Soho House & Co

Privacy policy

1. Who are we*?

This website (*'Site') is operated by Soho House UK Limited, a company registered in England and Wales under registration number 02864389 (*'Soho House', *'we', *'us' and/or *'our'). Our registered address is 180 Strand, London, WC2R 1EA. You can contact us as indicated under the 'Contact' section below.

The business responsible for your Personal Information is the Soho House company with whom you contract as a customer, member or membership applicant (*'Soho House', *'we', *'us' and/or *'our').

2. What is this privacy policy** for?

This privacy policy (**'Policy') applies to Personal Information that we collect from you as a user of this Site or as a membership applicant, member, customer, or guest ('you' or 'your' being interpreted accordingly). It provides information on (1) the Personal Information that we collect and how we use and disclose that information and (2) the privacy rights California residents may have relating to their Personal Information under the California Consumer Privacy Act ('CCPA') and how those rights can be exercised.

‘Personal Information’ as used in this Policy means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or, if required by applicable law, a household. All other capitalized but undefined terms shall have the meanings assigned to them in applicable laws.

By using our Site or submitting your Personal Information you are taken to accept the terms of this Policy, so please read these documents carefully. If you do not agree to this Policy, please do not access the Site or otherwise submit Personal Information to us.

3. Personal Information collection, use and disclosure

The following describes (1) the categories and sources of Personal Information we collect, (2) examples of the types of information that fall within each category of Personal Information collected, (3) how we use each category of Personal Information, and (4) how we disclose Personal Information.

Contact information:

Categories and sources of Personal Information

We collect this type of information from:

• You, such as when you sign up for our newsletter, request informational material, create an account, make a purchase, or contact customer service.

• Third-party services, such as online restaurant-reservation or travel-fare aggregator websites, when you make a reservation through the third party.

• Other third-party partners, such as brands with which we are collaborating or co-hosting events.

Representative data elements

Data elements in this category include name, address, email address; business address and phone number; gender, and date of birth.

We may also collect Contact Information for related persons, such as your family members, guests, or authorized users of your account.

Purpose for collecting, using, and sharing the Personal Information

We use Contact Information to identify you and communicate with you, including:

• To process your membership application;

• To process fee subscriptions;

• To process, confirm, and fulfill bookings at our hotels, spas, gym classes, and events;

• To process your purchases through our retail Sites;

• To send transactional messages (such as order confirmations and account information);

• To send you surveys, marketing communications, promotional offers, and other information you’ve requested;

• To personalize our communications;

• To provide customer service;

• For our everyday business purposes in accordance with the law, such as for legal and other information you’ve requested;

• To personalize our communications;

• To provide customer service;

• For our everyday business purposes in accordance with the law, such as for legal and regulatory compliance, security and fraud detection, and/or to enforce our rights.

Categories of other entities to whom Personal Information is disclosed

We may disclose Contact Information to:

• The 'Soho House group family of companies': sohohouse.com/our-businesses;

• Our partners to whom you’ve instructed us to send your information so they can communicate with you;

• Vendors who match and serve our targeted advertisements on social media platforms and other third-party websites;

• Our Service Providers that maintain our customer database; provide data storage processing; send communications on our behalf; prepare, ship and deliver your orders; help improve your online experience; process your payments; and provide fraud monitoring and detection services.

Government identification information:

Categories and sources of Personal Information

We may collect this type of information from you, if provided in connection with your membership application.

Representative data elements

Data elements in this category may include a copy of your passport, driver’s license or birth certificate.

Purpose for collecting, using, and sharing the Personal Information

We may collect Government Identification Information in order to allow us to verify whether you are eligible to the reduced under 27 years membership fee, in accordance with the House Rules (available 'here': sohohouse.com/terms-and-conditions/house-rules).

Categories of other entities to whom Personal Information is disclosed

We may disclose Government Identification Information to the Soho House group family of companies and to our Service Providers that maintain our customer database, provide data storage processing, and provide fraud monitoring and detection services.

