Privacy

Privacy Policy
Effective date: October 23, 2019

1. WHO ARE WE?

This app or website (“Site”) is operated by Redsip Inc., a Dalaware corporation with its principal place of business at 3165 Olin Avenue, San Jose, CA95117, USA. You can contact us as indicated under the “Contact” section below.
The data controller responsible for your personal data is Redsip Inc., the company with whom you contract as a customer, mobile user, member or membership applicant (“Redsip”, “we”, “us” and/or “our”).

2. WHAT IS THIS PRIVACY POLICY IS FOR?

This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site or as a membership applicant, member or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which became applicable to us and you as of 23 Oct 2019.
‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified.
By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

3. PERSONAL DATA WE COLLECT

We collect the following personal data about you:
• Membership Application: The personal details you provide when submitting a membership application. This includes your name, e-mail address; and phone number; gender; country; a picture of yourself; information about your wine drinking activities and other information that you elect to provide to support your application and to give you a customized experience on the Site.
• Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with this Site or any other websites we operate, and personal data that you provide to us when you visit our Site. We can also combine personal data that you provide to us with other information we collect about you when you make a reservation through third-party services such as online restaurant-reservation or travel fare aggregator websites, as necessary to process your requests.

4. AUTOMATICALLY COLLECTED PERSONAL DATA

• Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
• Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features. For detailed information on the cookies and similar technologies we use, please see our Cookie Policy in the Appendix.

5. HOW WE USE YOUR PERSONAL DATA

We use your personal data in the following ways:
• To acknowledge, confirm and deal with your membership/user application. Such use of your data is necessary in order to implement your request to become a member/user.
• Where you are a member, provide you with membership services, administer your membership account and contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.
• To contact you in connection with user/customer/member surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.
• Redsip may provide you, or permit selected third party service providers to provide you, with information about goods or services, events and other promotions we feel may interest you as a member or membership applicant. We (or such third party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.
• As necessary for certain legitimate business interests, which include the following:
o where we are asked to deal with any enquiries or complaints you make.
o to administer our Site, to better understand how visitors interact with our websites and ensure that
our Site is presented in the most effective manner for you and for your computer/device.
o to conduct analytics to inform our marketing strategy and enable us to enhance and personalize the
experience we offer to our members and our communications, including by creating customer or member
profiles to enable personalized direct marketing communications.
o to provide postal communications which we think will be of interest to you.
o if you ask us to delete your data or to be removed from our marketing lists and we are required to
fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
o to share personal data within our organization for administrative purposes, for providing membership
services and in relation to our marketing activities.
o we may anonymize, aggregate and de-identify the data that we collect and use such anonymized,
aggregated and de-identified data for our own internal business purposes, including sharing it with
our current and prospective members, business partners, our affiliated businesses, agents and other
third parties for commercial, statistical and market research purposes, for example to allow those
parties to analyze patterns among groups of people, and conducting research on demographics,
interests and behavior.
o for internal business/technical operations, including troubleshooting, data analysis, testing,
research, statistical and survey purposes and as part of our efforts to keep our Site, network and
information systems secure.
o to (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce
our Site rules; (d) protect our operations or those of any of our affiliated businesses; (e) protect
our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f)
enforcing or defending legal rights, or preventing damage.
• We may use your personal data for other purposes which you have consented to at the time of providing your data.
As used in this Privacy Policy, “legitimate interests” means the interests of Redsip and our affiliated businesses in conducting and managing our organization. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).

6. DISCLOSURE OF YOUR INFORMATION

We share your personal data with third parties in the following situations:
• Redsip Affiliated Businesses: We operate on a global scale. In order to provide the services you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including to offer products and services to you. Our affiliated businesses will only use your data for the purposes for which we originally collected it.
• Business Transfers: if we sell our business or our company assets are acquired by a third party personal data held by us about our members, membership applicants or customers may be one of the transferred assets.
• Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms & Conditions, Site Rules or other applicable contract terms that you are subject to or (iii) to protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organizations.

