Purpose

Twenty Eight (the ‘Club’) is committed to the protection of privacy and personal information. This Policy outlines the Club’s commitment to maintaining privacy and explains how we use the information we collect about Club members and guests, how you can instruct us if you prefer to limit the use of that information and procedures that we have in place to safeguard your privacy.

This Policy has been developed in compliance with The Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018, as well as, EU, General Data Protection Regulation. Information we collect about you will not be disclosed to any third party without your prior consent or the requestor’s demonstrated legal authority to receive it.

If you have any queries about this policy or about your data, please contact us at info@28int.com or +44 (0) 1534 729105. If you are not satisfied with the way in which Twenty Eight has treated your personal data, you may lodge a complaint with the Office of the Information Commissioner by sending an e-mail to enquiries@dataci.org or by telephone to +44 (0) 1534 716534.

You have the right to withdraw your consent to us holding your personal data at any time by contacting the Data Protection Officer. Should you wish to withdraw your consent and request us to delete any personal data, we will endeavour to do so as soon as reasonably practicable and in accordance with the Law.

When personal information is collected

Personal information is collected when emails are sent to any @28int.com email addresses, which includes staff member’s email addresses and in some cases as a result of enquiries made by phone or in person.

Other personal information that the Club may collect about its members and guests, usually during the membership application process and/or when accessing the Club, include:

– Name, job title, company name, company address;, date of birth.
– Information regarding guests that you bring to the Club;
– Personal preferences, including dietary preferences, allergies and other medical conditions if voluntarily provided by the member or guest;
– Information on member and guest reservations and Club events that members and guests attend;
– Credit card information and/or banking information for billing purposes;
– Images of members or guests on the Club’s CCTV system (discussed in section CCTV system); and
– Details on when you access the Club.

The Club does not capture or store any personal information about individuals who access our website (twentyeightinternational.com), except where individuals voluntarily choose to give us personal details by:
– Email
– Using an electronic table booking form
– Enquiring about any of the Club’s services

How we use your information

– Collected by email.
Information supplied by email will be processed by the email application and may be recorded in the customer relationship management system if relates to a matter of significance.

– Collected as a result of enquiries made by phone or in person.
Information may be recorded in the customer relationship management system if relates to a complaint, notification or other matter of significance.

– Collected as a result of membership applications and/or when accessing the Club Information may be recorded in the customer relationship management system if relates to the offering of services in relation to Club membership or the improvement of the Club experience received by members and guests.

Disclosure of personal information

We will not usually share your personal information with other parties without your consent except where we are required to by Law or in connection with a criminal investigation. In the absence of any previous consent provided by you, we will contact you should we consider disclosure to a third party is necessary for us to fully investigate your complaint or enquiry.

Access to your personal information

You are able to find out what information we hold about you by making a subject access request under the relevant Data Protection Law. To do so, please make the request in writing to the Data Protection Officer, Serafina Karahassan at serafina@28int.com or +44 (0) 1534 729105.

Links to other websites

This privacy policy does not cover any third party websites reached via links on this website. You are advised to read the privacy statements on the other websites you visit.

Closed Circuit Television (CCTV) system
– The Club may collect personal information of members and guests via the Club’s CCTV system. CCTV is used for the purposes of security and protection of Club property from theft and other crimes.
– The Club’s CCTV will not be used in any areas where people have a reasonable expectation of privacy such as private meeting rooms and restrooms. Currently, the Club has video cameras in the following locations only: the front entrance, rear exit and above each bar till.
– All CCTV is overt and only captures images, not audio. The CCTV is only reviewed in response to a triggering event. For example, if there is a safety incident at the Club, the CCTV will be reviewed.
– Where a triggering event requires the Club to review CCTV, the Club may use information collected through CCTV to make decisions regarding a member or guest’s continued access to the Club, up to and including termination of Club membership.
– Video images may only be reviewed by: (i) individuals responsible for the technical operation of the CCTV system (for technical purposes only); and (ii) individuals who reasonably need to view the video images for purposes of conducting an investigation into a specific incident, including human resources and/or legal counsel.
– Video images will not be disclosed to third parties unless such disclosure is required for the purposes of conducting an investigation, for law enforcement purposes or as authorised by privacy or other legislation.
– Video images will be erased within 90 days from the date of the recording unless the video image is associated with a specific incident being investigated. If the video image is associated with an incident being investigated or necessary for a prosecution, it will be retained for as long as reasonably necessary in the circumstances of the specific incident in issue.

Google Analytics

On occasion, we may use Google Analytics to help us understand how visitors engage with our websites so that we can improve them. When you visit twentyeightinternational.com site your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you’re visiting and your IP address.

Learn how to control the information your browser sends to Google on Google’s website

IP address
Your computer’s IP address is a number assigned to your computer when you use the internet. This is recorded automatically in a log file when you visit our site. This log file does not contain any personal identifiable information about you.

Cookies

Cookies are small files which can be stored on your computer when you visit a website. These files contain information about the webpages you look at so that the next time you visit the site it can be customised to meet your needs.

Changes to this policy

We may, at any time, revise this privacy statement without notice so you should check it regularly. Continued use of the Twenty Eight website after a change has been made is your acceptance of the change.