Technical information:

Categories and sources of Personal Information

We collect this type of information from:

• You and your computer or devices when you interact with the Site. For example, when you visit our Sites, our server logs record your IP address and other information;

• Automatically, via technologies such as cookies, web beacons, and pixels, when you visit our Sites;

• Third parties, including analytics providers and advertising partners who place cookies, web beacons, pixels, and other tracking technology on the Sites.

For detailed information on the cookies and similar technologies we use, and to opt out of the use of certain cookies, please see our Cookie Policy.

Representative data elements

Data elements in this category include IP address, device identifiers and characteristics, location information, browser type and settings, the date and time of your request, and other information regarding the interaction with our Sites.

Purpose for collecting, using, and sharing the Personal Information

We use Technical Information:

• To identify you and your computer or device and remember your preferences;

• To improve our online services, our products and your browsing experience;

• To measure the effectiveness of our marketing and advertising campaigns;

• For our everyday business purposes, in accordance with the law, such as for legal and regulatory compliance, security and fraud detection, and/or to enforce our rights.

Categories of other entities to whom Personal Information is disclosed

We may disclose Technical Information to:

• The Soho House group family of companies;

• Vendors who match and serve our targeted advertisements on social media platforms and other third-party websites;

• Our Service Providers that provide data storage processing, advertising and traffic analytics, and help improve your online experience.

Relationship information:

Categories and sources of Personal Information

We collect this type of information from:

• You, when you interact with us or our Sites;

• Third parties that provide access to information you make publicly available, such as social media.

Representative data elements

Data elements in this category include:

• Personal and household characteristics, demographic data, and preferences, such as your age range, gender, marital and family status, hobbies and interests;

• Membership, loyalty and rewards program data;

• Household demographic data;

• Education, employment, and professional information;

• Social-media engagement.

Purpose for collecting, using, and sharing the Personal Information

• To administer your membership with us;

• To personalize our communications;

• To conduct analytics to inform our marketing strategies;

• To improve our services and products and your browsing experience;

• For our everyday business purposes, in accordance with the law, such as for legal and regulatory compliance, security and fraud detection, and/or to enforce our rights.

Categories of other entities to whom Personal Information is disclosed

We may disclose Relationship Information to:

• The Soho House group family of companies;

• Vendors who match and serve our targeted advertisements on social media platforms and other third-party websites;

• Our Service Providers that maintain our customer database, provide data storage processing, and send communications on our behalf.

Transaction and reservation information:

Categories and sources of Personal Information

We collect this type of information from you when you stay with us, visit our spas or gyms, shop on our Sites, or otherwise interact with us.

Representative data elements

Data elements in this category include:

• Your booking and reservation history;

• Your purchase history.

Purpose for collecting, using, and sharing the Personal Information

We use Transaction and Reservation Information:

• To fulfill our business relationship with you, including processing, confirming, and fulfilling your reservations and orders;

• To provide customer service and ensure your satisfaction;

• To administer your membership;

• To personalize our communications;

• To conduct analytics to inform our marketing strategies;

• For fraud monitoring and detection purposes;

• For our everyday business purposes, in accordance with the law, such as for legal and regulatory compliance and/or to enforce our rights.

Categories of other entities to whom Personal Information

We may disclose Transaction and Reservation Information to the Soho House group family of companies and to our Service Providers that:

• Maintain our customer database;

• Provide data storage processing;

• Send communications on our behalf;

• Prepare, ship and deliver your orders;

• Help improve your online experience;

• Process your payments;

• Provide fraud monitoring and detection services.

Financial information***:

Categories and sources of Personal Information

We collect this type of information from:

• You;

• Payment processors and other financial institutions.

***We do not directly collect or process your Financial Information; it is collected directly by our payment services provider. See the Payment Information section below for more information regarding our handling of Financial Information.

Representative data elements

Data elements in this category include payment card information and bank account number and details (if you use automated payments).

