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