Who we are
Adderley is operated by Toma Group Ltd, company number 17129116, registered at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
Toma Group Ltd is the controller of the personal information described here. Contact hello@theadderley.com.
This notice covers theadderley.com, introductions, invitations, bookings, rooms and the Adderley iOS app, each operated by Toma Group Ltd.
What we use and why
We may use:
- your name, date of birth, city, email, mobile number, Instagram handle, referral details and optional photograph to review your introduction, confirm you are 21 or over, compose rooms, contact you and prevent duplicate or fraudulent records;
- public information on an Instagram profile you give us, including follower and following counts, to understand and verify your introduction, understand the composition of Adderley rooms, and produce aggregated information for internal planning and partnership discussions;
- technical information about how you reached and used the introduction form, being the address of the page you submitted from, any referring page or campaign details carried in the link you followed, and a random identifier generated for that form session, to check that a submission is genuine and to understand how people find Adderley;
- invitations, responses, attendance and communications to manage rooms and our relationship with you;
- payment and refund records to perform the booking contract and meet legal and accounting duties;
- dietary, allergy and access information to make requested arrangements; and
- photographs or film to document and promote rooms, with notice and a reasonable way to raise concerns or opt out.
We rely on contract where processing is needed for a booking, legal obligation where the law requires it, consent for optional photographs, push notifications and special-category information, and legitimate interests for introduction review, room composition, security, submission integrity, understanding how people reach us, attendance and relationship records, understanding the aggregate composition of rooms for internal and partnership planning, and general documentary photography.
Required form and booking fields are marked. Without them, we may not be able to review an introduction or confirm a booking.
Introductions are reviewed by people. We do not make decisions to accept or reject an introduction solely by automated means.
If someone names you as a referrer, we use the limited details only to check and record the referral and provide privacy information where required.
If you send us writing for the Adderley Journal, we use your name, email address, proposed title, your pitch or opening paragraph, your short biography, any document or links you choose to send, and any match to an existing Adderley record, in order to consider the piece for publication, to contact you about your submission, and to keep a record of our editorial consideration and decision. We rely on legitimate interests in running an edited publication. Sending us writing is separate from subscribing to the Journal, from room invitations, and from the marketing choices you made when introducing yourself, and it changes none of them. You keep ownership of your writing: reviewing it does not transfer any rights to us, and nothing is published without your agreement.
Email and WhatsApp
We may contact you where necessary to respond to an introduction you have made, manage an invitation or booking, communicate important information about a room you are attending, process a payment or refund, or deal with a safety or service issue. Those messages are not marketing and are not governed by the choices below.
If you separately choose to hear about future Adderley rooms by email or WhatsApp, we use that choice to send you those messages. Email and WhatsApp choices are separate and you can withdraw either choice at any time using the opt-out provided in the message or by contacting hello@theadderley.com. Making an introduction is not itself a choice to hear from us, and neither is being accepted: we send room marketing only to people who have asked for it on that channel. We do not rely on the electronic-marketing soft opt-in for room marketing. Where an earlier version of this form recorded a soft opt-in, we keep that record because it is what was collected at the time, and we do not market to it.
If you separately subscribe to the Adderley Journal, we use your email address to send new writing and related editorial emails based on your consent. You can unsubscribe at any time using the link in each email. Journal consent is its own choice: subscribing does not opt you into room marketing, and introducing yourself does not subscribe you to the Journal. We keep a record of your subscription, the wording you agreed to, and any later unsubscribe, bounce, complaint or suppression so that your choice is respected, and we use an email delivery provider to send these emails on our behalf.
Every marketing message identifies us and includes a simple opt-out. WhatsApp messages are one-to-one. We do not add applicants or guests to groups or share their mobile numbers with other guests.
We keep a minimal suppression record after an opt-out so that we can respect the choice.
We do not sell personal information or give it to sponsors or partners for their own marketing without separate permission.
Website and technical information
When you use our website, our hosting and security systems process technical information about the request: the internet address it came from, the browser or device type, the pages and addresses requested, the date and time, referring information where the browser sends it, and security or error information. Where an address you followed carries a campaign or referral parameter, that parameter forms part of the request and is processed with it.
We use this to deliver and secure the website, to prevent abuse, and to diagnose faults. We rely on our legitimate interests in operating a secure and reliable service, except where another lawful basis applies.
The site loads no advertising, no third-party analytics and no tracking or profiling technology, and it sets no cookie for any of those purposes.
Our legitimate interests
Where we rely on legitimate interests, those interests are reviewing introductions and organising coherent rooms, protecting Adderley and the people who use it from misuse or fraud, maintaining appropriate attendance and relationship records, operating and securing our services, understanding the aggregate composition of rooms — including limited social-profile metrics — for internal and partnership planning, and documenting Adderley rooms. We consider whether what we are doing is necessary and proportionate, and we balance it against the rights and reasonable expectations of the people affected.
The Adderley app
The Adderley iOS app is operated by Toma Group Ltd and is covered by this notice.
The app may use your email and authentication session to sign you in, messages and optional photographs you add, device and app information, crash diagnostics and a push-notification token where notifications are enabled.
We use this information to provide, secure and improve the app.
How long we keep it
- introduction, referral, relevant public-profile information and derived social-profile metrics: up to 24 months after the last relevant activity;
- guest, app and attendance records: while our relationship is active and normally for up to 24 months afterwards;
- dietary, allergy and access information: normally 30 days after the room, unless needed for an incident or claim;
- payment and accounting records: six years from the end of the relevant financial year;
- Journal contributions and our editorial decisions: up to 24 months after the decision, or for as long as we are working with you on an agreed piece;
- marketing choices and suppression records: for as long as needed to evidence and respect the choice; and
- selected photographs and film: while reasonably used for documentary or promotional purposes, subject to review.
We may keep information longer where required by law or needed for safety, fraud, insurance or legal claims.
Your rights
Depending on the circumstances, you may ask for access, correction, deletion, restriction or portability; object to processing based on legitimate interests; object at any time to direct marketing; or withdraw consent.
Email hello@theadderley.com. We may need to verify your identity. These rights are not absolute.
Complaints
Send a data-protection complaint to hello@theadderley.com with the subject “Data protection complaint”. We will acknowledge it within 30 days, investigate it and tell you the outcome without undue delay.
You may also complain to the Information Commissioner’s Office at ico.org.uk.
Changes
We may update this notice when our services or use of personal information changes. We will update the date above and bring material changes to your attention where required.