Purpose for collecting, using, and sharing the Personal Information

We use Financial Information:

• To record and process your membership application and administer your membership;

• To fulfill our relationship with you, including recording and processing your membership application, administering your membership, and processing your purchases, orders and reservations;

• For fraud monitoring and detection purposes;

• For our everyday business purposes, in accordance with the law, such as for legal and regulatory compliance and/or to enforce our rights.

Categories of other entities to whom Personal Information is disclosed

Financial Information, which is directly collected by our payment services processor, may be disclosed to the Soho House group family of companies for the same purposes for which it was collected and used.

Audio/Visual information:

Categories and sources of Personal Information

We collect this type of information from:

• You, when you provide photographs as a part of your membership application;

• Automatically, such as when we use CCTV cameras in our facilities;

• Third parties that provide access to information you make publicly available, such as social media.

Representative data elements

Data elements in this category include photographs and video images of you or your family.

Purpose for collecting, using, and sharing the Personal Information

We use Audio/Visual Information for security and fraud monitoring and detection purposes, as well as for our everyday business purposes, in accordance with the law, such as for legal and regulatory compliance and/or to enforce our rights.

Categories of other entities to whom Personal Information is disclosed

We may disclose Audio/Visual Information to the Soho House group family of companies and to our Service Providers that maintain our customer database, provide data storage processing, and provide security and fraud monitoring and detection services.

Please note that we may also share each of the categories of Personal Information above (1) if we sell our business or our company assets to a third party or (2) if we need to (i) comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process; (ii) enforce our Terms & Conditions, House rules or other applicable contract terms to which you are subject; or (iii) protect us, our members, membership applicants, or contractors against loss or damage.

We may anonymize, aggregate and de-identify the data that we collect; this anonymized, aggregated and de-identified data is no longer Personal Information. We may use this 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.

4. Payment information

Any credit/debit card payments and other payments you make through our Site will be processed by our third-party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.

We may arrange that card or payment data you submit in support of a membership application or subscription fee is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful. If you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription.

We store and use this card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.

You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee or for the purpose of making any future purchases.

5. Tracking and Do Not Track Disclosures

Please be advised that parties other than Soho House may collect Personal Information about the online activities of the users of our Site over time and across different websites when a consumer uses our Site.

Do Not Track ('DNT') is a privacy preference you can set in most browsers. If you enable DNT on your browser, we will honor your request not to be tracked across the Internet. For more information, including how to turn on DNT, visit allaboutdnt.com.

6. Children

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

7. Security

Where we have given you (or where you have chosen) a password or login 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 login 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 Information that you submit to us against unauthorized/unlawful access or loss, destruction or damage, although we cannot 100 per cent guarantee the security of Personal Information that you provide to us online.

8. Personal Information retention

We will keep your Personal Information 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 Information, we consider the amount, nature, and sensitivity of the Personal Information, the purposes for which we process your Personal Information, 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 Information in accordance with applicable laws and regulations. In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.

9. Your privacy rights

Certain applicable data protection laws give you specific rights in relation to your Personal Information. In particular, if you are a California resident and the processing of your Personal Information is governed by the CCPA, subject to applicable exceptions, you have the following privacy rights in relation to your Personal Information we have collected:

• The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information.

• The right to request deletion of your Personal Information.

• The right to opt-out: We do not and will not sell your Personal Information but we may share your Personal Information (including your Contact Information, Technical Information, and Relationship Information) with social media platforms and other advertising partners that will use that information to match and serve our targeted advertisements on the social media platforms and other third-party websites. We do not control and are not responsible for the social media platforms’ or advertising partners’ processing of your Personal Information. You can opt out of this sharing on a vendor-by-vendor basis here. You can also opt out of our use of your Personal Information for targeted advertising purposes by [emailing privacy@sohohouse.com] / [clicking here].

• The right to be free from discrimination relating to the exercise of any of your privacy rights.

Exercising Your Rights: California residents can exercise the above privacy rights by emailing us at privacy.policy@sohohouse.com.

Verification: In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents: You may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, the agent must provide signed, written permission to act on your behalf and you may also be required to independently verify your identity with us.