7. PERSONAL DATA TRANSFERS

Your personal data will be transferred to and stored in countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area (“EEA”), to our service providers and affiliated businesses for the purposes described above.
Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where we transfer your personal data to countries outside of the EEA we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service providers’ Privacy Shield certification or implementing standard contractual clauses for data transfers. We have implemented data transfer agreements pursuant to applicable data protection law in order to implement appropriate safeguards for the transfer of personal data to Soho House group companies in countries outside the EEA. If you would like to receive more information on the safeguards that we implement, including copies of relevant data transfer contracts, please contact us as indicated below.

8. CHILDREN

The Site is not directed to children who are under the age of 13. We do not knowingly collect personal data from children who are under 13. If you have reason to believe that a child under the age of 13 has provided personal data to us through the Site please contact us and we will endeavor to delete that information from our databases.

9. SECURITY

Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else.
Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organizational security measures to protect the personal data that you submit to us against unauthorized/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

10. PERSONAL DATA RETENTION

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for six years after expiration or termination of your membership. We retain information submitted through the Site and the other websites we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.
To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

11. YOUR PERSONAL DATA PROTECTION RIGHTS

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:
• Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
• Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your personal data, and we will do so:
o If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or
o If we are processing your personal data for direct marketing.
• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the supervisory authority, in particular in the Member State of your habitual residence.
If you wish to exercise any of these rights please contact us as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.

12. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.

13. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to info@redsip.co

Appendix – Cookie Policy

This cookie policy (“Cookie Policy”) describes the cookies that Redsip and its affiliated businesses (“we”, “us” and/or “our”) use on our respective websites (each a “Site”) and the choices that you have. This Cookie Policy forms part of the privacy policy of each of Soho House and its affiliated businesses. Please refer to the privacy policy for the relevant business for information about (i) the purposes for which we use your personal data and our lawful basis for processing it, (ii) how we protect your data, and (iii) your rights and our obligations in relation to such use.

Cookies and other technologies

A cookie is a piece of information sent to your browser from a website and stored on your computer’s hard drive. Cookies can help a website like ours recognize repeat users and allow a website to track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. For more details on cookies and similar technologies please visit All About Cookies.
Cookies can be stored on your computer for different periods of time. “Session cookies” only last for as long as the browser session and are deleted automatically once you close your browser. “Persistent cookies” cookies survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again.
The Site uses first party cookies (cookies set directly by us and are essential for using and navigating our services) as well as third-party cookies, as described below.
We also use pixel tags (usually in combination with cookies), from the third parties described below, to get information about your usage of the Site and our services. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.

Types of Cookies Used

Type: Strictly Necessary; Session

Description: We use cookies that are strictly necessary to provide you with services available through our Site and to use some of its features, such as the ability to log-in and access to secure areas as well as the ability to make payments. These cookies are essential for using and navigating the Site. Without these cookies, basic functions of the Site would not work. We use session cookies to help our Site remember what you have selected on previous pages, avoiding the need to re-enter information. These cookies are temporary and expire once the browser is closed.
• Payments Engine
• Current Branch
• Identity Service
• Identity Session
• Original URL
Opt Out: Because these cookies are strictly necessary to deliver the Site and our services, you cannot refuse them.

Type: Analytics / Performance; Persistent

Google Analytics: Google Analytics helps understand how visitors use the Site. Google, Inc. (“Google”) will use this information on our behalf to evaluate your use of the Site, compile reports on Site activity and similar data relating to use of the. Your IP address and other information collected by this cookie will be sent to and stored by Google on servers in the United States. To learn how Google uses data collected on our Site, visit https://policies.google.com/privacy/partners?hl=en-GB&gl=uk. Learn more on the individual cookies and their expiration at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
Intercom: Cookies from Intercom allow us to track usage across most of our Site. Expiration of these cookies depends on the cookies used (generally, between 1 week and 1 year). Learn more here: https://www.intercom.com/terms-and-policies#privacy.
Bing: These analytics cookies, provided by Microsoft, Inc. are used to collect information about how visitors use our Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. These cookies expire after 1 year. Learn more here: https://privacy.microsoft.com/en-gb/privacystatement
Opt Out: You can block or delete cookies by changing the browser settings as explained under the “Your Choices” section below. To opt out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Type: Functionality; Persistent

