-of-date, please inform us. For further information on requesting access, changes to the information Crown London holds on you, updating your marketing preferences or to unsubscribe please contact us (refer to the “How to Contact Crown” section of this policy).

WEBSITES, DEVICES AND COOKIES

Where applicable, Crown London will also collect the following information from you: 

  • Where devices are enabled to connect to or are identifiable by, the Crown London premises infrastructure (for example Wi-Fi networks or Bluetooth infrastructure), we and our third-party providers may automatically collect data from those devices including usage, type of device, location within the complex and arrival and departure time; 
  • The fully qualified domain name from which you accessed our websites, or alternatively, your IP address;
  • The web browser that you are using and the pages you accessed; 
  • Device ID number (MAC address); 
  • The date and time you accessed each page on our websites; 
  • The URL of any webpage from which you accessed our websites or by using the complex Wi-Fi, and the details of any mobile Apps you have accessed from a device using the complex Wi-Fi; 
  • Publicly accessible social media posts and any personal information you allow us to collect by linking your account on our website with a third-party social-networking site including but not limited to Facebook, Twitter, or Google+; and 
  • Cookies that track your visits to our websites (refer to the Cookies section below for further information).

Where applicable, we collect this information (and may use or hold this information) to provide, improve and develop our services to you and enhance the customer experience. 

Crown London may use this anonymised data to use for our promotional and marketing strategies, as well as for research and profiling purposes including customer demographics, interests and behaviours based on personal information and other information provided to us. This research may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated information in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

Crown London may connect information you provide to us for one purpose with other information for use for one or more of the above purposes. If you access or log-in to the premises Wi-Fi service and we hold other information (both personal or non-personal) that can be associated to you or the device on which you are accessing the Wi-Fi service (including, but not limited to a device ID number (MAC address)), then that information may be linked with personal information we hold about you as set out in this policy. This will be treated in the same manner as the personal information to which it has been linked.

COOKIES

Crown London uses cookies, which are pieces of information that allows the server to identify and interact more effectively with your device whenever it communicates with www.crownlondonaspinalls.com. Google Tag Manager, Google DoubleClick and Google Analytics  interact with the website. Crown London uses cookies to identify you between multiple visits, to understand how www.crownlondonaspinalls.com is used, and to provide you information, which may be of interest to you. This information is based on your previous visits to www.crownlondonaspinalls.com and to provide targeted advertising to you (including through ad-servers and other third-party advertisers) when you visit www.crownlondonaspinalls.com and certain other websites where advertising is found from time to time.

We may provide the information we gather from cookies to third parties for these purposes and for other purposes connected with www.crownlondonaspinalls.com. If cookie information is linked with personal information, we hold about you as set out above, this cookie information becomes personal information and will be treated in the same manner as the personal information to which it has been linked. Most web browsers are set to accept cookies, however, if you do not wish to receive any cookies, you may set your browser to refuse them. In some instances, this will mean that you will not be able to take full advantage of parts of the website that provides you with improved service.

DATA STORAGE

Information and records relating to offers and services will be stored securely and will only be accessible to authorised staff and, in some cases, may be made available to third-party processors. 

Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately in accordance with Crown London’s Records Management Policy and Document Retention Guide. 

It is Crown London’s responsibility to ensure all personal and company data is subject to the implementation of the appropriate technical and organisational measures required by DPA 2018 in the current version, in order to safeguard the rights and freedoms of the data subjects.

MAKING A PRIVACY COMPLAINT

Crown London takes its obligations pursuant to the DPA 2018 seriously. 

Individuals may make a written complaint about a breach of the DPA 2018 by Crown London to Crown London’s Data Protection Officer (using the address in the “How to Contact Crown” section of this policy). 

Any complaint should set out as much detail as possible, all the relevant particulars relating to the complaint, including why the individual says that Crown London has breached the DPA 2018. 

Upon receiving a written complaint, Crown London will acknowledge receipt of the complaint in writing without undue delay. Crown London will investigate the matters described in the complaint and then provide a substantive written response within one month from the date the written complaint was received by Crown London. 

Should you feel that Crown London has not processed your data fairly, you retain the right to submit a complaint to the Information Commissioner’s Office (ICO). For further details refer to their website, https://ico.org.uk/.

HOW TO CONTACT CROWN LONDON

Individuals can obtain further information in relation to this Privacy Policy, or provide any comments, by contacting:

Telephone: +44 (0) 20 7647 5454

By Post:
Data Protection Officer
Crown London 
27-28 Curzon Street 
London W1J7TJ

Email: dpo@crownaspinalls.com

Crown London also collects personal information as part of its normal communication processes directly related to those purposes, including:

  • When an individual emails staff members; 
  • When an individual phone Crown London, it may store their phone number on its telephone system; and 
  • When an individual provides Crown London with their business card.

Privacy Policy v4
August 2023
Crown London is owned by Aspinalls Club Limited an England registered company no. 2495259, registered with the Information Commissioner’s Office (ICO) no. Z6242841.