10. Changes to our privacy policy

Any changes we may make to this 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 significant changes to this Policy.

11. Last updated

This Policy was last updated on 1 January, 2020.

12. Contact

Questions, comments or requests regarding this Policy should be addressed to privacy.policy@sohohouse.com

Germany privacy policy

1. WHO ARE WE?

This website ("Site") is operated by Soho House UK Limited, a company registered in England and Wales under registration number 02864389 ("Soho House", "we", "us" and/or "our"). Our registered address is 180 The Strand, London, United Kingdom, WC2R 1EA. You can contact us as indicated under the "Contact" section below.

The data controller responsible for your personal data is the Soho House company with whom you contract as a customer, member or membership applicant ('Soho House', 'we', 'us' and/or 'our') and our group data controller is Soho House Bond Limited, a company registered in Jersey under registration number 112133.

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 25 May 2018.

'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, address, e-mail address; business address and phone number; gender and date of birth; country; a picture of yourself; information about your work and other information that you elect to provide to support your application. If you are under 27 years old, we will require you to attach to your application a copy of your passport, driver's license or birth certificate in order to allow us to verify whether you are eligible to the reduced under 27 years membership fee, pursuant to the House Rules (available here). We also collect information about your debit/credit card and bank account information provided by you to our payment service providers, that we require for the purpose of recording and processing your membership application (and administering your membership). For further details please also refer to the section below headed "Payment Information".

Reservation Information: Guest information, such as your first and last name, email address, billing and payment information (for further details please also refer to the section below headed "Payment Information"). Personal data collected in relation to reservations will be processed in accordance with a privacy policy provided at the time of requesting a reservation so please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect or process your personal data.

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 one of our clubs or other premises. 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.

5. HOW WE USE YOUR PERSONAL DATA

We use your personal data in the following ways:
To acknowledge, confirm and deal with your membership application (and where necessary put you on our waiting list). Such use of your data is necessary in order to implement your request to become a member.

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 complete and fulfill your reservation and stay, for example, to process your payment, ensure that your room is available, and provide you with related customer service, including sending confirmations or pre-arrival messages, assist you with meetings, events or celebrations. Such use is necessary 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.

Soho House and the Soho House family 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 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 that of the Soho House family and enable us and the Soho House family to enhance and personalise the experience we offer to our members, customers and our communications, including by creating customer or member profiles to enable personalised 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 among the Soho House family for administrative purposes, for providing membership services and in relation to our sales and marketing activities.

o we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, the Soho House family, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse 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; © enforce our House Rules; (d) protect our operations or those of any of the Soho House family; (e) protect our rights, safety or property, and/or that of the Soho House family, 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 Soho House and the Soho House family in conducting and managing our organisation. 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:

Service Providers: Soho House, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members, (iv) web analytics providers, (v) providers of digital advertising services and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Soho House Family Businesses: We operate on a global scale. In order to provide the services you request from us, the Soho House family may access and process the information which we collect from you for the purposes described above, including to offer products and services to you. The Soho House family 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, House 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 organisations.

7. PAYMENT INFORMATION

Any credit/debit card payments and other payments you make through our Site will be processed by our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we do not ourselves directly process or store the debit/credit card data that you submit.

We may arrange that card or payment data you submit in support of a membership application or subscription fee is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful (or if you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription).

We store and use this card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.

You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee or for the purpose of making any future purchases.

8. 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 the Soho House family 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.

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 organisational security measures to protect the personal data that you submit to us against unauthorised/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 anonymise 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.

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 rectification:

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 erasure:

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 restrict processing:

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 data portability:

You may ask us at any time to stop processing your personal data, and we will do so:Right to object:
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.

