Privacy Policy

We are Troia (UK) Restaurants Ltd, trading as The Ivy Collection, The Ivy Asia, Harry’s Dolce Vita, Harry’s Bar James Street, and Brasserie of Light (Troia). This privacy notice explains how we and our sister brands, Caprice Holdings Ltd and Birley Club Group (collectively we, us, our), collect and process personal data. We respect your privacy and are committed to protecting your personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This privacy notice explains how Troia collects and processes your personal data when you visit our restaurants, visit The Ivy Collection website (Website) and The Ivy Collection App (App), or interact with our services.

Please read this privacy policy alongside any other privacy notices we may provide when collecting or processing your personal data. This ensures you understand how and why we use your data. This privacy policy supplements other notices and does not replace them.

Who we are and how to contact us

Troia (UK) Restaurants Ltd is the data controller in relation to locations including The Ivy Collection, The Ivy Asia St Paul’s, The Ivy West Street, Harry’s Dolce Vita, Harry’s Bar James Street, Brasserie of Light and Granary Square Brasserie.

CH Acquisition Ltd is the data controller in relation to locations including J Sheekey, J Sheekey Atlantic Bar, 34 Mayfair, Balthazar, Daphne’s, Le Caprice, Rivington Greenwich, Scott’s, Sexy Fish.

If you have any questions about this privacy notice or our data protection practices, please contact us using the details below:

Email: [email protected]

Post: 26 – 28 Conway St, London, W1T 6BQ

Telephone: 0161 830 5855

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

Our Website and App may include links to third-party websites, plug-ins and applications. When you click on these links or enable these connections, third parties may collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. Before clicking on any external links or enabling third-party connections, we encourage you to read the privacy policy of the relevant third party. Please note that these third parties may have different data protection standards than we do, and we are not responsible for their practices.

The Website and App may include social media features and widgets, such as the Facebook Like button, the Share This button or interactive mini programs that run on the Website and App. These features may collect your IP address and which page you are visiting on our Website and App and may set a cookie or other identifier to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website or App. Your interactions with these features are governed by the privacy notice of the company providing it, and we are not responsible for the processing of your personal data by these third parties.

The data we collect about you

Personal data, or personal information, means any information that can be used to identify you as an individual. It does not include data where your identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender and membership details.

If you provide personal information about anyone other than yourself (e.g. your family members or friends), you are responsible for informing that person that we are collecting their personal information and for ensuring that you have valid permission to provide such personal information to us.

We collect, use and share Aggregated Data such as statistical or demographic information for any purpose. While Aggregated Data may be derived from your personal data, it does not directly or indirectly reveal your identity and is not considered personal data under law. For example, we may aggregate Usage Data to calculate feature usage statistics. We implement technical measures to prevent re-identification of individuals from Aggregated Data. If we ever combine Aggregated Data with personal data in a way that could identify you, we will treat the combined information as personal data subject to this privacy notice and appropriate safeguards.

Special categories of personal data

Children’s data

Our App and Website are not intended for children under 16 years old, and we do not knowingly collect data from children under this age.

If you are under 16 years old, you must obtain consent from your parent or guardian before providing any personal information to us. If you are a parent or guardian and believe your child under 16 has provided us with personal information without your consent, please contact us immediately so we can delete their information and remove them from our mailing lists.

If we become aware that we have inadvertently received personal information from a child below 16 years of age, we will delete such information from our databases.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How we collect your personal data

We collect and process your personal data in the following ways:

• Information you provide directly to us when you:
  • Make a reservation at any of our restaurants;
  • Purchase gift vouchers;
  • Visit or make transactions on our Website, App, or in our establishments;
  • Respond to our promotions or subscribe to our mailing lists;
  • Participate in competitions, contests, or games we organise;
  • Attend events or functions at our establishments (including property launches, private dining, ticketed events, promotional events, and social events); and
  • Communicate with us by telephone, email, website, or through social media platforms.
• Information we collect automatically, including:
  • Payment and transaction information when you make purchases or bookings; and
  • Transaction Data, Technical Data, Profile Data, Usage Data, and Marketing and Communications Data when you use our App and Website. This includes information about your equipment, usage patterns, and marketing preferences. We may also receive technical data when you visit other websites through links in our App or Website. We may anonymise your Technical Data, Profile Data, and Usage Data.
• Information we receive from third parties, including:
  • Business partners (tour operators, booking agencies, reservation systems, and third parties providing advertising, marketing, and promotional services);
  • Social networks;
  • Event organisers for private dining;
  • Family members or friends who provide your personal information on your behalf; and/or
  • Regulatory authorities, law enforcement agencies, and other public bodies (where legally required).

