New West End Company Privacy Policy

 

New West End Company (referred to as “New West End Company”, “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data.

This privacy notice will inform you as to how we collect and process your personal data:

  • through your employment in a New West End Company’s member business;
  • through your participation in the West End Club loyalty scheme;
  • through your engagement with New West End Company’s security team;
  • through the use of this website (including any data you may provide when you sign up to our newsletters or take part in a prize draw);
  • interact with us when you apply for a role within our organisation; or
  • when you visit the West End.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Contacting us

 

Our full details are:

  • Full name of legal entity: The New West End Company
  • E-mail address: [email protected]
  • Postal address: Heddon House, 149-151 Regent Street, London W1B 4 JD

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at [email protected]. If you would like to update your marketing preferences or unsubscribe from our newsletters, please use the option to manage your preferences at the bottom of our newsletters or contact [email protected] with details of your request.

 

Personal data that we may collect

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect personal data about individuals in the following circumstances:

  • As a visitor to New West End Company website:
    • Type of data:
      • IP address
      • Browser settings
      • Cookie data
    • Lawful basis:
    • Legitimate interest
  • Purpose of processing:
    • To improve our website and better understand how people use it. More detail on the information we collect and how we do this is set out our cookie policy.
  • As an employee of a member of New West End Company:
    • Type of data:
      • Full name
      • Company name
      • Business address
      • Business e-mail
      • Business phone number
      • IP address
    • Lawful basis:
      • Performance of a contract
    • Purpose of processing:
      • To fulfil our contractual obligations to New West End Company members.
  • As a member of West End Club loyalty scheme:
    • Type of data:
      • Full name
      • Company name
      • Business address
      • Business e-mail
      • Business phone number
      • Marketing preferences
      • Profile data (feedback and survey responses)
    • Lawful basis:
      • Legitimate interest:
        • To engage with New West End Company members, or to comply with our legal, contractual, or regulatory obligation towards our members.
        • To ensure members get the best out of the services we offer.
      • Consent:
        • When we send you our newsletter because you have opted-in to receive it, we rely on your consent to contact you. You can unsubscribe from our newsletter at any time (see ‘Opting Out’ below).
      • Performance of a contract:
        • To comply with our contractual obligation towards the participants of the scheme.
  • As a supplier of goods and services to New West End Company:
    • Type of data:
      • Full name
      • Company name
      • Business address
      • Business e-mail
      • Business phone number
    • Lawful basis:
      • Performance of a contract
    • Purpose of processing:
      • To fulfil our contractual obligations towards you as the recipient of your goods or services.
  • As an applicant for a role with our organisation:
    • Type of data:
      • Full name
      • Personal e-mail
      • Personal phone number
      • Employment and education history
      • Information about your entitlement to work in the UK
      • Equal opportunities monitoring information, including information about your gender, disability status, age and ethnic origin
    • Lawful basis:
      • Contractual reasons: In order to enter into or perform a contract with you, e.g. to facilitate a recruitment process in which you are involved.
      • Legitimate interest: To make sure you receive updated information on our business activities and opportunities of interest (e.g. future events, job roles and/or research collaborations).
      • To comply with a legal obligation/exercise a legal right in relation to employment: To prevent discrimination during our recruitment process, or the obligation not to employ someone who does not have the legal right to work in the UK.
      • Substantial public interest (we have conducted a Data Protection Impact Assessment to support this lawful basis: So that we can carry out equal opportunities monitoring.
  • As a member of the public visiting the West End
    • We and our third-party suppliers may collect the following:
      • Your name, address and contact information (when you provide this voluntarily to us or our security teams).
      • Images and video footage (including of your racial image) on CCTV recording and body-worn cameras (used for identification purposes).
      • Data on visitor logs, data relating to incidents at business premises.
      • Personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual identity or sexual orientation.
      • Personal data about criminal allegations, proceedings or convictions.
    • Lawful basis:
      • Substantial public interest (we have conducted a Data Protection Impact Assessment to support this lawful basis).
      • Legitimate interest (we have conducted a Legitimate Interests Assessment to support this lawful basis).
    • Purpose of processing:
      • To record incidents of suspected or known anti-social behaviour or criminal activity in the West End and to implement preventative measures to make the West End safer for members of the public.
      • To support the police in their efforts to issue Community Protection Notices and Community Behaviour Orders in accordance with the Anti-Social Behaviour, Crime and Policing Act 2014.
      • To share details of known or suspected offenders and details of their behaviour/offences with local business for preventative and intelligence-gathering purposes.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. 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.

Opting out

 

You may opt out of our e-mail communications at any time by following the Manage Preferences link at the bottom any marketing communications e-mail sent to you by New West End Company or, in absence of the Manage Preferences link, by contacting [email protected] to request an opt-out.

If you personally amend your communications preferences using the Manage Preferences link, the change will come in effect instantaneously.

If you make an e-mail request for us to update your preferences manually or to make any changes to your personal data, we will first assess your request and will contact you again further as soon we have identified your data and the purpose for which we hold it, but within the 30-day mandated time limit. We will then provide you with details of our decision and your further rights if we are unable to meet your request.

 

Disclosures of your personal data to third parties

 

We do not, and will not, sell any of your personal data to any third party. However, in the normal course of business, we may receive your personal information from third parties or share your personal information with third parties within the boundaries set out by law and our regulatory obligations and without violating your interests and fundamental rights.

Third parties that may provide us with your personal information:

  • Publicly available repositories of personal data, e.g. LinkedIn, your social media pages or your company’s public website.
  • Our commercial partners that we use to help us run our business, such as security service providers.

Third parties that may receive your personal information from us:

  • Databases to manage your personal records (i.e. CRM software).
  • Applications that are used to send our marketing communications and store your communications preferences to help us improve our engagement with you.
  • Applications that are used to collect survey data from you or your personal data for participating in a prize draw or raffle.
  • Analytics providers (e.g. Google Analytics) that collect information about how you use our website and social media pages to help us improve them.
  • Commercial partners (such as security service providers), New West End Company members and law enforcement agencies that we work with to make the West End a safer environment for members of the public.

We require all our third-party service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

When working with third parties we may need to transfer your personal data outside of the UK and/or EU. Whenever we transfer your personal information outside of the UK and/or the EU, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us using the details above for more information on this.

 

Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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. If you have any concerns about the security of your personal data, please contact [email protected].

 

Data retention

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.

 

Third-party links

 

This website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Please note that New West End Company does not warrant, represent, endorse, or hold responsibility over any external sites that may be linked to and from this site.

 

Your legal rights

 

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

  • 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.
  • Correct 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 continuing to process 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, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
  • To 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Not to be subject to a decision based solely on automated processing with no human involvement, including automated profiling, which produces legal or similarly significant effects concerning you.

If you wish to exercise any of the rights set out above, please contact [email protected] for further details.

Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.

 

Complaints

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 at [email protected] in the first instance.

 

Changes to the privacy policy

 

This version was last updated on 19 June 2026. We may change this policy from time to time by updating this page so please revisit and reread it periodically.