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 withdraw consent:

If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns (you may find EU Data Protection Authorities' contact information here.)Right to lodge a complaint with the data protection authority:

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

or to our Data Protection Officer at:privacy.policy@sohohouse.comQuestions, comments or requests regarding this Privacy Policy should be addressed to

Datenschutzbeauftragter:
Eva Gaertner – CompanyCheck Deutschland GmbH
Schillerstrasse 47/49
22767 Hamburg
040-540903150
datenschutz@companycheck-deutschland.de

Turkish privacy policy

1. WHO ARE WE?

This website ('Site') is operated by Soho House UK Limited a company registered in England and Wales under registration number 02864389 and its registered address is 180 The Strand, London, United Kingdom, WC2R 1EA for the operation of Corpera Turizm Yatırımları Anonim Şirketi ('Soho House Istanbul'), a company registered in Turkey under registration number 654893/0 and our registered address is Evliya Çelebi Mah. Meşrutiyet Cad. No.56 Beyoğlu/Istanbul. Soho House Istanbul will be referred to as 'we' 'us' and 'our' being interpreted accordingly.

2. WHAT IS THIS PRIVACY POLICY FOR?

We may record your personal data, store it, share it with third parties in accordance with the framework set out under the Law on the Protection of Personal Data ('Law') and process it in other forms permitted by the Law. This Privacy Policy gives you information about how personal data and other private information 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) will be used by us, the Law and your rights under the Law. When we refer to ‘personal data’ in this Policy it 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 Policy, so please read it carefully.

3. GENERAL INFORMATION ABOUT THE LAW

The Law on the Protection of Personal Data No. 6698 adopted on 24 March 2016 published at the Official Gazette No. 29677 dated 7 April 2016 has come into force at the date of its publication. The purpose of this Law is to protect the fundamental rights and freedoms of persons, privacy of personal life in particular, while personal data are processed, and to set forth obligations of natural and legal persons who process personal data and procedures and principles to comply with for the same.

4. INFORMATION ON DATA CONTROLLER

As Soho House Istanbul, we will use your personal data in compliance with the relevant legislation as a data controller under the Law. The data controller responsible for your personal data is the Soho House company with whom you contract as a customer, member or membership applicant ('Soho House', 'we', 'us' and/or 'our') and our group data controller is Soho House Bond Limited, a company registered in Jersey under registration number 112133.

5. WHAT PERSONAL DATA MAY WE COLLECT?

We may collect the following personal data about you: The personal details you provide, such as name, address, email address, business address, phone number and photograph when submitting a membership application; information about your debit/credit card and bank account information that we require for the purpose of recording and processing your membership application and administering your membership (for further details, please refer to the section below headed Payment Information); and personal details you choose to give when corresponding with us by phone, email or that you provide to us when you visit one of our clubs or other premises. We may also receive other personal or private information about you that you choose to submit to this Site or any other websites we operate.

6. COOKIES

Our Site uses cookies 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 we use, please see our Cookie Policy.

7. HOW YOUR PERSONAL DATA IS PROCESSED

Any operation performed upon personal data such as collection, recording, storage, preservation, disclosure, transfer, retrieval, making available for collection or categorisation of your personal data that you share with us by wholly or partly automatic means (or otherwise than by automatic means), which form part of a filing system may be carried out by us pursuant to the Law as a data controller. We may use your personal data including, but not limited to, the following ways: – to acknowledge, confirm and deal with your membership application (and where necessary put you on our waiting list). – where we are asked to deal with any enquiries or complaints you make. – to provide you with membership services and administer your membership account. – we may provide you, or permit selected third-party service providers (e.g. our on-premises gym providers) to provide you with information about goods or services we feel may interest you as a member or membership applicant. We will contact you by electronic means (such as e-mail or SMS) with information about goods and services that are similar to those which you previously purchased from us (or tried to purchase).

8. WHAT ARE THE PURPOSES AND LEGAL REASONS OF PROCESSING YOUR PERSONAL DATA?

We will process your personal data you share with us pursuant to the Law and applicable legislation in order to conduct our services that we provide to you in accordance with the requirements of the agreement and technology and to improve our goods and services that we offer to you.

