We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website privacy policy is divided into the following sections:

• Who we are
• Our website
• Our collection and use of your personal information
• Transfer of your information out of the UK and EEA
• Marketing
• Your rights
• Keeping your personal information secure
• How to complain
• Changes to this website privacy policy
• How to contact us

Who we are

This website is operated by Forever Holdings Limited. We create one-to-one digital encounters between A-List people and the people who love them. For more information see: https://hereintheroom.com.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our website

This privacy policy relates to your use of our website: https://hereintheroom.com only.

Our website may include links to and from the websites of our partner networks, advertisers and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website.

We collect this personal information from you either directly, such as when you register with us, contact us or purchase products or services via our website or indirectly, such as your browsing activity while on our website.

The personal information we collect about you depends on the particular activities carried out through our website.

• This information includes:
• your name, address and contact details
• date of birth
• details of any feedback you give us by phone, email, post or via social media
• information about the services we provide to you
• your account details, such as username, login details

We use this personal information to:

• create and manage your account with us
• verify your identity
• provide goods and services to you
• customise our website and its content to your particular preferences
• notify you of any changes to our website or to our services that may affect you
• improve our services

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

Further information—the personal information we collect, when and how we use it

For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:

When you register with us

We ask for:

• Name
• Contact details
• Password
• Username

In order to:

• create and manage your account with us
• communicate with you about your account

We rely on CONTRACT as the lawful basis for collecting and using your personal information.

We will keep this information until:

• you close your account with us
• we close your account

When managing our IT system

We ask for:

• Name
• Contact details
• Password
• Username

In order to:

• manage our IT systems
• ensure that we are able to deliver all functions required to provide the services in accordance with our terms and conditions

We rely on CONTRACT as the lawful basis for collecting and using your personal information.

We will keep this information until:

• you close your account with us
• we close your account

To perform the services under your paid subscription

We ask for:

• Name
• Contact details
• Password
• Username
• Payment information

In order to:

• manage the contractual relationship with you in accordance with our terms and conditions
• deliver relevant website services and content

We rely on CONTRACT as the lawful basis for collecting and using your personal information.

We will keep this information until:

• you close your account with us
• we close your account

To manage the relationship with you

We ask for:

• Identity
• Contact details
• Password
• Username

In order to:

• provide any information, products and services that you have requested from us
• notify you about any changes to our services, terms and conditions or privacy notice
• ask you to leave a review

We rely on CONTRACT and LEGITIMATE INTEREST as the lawful basis for collecting and using your personal information.

We will keep this information until:

• you close your account with us
• we close your account
• 1 year thereafter

To conduct our marketing campaigns

We ask for:

• Identity
• Contact details
• Password
• Username
• IP address
• Usage

In order to:

• deliver relevant advertisements and information for you
• recommend services discounts and offers that may be of interest to you
• measure the effectiveness of the advertising provided
• improve our website, services, marketing, customer experiences
• conduct market research, statistical and survey purposes

We rely on CONSENT and LEGITIMATE INTEREST as the lawful basis for collecting and using your personal information.

We will keep this information until:

• you close your account with us
• we close your account
• 1 year thereafter

To comply with our legal obligations

We ask for all data collected which is necessary to perform the obligation in order to to comply with relevant legal obligations.

We rely on LEGITIMATE INTEREST as the lawful basis for collecting and using your personal information.

We will keep this information for the period necessary to fulfil the legal obligation.

Who we share your personal information with

We may disclose or share your personal data with the following third parties:

• where you have consented for us to do so. For example, if you have consented to receive marketing materials from third parties, or in respect of third parties’ (including co-branded or jointly promoted) products and services, we may pass your data on to the relevant third parties for the purpose of sending you such marketing communications provide goods and services to you.
• to business partners, suppliers, sub-contractors and other third parties that we use in connection with the running of our business, such as:
  • third party service providers that we engage to provide IT systems and software, and to host our website;
  • third party payment processing services Stripe Payments Ltd. We do not store your payment information.  Your payment details are provided to the payment processing service you have selected, who are required to comply with applicable regulations and data protection laws. Please refer to the privacy policy of the relevant provider for details of how they process your personal data.
  • analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • affiliate networks through whom you have accessed our website;
• if we are under a duty to disclose or share your personal to comply with any legal obligation; or
• to our professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• to any third party 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 notice.

Some of those third party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see Transfer of your information out of the UK and EEA.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

Transfer of your information out of the UK and EEA

We may transfer your personal information outside the United Kingdom (UK) and European Economic Area (EEA).

Whenever we transfer personal data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place If you would like further information please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the UK or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Marketing

We would like to send you information about services, events, new experiences, and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, or text message (SMS).

We will only ask whether you would like us to send you marketing messages when you tick the relevant boxes when you subscribe with us, visit our website and our social media pages.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

• contacting us at service@hereintheroom.com
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

It may take up to 14 days for this to take place.

For more information on your rights in relation to marketing, see Your rights below.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us
• let us have enough information to identify you (eg account number, user name, registration details),
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this website privacy policy

This website privacy policy was published on March 16th, 2021.

We may change this website privacy policy from time to time, when we do we will inform you via email.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to service@hereintheroom.com or write to Forever Holdings Ltd, 73 Cornhill London, EC3V 3QQ.