How and why we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a contract: where we need to perform the contract, we are about to enter into or have entered into with you.
• Legitimate interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means our business interests in conducting and managing our operations effectively and lawfully. When we process your personal data based on legitimate interests, we first conduct a balancing test to ensure our interests do not override your fundamental rights and freedoms. We only rely on legitimate interests where we are satisfied this balance is met, unless we have your consent or are otherwise required or permitted by law to process the data.
• Legal obligation: where we need to comply with a legal obligation.

We generally do not rely on consent as our primary legal basis for processing your personal data. Where we do rely on consent (such as for processing special category data about dietary requirements or for direct marketing), you have the right to withdraw it at any time by contacting us at [email protected] or through your account settings. We will process your withdrawal request without undue delay and within one month at the latest. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal. However, it may impact our ability to provide certain services or process your data for the purposes that required consent. Where we have other valid legal bases, we may continue processing your data on those grounds.

Purposes for which we will use your personal data

The table below describes how we use your personal data and the legal bases we rely on. We may process your personal data for more than one lawful purpose depending on the specific reason for using your data. Please contact us if you need details about the specific legal ground we are relying on where more than one ground is listed.

Marketing

We provide you with specific choices regarding the use of your personal data for marketing and advertising purposes, in accordance with data protection laws.

Promotional offers from us

We may use your Identity, Contact, Technical, Profile and Usage Data to form a view on what products, services and offers may be relevant or of interest to you (we call this marketing). This includes analysing your dining preferences, booking history, and interaction with our services to provide you with personalised recommendations and offers.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, where required by law, have provided your consent to receiving such communications. You have the right to opt out of receiving this marketing at any time.

Third-party marketing

We will obtain your explicit opt-in consent before sharing your personal data with any third party for marketing purposes. You can withdraw this consent at any time by contacting us or using the opt-out methods described below.

Opting out of marketing

You can ask us or third parties to stop sending you marketing messages by:

• Following the opt-out links on any marketing message sent to you;
• Adjusting your marketing preferences in your account settings; or
• Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions.

Cookies

Our App and Website use cookies and similar technologies to distinguish you from other users and enhance your user experience. You can control and manage cookies through your browser settings. Essential cookies required for the operation of our services cannot be disabled. You can find more information about the individual cookies we use, their purposes, and how to manage your preferences in our cookies policy, which is available on our Website and App.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below:

1. Our Restaurant Group primarily for business and operational purposes.
2. Third parties including professional advisors, social media networks, data management companies, digital agencies, reservation booking platforms, payment processors, gift voucher solutions providers, distribution & delivery partners, CRM software providers, automated customer service providers, and IT consultants carrying out testing and development work on our business technology systems and function co-ordinators.
3. External third parties who act as processors providing IT and system administration services to us.
4. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
5. HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
6. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We implement appropriate data processing agreements with our third-party service providers that include processing personal data only on our documented instructions and implementing appropriate technical and organisational security measures.

We do not allow our third-party service providers to use your personal data for their own purposes.

International transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Automated decision making

Data security

We have implemented appropriate technical and organisational security measures including encryption, access controls, and regular security assessments to protect your personal data from unauthorised access, accidental loss, alteration, or disclosure. Access to your personal data is strictly limited to employees, agents, contractors and other third parties who have a legitimate business need, are bound by contractual confidentiality obligations, and process data only on our documented instructions. We regularly review and update these measures to maintain the security of your data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if there is a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you. Typically, we retain customer data for up to 6 years after your last interaction with us, unless a longer period is required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note that we may need to retain certain information for legal or administrative purposes (such as fraud prevention) or to complete transactions. However, we may not always be able to comply with your request for erasure for specific legal reasons, which will be explained to you at the time of your request if applicable.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format (such as CSV or XML). Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you (such as personalised dining recommendations or loyalty program benefits). We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out in this privacy notice.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will respond to all legitimate requests within one month of receipt of your request. Occasionally it may take us up to two additional months if your request is particularly complex or you have made multiple requests. In this case, we will notify you within one month of receiving your request and explain why the extension is necessary. We will keep you updated on the progress of your request.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 10 September 2025. Historic versions of our privacy policy are available upon request. We will notify you of any material changes to this privacy policy through our Website or email notification where we have your contact details.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can update your personal information through your account settings or by contacting our customer service team using the contact details provided in this privacy notice. Maintaining accurate information helps us comply with data protection laws and enables us to provide you with the best possible service.