9. INFORMATION ON PERSON OR INSTITUTIONS WHO WE CAN TRANSFER YOUR PERSONAL DATA

For the purposes set out above, the persons / organizations and their affiliates to whom your personal data you share with us may be transferred; our main shareholders, our direct / indirect domestic / foreign subsidiaries; program partner organizations, domestic / foreign organizations that we receive services to conduct our activities and we have business cooperation and other third persons. We may share your personal data with third parties. For example, in the following situations: we may make your personal data available to selected third parties who act on our behalf to support our operations (card processing or payment services; for further details, see the section below headed Payment Information) and credit reference agencies to protect against possible fraud; our IT suppliers and contractors (e.g. data hosting providers or delivery partners) may need to have access to your personal information to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members; if we sell our business or our company assets are acquired by a third party, personal data held by us about our members or customers may be one of the transferred assets; if we need to disclose your personal data to comply with a legal obligation or to enforce our General Terms & Conditions, membership rules or other applicable contract terms that you are subject to; and to protect us, our members or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

10. PAYMENT INFORMATION

Any credit/debit card payments and other payments you make through this Site will be processed by our third-party payment provider and the payment data you submit will be securely stored and encrypted by our payment service provider using up to date industry standards. We may arrange that card or payment data you submit in support or a membership application or subscription is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful (or if you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription). We may also store and use this card or payment information for the purpose of processing any future payments that you make as a member for renewals and additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.

11. SECURITY

The personal data other than payment information that we collect from you may be transferred to and stored by the program partner organisations, domestic/foreign organisations that we receive IT support services and we have business cooperation. In accordance with applicable law, we will do everything we reasonably can to make sure that those subcontractors comply with appropriate security standards to protect the personal data that they handle. Please note that foreign countries may not provide the same legal standards for protection of your personal data that you have in Turkey. By submitting your personal data, you agree to the transfer and processing of your personal data abroad for the purposes set out in this Privacy Policy. Where we have given you (or where you have chosen) a password or login 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. We must not to share your password or login 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 organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100 per cent guarantee the security of data that you provide to us online.

12. YOUR DATA PROTECTION RIGHTS

Article 11 of the Law has entered into force on 7 October 2016 and your rights as per relevant article after this date are as follows:
Everyone, in connection with herself/himself, has the right to; a) Learn whether or not her/his personal data have been processed; b) Request information as to processing if her/his data have been processed; c) Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose; d) Know the third parties in the country or abroad to whom personal data have been transferred; e) Request rectification in case personal data are processed incompletely or inaccurately; f) Request deletion or destruction of personal data within the framework of the conditions set forth under article 7; g) Request notification of the operations made as per indents (e) and (f) to third parties to whom personal data have been transferred; h) Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems; i) Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data, by applying to the data controller. If you wish to exercise any of these rights please contact us as described in the Contact section below. Any access request may be subject to a small fee to meet our costs. We may also need to ask you for further information to verify your identity before we can respond to any request.

13. 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.

14. CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to istanbul.membership@sohohouse.com or, by post, to our privacy officer at the above address.

US privacy policy

1. Who are we?

This website ( "Site" ) is operated by Soho House UK Limited, a company registered in England and Wales under registration number 02864389 ( "Soho House" , "we" , "us" and/or "our" ). Our registered address is 180 Strand, London, WC2R 1EA. You can contact us as indicated under the "Contact" section below.

The business responsible for your Personal Information is the Soho House company with whom you contract as a customer, member or membership applicant ( "Soho House" , "we" , "us" and/or "our" ).

2. What is this privacy policy is for?

This privacy policy ( "Policy" ) applies to Personal Information that we collect from you as a user of this Site or as a membership applicant, member, customer, or guest ( "you" or "your" being interpreted accordingly). It provides information on (1) the Personal Information that we collect and how we use and disclose that information and (2) the privacy rights California residents may have relating to their Personal Information under the California Consumer Privacy Act ( "CCPA" ) and how those rights can be exercised.

'Personal Information' as used in this Policy means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or, if required by applicable law, a household. All other capitalized but undefined terms shall have the meanings assigned to them in applicable laws.

