Privacy Policy

Effective Date: 16/07/2025

At The Winkle ("we", "our", or "us"), we are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR). This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website, make a reservation, or interact with us online or in person.

1. Data Controller

The data controller responsible for your personal data is:

Owner: Owen Pickrell

The Winkle
139 Kings Road Arches, Brighton
Email: hello@thewinkle.co.uk

2. Information We Collect

We may collect the following types of personal data:

• Identity & Contact Data – Name, email address, phone number
• Reservation Data – Date, time, party size, special requests (e.g., dietary needs)
• Payment Data – Processed securely by third-party providers (we do not store card details)
• Technical Data – IP address, browser type, pages visited, and interaction history
• Marketing Preferences – When you opt-in to receive newsletters or offers

3. Lawful Basis for Processing Under GDPR

Under the UK GDPR, we process your personal data only when we have a legal basis to do so, including:

• Contractual Obligation – To manage bookings, respond to your enquiries, or provide dining services
• Consent – When you sign up to receive marketing emails or newsletters
• Legitimate Interests – To improve our website, services, and customer experience
• Legal Obligation – To comply with financial or regulatory duties (e.g., transaction records)

You may withdraw your consent at any time by contacting us at: hello@thewinkle.co.uk

4. How We Use Your Data

We use your personal information to:

• Confirm and manage reservations
• Respond to questions or feedback
• Send booking confirmations or service updates
• Send promotional emails if you have opted in
• Improve our website and customer experience
• Comply with legal and financial record-keeping requirements

5. Data Sharing & Third Parties

We do not sell or rent your personal data. 

We only share it with:

• Service Providers – Such as our booking system, payment gateway, or website host
• Email Marketing Tools – Only if you have opted in to communications
• Regulators or Legal Authorities – If required by law or for fraud prevention

All third parties are required to comply with GDPR and maintain the confidentiality of your data.

6. International Data Transfers

We aim to store and process your data within the UK or the European Economic Area (EEA). If data is transferred outside of the EEA, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses or similar mechanisms).

7. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right to Access – You can request a copy of the data we hold about you
• Right to Rectification – You can ask us to correct inaccurate or incomplete data
• Right to Erasure – You can request deletion of your data (where legally permissible)
  
  
• Right to Object – You can object to certain types of processing, including direct marketing
• Right to Data Portability – You can request a copy of your data in a portable format
• Right to Withdraw Consent – You may withdraw consent to marketing or other optional uses at any time

To exercise any of these rights, please contact us at: hello@thewinkle.co.uk

If you believe we have not handled your data properly, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO): www.ico.org.uk

8. Cookies & Website Tracking

We use cookies to enhance site performance and personalize content. You will be asked to accept or decline cookies when you first visit our site. You can also manage your preferences in your browser settings.

9. Data Retention

We keep your data only as long as necessary for the purpose it was collected:

• Booking data – Retained for up to 12 months
• Marketing consent – Retained until you unsubscribe
• Financial records – Retained for up to 7 years (legal requirement)

10. Data Security

We implement appropriate security measures (such as encrypted communications and access controls) to protect your data from loss, misuse, or unauthorised access.

11. Children’s Privacy

Our services are not intended for individuals under 16 years of age, and we do not knowingly collect personal data from minors.

12. Updates to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on our website with the effective date updated accordingly.

13. Contact Us

If you have questions about this policy or how your data is handled, please contact:

The Winkle
139 Kings Road Arches, Brighton
Email: hello@thewinkle.co.uk