&Soul Privacy Policy

Last updated 14th September 2023

FF Propco 2 Limited and its group companies (collectively “&Soul”, “we“, “us“, and “ours“) is committed to protecting the privacy of our users and customers. This privacy notice (“Privacy Notice“) is intended to inform you how we gather, define, and utilise your personal data such as name, address, email address and mobile phone number that you give to us when you interact with us in person, phone, email, through www.andsoul.com (the “Website”), our mobile application (the “App”) or via any other of our services (the Website, App and our other services, collectively our “Services”). It is also intended to assist you in making informed decisions when using our Services. All your personal information shall be held and used in accordance with the General Data Protection Regulation ((EU) 2016 /679) and Data Protection Act 2018 (including all updated or amended legislation).

What information do we collect?

The personal information that we may collect about you broadly falls into the following categories:

  • Information that you provide voluntarily

Certain parts of our Services may ask you to provide personal information voluntarily: for example, we require personal information from you when you make a booking with us, we may ask you to provide your contact details when you visit our sites or in order to register an account with us, or you may engage with us or other users of the Services via interactive functions on our Website or App.

This information may include your name, contact details, identity verification, passport and visa details, and payment and bank account information, employment information, records from previous visits, survey responses and images and audio from our CCTV (as further explained under the heading ‘CCTV’).

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

  • Information that we collect automatically

When you use our Services, we may collect certain information automatically from your device.  In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.  We may also collect information about how your device has interacted with our Services, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who use our Services, where they come from, and what content on our Services is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our Services to our visitors.

We may aggregate data that we collected, and this aggregated data will not personally identify you or any other user. 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.

  • Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including our customer referral scheme), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties include for example your name and email address and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you.

We maintain the highest standards of security, however the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your Information, we cannot ensure the security of your data transmitted to our Website. Any information you submit is sent at your own risk. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using appropriate technical security measures.

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 into with you (for example, to provide you with certain 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.

How do we use the information that you provide to us?

We use and analyse your information to keep in touch with you and to supply and improve our Services. Sometimes we’ll combine and anonymise this information so you won’t be identified.

In particular, we use your information for the following purposes:

  • To register you as a member or for registration to other services.
  • To undertake eligibility checks with respect to your stay at our sites.
  • To provide you with member support during your stay.
  • For the security of our business and premises.
  • To allow you to access the Services we provide.
  • To process and manage and deliver Services to you including, managing and recovering payments, fees and charges.
  • To ensure that content from our Website and App is presented in the most effective manner for you and your devices.
  • To administer and protect our business, and the Services.
  • To pass your information to other companies to supply goods, services or information requested by you and we may pass your information to them for this purpose.
  • To manage our relationship with you for example notifying you about changes to our services, or any concerns you may have.
  • To contact you with information about products, services and special offers or ask you to participate in one of our customer satisfaction surveys.
  • To use data analytics to improve the Website, App, products/services, marketing, customer relationships and experiences.
  • To make suggestions and recommendations to you about goods or services that may be of interest to you.
  • If we buy or sell any business or assets in which case we may disclose your Information to the seller or buyer of such business or assets.
  • If we are under a duty to disclose or share your personal data to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or protect the rights, property, or safety of our customers, or others.
  • To pursue our legitimate business interests (such as direct marketing, conducting market research and preventing fraud and money laundering to minimise our credit and fraud risks and protect our business).
  • We may sometimes use automated systems to analyse your information. We ensure that any service provider that we use which may make automated decisions about you based on your personal information has implemented measures to safeguard your rights and interests.
  • To contact you with events we think you may be interested in, manage your bookings for events and to provide you with event updates.
  • To better understand your likes and dislikes and enable you to interact more effectively with the community.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only: (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided within this Privacy Notice.

Who does &Soul share my personal information with?

We may disclose your personal information to certain recipients. 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.

The recipients we disclose below:

  • to our third party services providers and partners and agencies and each of their sub-contractors who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
  • we may share personal information within our corporate family of companies that are related by common ownership or control, to support us in providing our Services, our affiliates’ services or for integrating, promoting and improving our Website or our App;
  • to any other person with your consent to the disclosure.

If you choose to ‘share’ our content with friends through Facebook, Twitter or other social networks, some of your personal data might be sent to these websites. We don’t control how these social networks use your personal data, so please check those websites’ privacy policies and terms for more information about how they may use your personal data. Social media networks receive data which may include information like the website you’re visiting, the date and time you visit the website, your IP address, browser type, cookie information and other browser-related information.

Our service providers

We use a number of service providers to provide our cloud infrastructure environment and storage of our user’s personal information.

We also work with various service providers that monitor, maintain and otherwise support our Services. In order to provide this functionality these service providers may have access to your personal information (but as legally permitted).

Your data protection rights

If you wish to access, correct, update, request deletion or have any concerns regarding your personal information, you can contact us at any time using the following contact details: FF Propco 2 Limited whose registered office is at 14 Bedford Square, London, United Kingdom, WC1B 3JA.

In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided in this notice.

You have the right to opt-out of marketing communications we send you at any time. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided in this notice.

Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. In the UK this is the Information Commissioner who can be contacted through www.ico.org.uk.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Please note that email is not recognised as a secure medium of communication. For this reason, we request that you do not send private information to us by email.

International data transfers

Data and personal information that we collect from you may be transferred to, processed and stored at a destination outside the European Economic Area (“EEA”) as certain of our third-party service providers and partners operate around the world.  This means that when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.

Data retention

We retain personal information we collect from you where we have consent or an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When consent is no longer valid or we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • Send us an email at hello@andsoul.com;
  • or write to us at: FF Propco 2 Limited, 14 Bedford Square, London, United Kingdom, WC1B 3JA.

If you are unhappy about the way we have used your personal information, please let us know by emailing us at hello@andsoul.com, and we will try and resolve your complaint.  If we are unable to resolve your complaint to your satisfaction, you may lodge a complaint with the Information Commissioner’s Office.

CCTV

For the safety of our guests and members, and the prevention and detection of crime, CCTV is in operation in public, communal and shared areas of our locations.

If a government or regulatory authority or if the police or any other regulatory or government authority investigating suspected illegal activities requests CCTV images of you or any other personal information relating to you, we are obliged to comply.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.