Empathy Broker: Many of our Sites allow you to search for content on the Site. We use cookies from Empathy Broker to enable our search functionality. Expiration of these cookies depends on the cookies used (generally, between 1 hour and 3 years). Learn more here: https://www.empathybroker.com/privacy-policy/
Spotify: Some of our websites embed playlists from Spotify. When visiting any of our pages with a Spotify playlist, these cookies may be presented. Expiration of these cookies depends on the cookies used (generally, between 1 day and 2 months). Learn more here: https://www.spotify.com/uk/legal/privacy-policy/
YouTube: Some of our websites embed videos or include links from YouTube. When visiting any of our pages with content from YouTube these cookies may be presented. Expiration of these cookies depends on the cookies used (generally, between 6 months – 2 years). Learn more here: https://policies.google.com/technologies/types
Open Table: We use OpenTable to give you the ability to make bookings online at our restaurants. The cookies from OpenTable allow us to provide this functionality. Learn more here https://www.opentable.com/legal/privacy-policy
Dropbox: Our careers website allows you to upload files from Dropbox. Because we integrate Dropbox into our website, these cookies may be presented on some pages our website. Expiration of these cookies depends on the cookies used (generally, between 1 day – 5 years). Learn more here https://www.dropbox.com/en_GB/privacy
Vimeo: Some of our websites embed videos from Vimeo. When visiting any of our pages with content from Vimeo these cookies may be presented. They expire after 2 years. Learn more here https://vimeo.com/privacy
Wufoo: We use Wufoo to build some of the forms on our websites. The cookies from Wufoo allow us to use this functionality. Expiration of these cookies depends on the cookies used (generally, between 3 months – 1 year). Learn more here https://www.surveymonkey.com/mp/legal/privacy-policy/
Opt Out: You can block or delete cookies by changing the browser settings as explained under the “Your Choices” section below.

Type: Advertising; Persistent

Facebook: Facebook helps you stay in touch with your network through your website/mobile application. Because we include a link for you to view our Facebook profiles via our Site, Facebook includes an advertising cookie on the Site. These cookies expire after 2 months. Learn more here: https://www.facebook.com/policies/cookies/
DoubleClick: Enables Google and its partners to serve ads to you based on your visit to our Site. Learn more about Google’s privacy practices here: http://www.google.com/intl/en/policies/privacy/.
Twitter: Twitter provides real time updates from across the globe on the latest trending stories, ideas and opinions from the Twitter accounts or hashtags that you choose to follow. We make it easier for you to share our website content over Twitter. Learn more here: https://twitter.com/en/privacy
Opt Out: You can block or delete cookies by changing the browser settings as explained under the “Your Choices” section below. The providers listed below also offer direct opt-out functionalities:
Facebook: To opt out, please visit https://www.f.acebook.com/help/769828729705201.
DoubleClick: You may opt out of personalised advertising by visiting Google’s Ads Settings at the following link: https://adssettings.google.com/authenticated. You can also prevent your data from being collected by DoubleClick on our Site by downloading and installing the DoubleClick Opt-out Browser Add-on for your current web browser at the following link: https://support.google.com/ads/answer/7395996.

Your Choices

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Cookie Settings in Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Cookie Settings in Firefox: https://support.mozilla.com/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
Cookie Settings in Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Cookie Settings in Safari
o iPad/iPhone: https://support.apple.com/en-gb/HT201265
o macOS: https://support.apple.com/kb/ph21411?locale=en_US
Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

Changes

We may change the type of third party service providers that place cookies on the Site and amend this Cookie Policy at any time by posting the amended version on the Site. Unless additional notice or consent is required by applicable laws, this will serve as your notification of these changes.

Contact Us

If you have any questions or concerns, please contact Redsip and the affiliated businesses you engage with at info@redsip.co