Privacy Policy for Sapphire Soho

Effective Date: 16 July 2025.

At Sapphire Soho (“we,” “us,” “our”), your privacy is extremely important to us. This Privacy Policy explains how we collect, use, store, and protect your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the London IT Act.

1. Who We Are

Sapphire Soho is a licensed entertainment venue located in London, UK. Our address is 4 Carlisle St, London W1D 3BJ, United Kingdom. If you have questions about this policy or your data, please contact us at info@sapphiresoho.co.uk or by calling 02072875041.

2. What Information We Collect

We may collect and process the following types of personal data:

Identity Data: Name, date of birth (to verify age), and contact details (email, phone number).

Usage Data: Information about how you interact with our website, including IP address, browser type, device information, and pages visited.

Marketing and Communications Data: Your preferences regarding marketing communications and advertising preferences (including data collected via Google Ads).

Consent Data: Data regarding your consent to marketing and other processing activities.

3. How We Collect Your Data

We collect data through:

Direct interactions (e.g. bookings, online forms).

Automated technologies (e.g. website cookies, Google Ads).

Third-party services (e.g. payment processors).

4. How We Use Your Data

We process your personal data for the following purposes:

To provide our services and manage bookings.
To verify your age and eligibility to access adult entertainment.
To send you marketing communications (with your consent).
To improve our services, including analyzing website usage.
To comply with legal obligations, such as age verification and financial record-keeping.

5. Lawful Basis for Processing

We rely on the following legal bases under UK GDPR:

Consent (Article 6(1)(a)): For sending marketing communications.

Performance of Contract (Article 6(1)(b)): To fulfill bookings and reservations.

Legal Obligation (Article 6(1)(c)): For regulatory compliance and age verification.

Legitimate Interests (Article 6(1)(f)): To improve services and manage our business, provided these interests are not overridden by your rights.

6. Data Sharing

We may share your data with:

Our IT and website service providers.
Google Ads (for remarketing and analytics).
Payment processors (to facilitate secure transactions).
Law enforcement agencies or regulators where required by law.
We will never sell your personal data to third parties.

7. International Transfers

We store and process your data within the UK and the European Economic Area (EEA). Where data is transferred outside the UK or EEA (e.g. via Google Ads), we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the UK ICO.

8. Data Retention

We will retain your data only as long as necessary to fulfill the purposes outlined above, unless a longer retention period is required by law.

9. Your Rights

Under the UK GDPR, you have the right to:

Access your personal data.
Request correction or deletion of your data.
Object to or restrict certain types of processing.
Withdraw consent for marketing at any time.
Lodge a complaint with the Information Commissioner’s Office (ICO).

10. Cookies and Tracking

We use cookies to improve website functionality and personalize advertising through Google Ads. You can manage cookie preferences through our cookie banner or your browser settings.

11. Security

We implement appropriate technical and organizational measures to protect your data, including encryption, access controls, and secure servers.

12. Contact Us

For any privacy-related concerns, please contact our Data Protection Officer at:

Email: info@sapphiresoho.co.uk

Phone: 02072875041

Address: 4 Carlisle St, London W1D 3BJ, United Kingdom

13. Updates to this Policy

We may update this Privacy Policy from time to time. The latest version will always be posted on our website.