3. Personal information collection, use, and disclosure

CONTACT INFORMATION

Categories and Sources of Personal Information

We collect this type of information from:

You, such as when you sign up for our newsletter, request informational material, create an account, make a purchase, or contact customer service.

Third-party services, such as online restaurant-reservation or travel-fare aggregator websites, when you make a reservation through the third party.

Other third-party partners, such as brands with which we are collaborating or co-hosting events.

Representative Data Elements

Data elements in this category include name, address, email address; business address and phone number; gender, and date of birth.

We may also collect Contact Information for related persons, such as your family members, guests, or authorised users of your account.

Purpose for Collecting, Using, and Sharing the Personal Information

We use Contact Information to identify you and communicate with you, including:

To process your membership application; To process fee subscriptions; To process, confirm, and fulfil bookings at our hotels, spas, gym classes, and events; To process your purchases through our retail Sites; To send transactional messages (such as order confirmations and account information); To send you surveys, marketing communications, promotional offers, and other information you’ve requested; To personalise our communications; To provide customer service; For our everyday business purposes in accordance with the law, such as for legal and other information you’ve requested; To personalise our communications; To provide customer service; For our everyday business purposes in accordance with the law, such as for legal and regulatory compliance, security and fraud detection, and/or to enforce our rights. Categories of Other Entities to Whom Personal Information is Disclosed We may disclose Contact Information to: The

Israeli Privacy policy

1. Who are we?

This website ('Site') is operated by Soho House UK Limited, a company registered in England and Wales under registration number 02864389 ('Soho House', 'we', 'us' and/or 'our'). Our registered address is 180 The Strand, London, United Kingdom, WC2R 1EA. You can contact us as indicated under the 'Contact' section below.

2. What is this privacy policy 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 Israeli Protection of Privacy Law 1981.

'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. The personal data collect

We collect the following personal data about you:

Membership application
The personal details you provide when submitting a membership application and when you register through the Site. This includes your name, address, email address; business address and phone number; gender and date of birth; country; a picture of yourself; information about your work and other information that you elect to provide to support your application and other information that you elect to disclose in your user profile on the Site. If you are under 27 years old, we will require you to attach to your application a copy of your passport, driving licence or birth certificate in order to allow us to verify whether you are eligible to the reduced under-27-years membership fee, pursuant to the House rules (available here). We also collect information about your debit/credit card and bank account information provided by you to our payment service providers. We require this information for the purpose of recording and processing your membership application (and administering your membership). For further details, please also refer to the section below headed 'Payment information'.

Reservation information
Guest information, such as your first and last name, email address, billing and payment information (for further details, please also refer to the section below headed 'Payment information'). Personal data collected in relation to reservations will be processed in accordance with a privacy policy provided at the time of requesting a reservation. Please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect, or process, your personal data.

Site and Soho House Digital Channels Information and Services.
Any content you generate on our upload to the Site or generate, upload or make available such content through our Digital Channels, including preferences you set (such as choice of language), photographs and videos you upload, conversations and connections you have with other users and comments you make via our messaging services.

We also collect information regarding your use of the Site and our Digital Channels, e.g. how you engage with Site and our Digital Channels, including how you interact with content we show to you, videos you watch, how you use and interact with our Soho Connect, messaging and House Pay features, what Houses you visit. We also infer your preferences, including your interests for the purpose of personalising content. We will also process your personal data in order to tell you about our existing Soho House family services and opportunities and any new Soho House family services and opportunities.

Location Information
We may also use GPS technology to determine your current location. Some of Our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can enable or disable location services when you use our Site or Digital Channels at any time through your mobile device settings
Capacity planning and tracing information

We also collect information regarding your visits to our Soho Houses, restaurants, spas, Soho Works and gyms for capacity planning purposes and to comply with government guidelines, regulations and mandates.

Other information
Personal details you choose to give when corresponding with us by phone or email; 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 one of our clubs or other premises. 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 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.

You are under no legal obligation to furnish any personal data about you, and the furnishing thereof is at your discretion and at your own free will. However, if you do not furnish certain information about you, we may not be able to provide our services to you.

5. How we use your personal data

We use your personal data in the following ways:

To acknowledge, confirm and deal with your membership application (and where necessary put you on our waiting list). Such use of your data is necessary in order to implement your request to become a member.

Where you are a member, we use it to 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 complete and fulfil your reservation and stay, for example, to process your payment, ensure that your room is available, and provide you with related customer service, including sending confirmations or pre-arrival messages, assist you with meetings, events or celebrations. Such use is necessary 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).
To personalise the content you receive and provide you with tailored content that will be of interest to you

To communicate with you about your visit to our Site and Digital Channels, Soho Houses, spas, restaurants, gyms and Soho Works sites.
To notify you about changes to our service, provide you with user support and enforce our terms, conditions and policies.

Soho House and the Soho House family 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.
In order to comply with our legal obligations, we use your data to help us detect abuse, fraud and illegal activity on the Site.

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 that of our the Soho House family, and enable us and the Soho House family to enhance and personalise the experience we offer to our members, customers and our communications. This includes creating customer or member profiles to enable personalised direct marketing communications.

o To enable our Soho Connect and messenger service to function if you choose to use this function.

o To improve, promote and develop the Site and promote popular conversations, programs and campaigns on the Site.

o To enable you to socialise on our Site, for example, through Soho Connect and our messenging platform and by allowing other members to identify you via your shared interests if you consent to this through our Site preferences.

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 among the Soho House family for administrative purposes; for providing membership services; and in relation to our sales and marketing activities.

o We may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, the Soho House family, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.
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 contact you in case you may have been in contact with a person who has or is displaying symptoms of COVID-19 and to comply with government guidelines, regulations and mandates.

o To (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce our House rules; (d) protect our operations or those of any of the Soho House family; (e) protect our rights, safety or property, and/or that of the Soho House family, you or others; and (f) enforcing or defending legal rights, or preventing damage.

We may use your personal data for other purposes, which you consented to at the time of providing your data including but not limited to provide you with location-based services (where those services are available in your jurisdiction and you choose to share your precise location with us).

As used in this Privacy Policy, 'legitimate interests' means the interests of Soho House and the Soho House family in conducting and managing our organisation. 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 personal data protection rights' section below).

6. Disclosure of your information

We share your personal data with third parties in the following situations:
Service providers: Soho House, like many businesses, sometimes hires selected third parties who act on its behalf to support its operations, such as (i) card processing or payment services (see the section below headed 'Payment Information'); (ii) credit reference agencies to protect against possible fraud; (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members; (iv) web analytics providers; (v) providers of digital advertising services; and (vi) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Soho House Family: We operate on a global scale. In order to provide the services you request from us, the Soho House family may access and process the information that we collect from you for the purposes described above, including to offer products and services to you. The Soho House family 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 requirements from public health organisations, local councils and governmental, federal and state authorities. (ii) to enforce our Terms & Conditions, House 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 organisations.

7. Payment information

Any credit/debit card payments and other payments you make through our Site will be processed by our third-party payment providers. The payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that aside from card information tokenisation we do not directly process or store the debit/credit card data that you submit ourselves.
We may arrange that card or payment data you submit in support of a membership application or subscription fee is stored for the purpose of processing your application, initiating your membership and collecting your subscription fees if your initial application is successful. If you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription.

We store and use this card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law, and only for so long as legally permitted.

You may choose to opt out of us holding your card or payment data, although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee, or for the purpose of making any future purchases.

8. 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 Israel or the European Economic Area ('EEA') , to our service providers and the Soho House family 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 Israel, the United Kingdom or EEA.

Where we transfer your personal data to countries outside of Israel or 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 or implementing data transfer agreements or 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 of Israel and 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.

9. Security

Where we have given you (or where you have chosen) a password or login that 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 login 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 organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100 per cent 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 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 anonymise 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 Israeli Protection of Privacy Law, 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 object: You may ask us at any time to stop processing your personal data, and we will do so if:

o We are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing.

o 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.