Who we are
Adderley is operated by Toma Group Ltd, a company registered in England and Wales under company number 17129116. Its registered office is 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
Toma Group Ltd is the data controller for the personal information described in this notice. References to “Adderley”, “we”, “us” or “our” mean Toma Group Ltd operating the Adderley brand.
Questions about this notice or your personal information can be sent to hello@theadderley.com.
What this notice covers
This notice covers information collected through:
- theadderley.com and the Adderley introduction form;
- invitations, room attendance, payments and membership administration;
- the Adderley iOS app, where used;
- emails, support conversations and other direct communications with us; and
- referral information that someone provides when they introduce themselves.
We collect information directly from you when you introduce yourself, respond to an invitation, attend a room, make a payment, use the app or contact us. We may also receive limited information about you from a person who names you as their referrer.
We do not use solely automated decision-making to accept or reject introductions.
Introductions
When you introduce yourself, we use the details you provide to review your introduction, keep an accurate record, prevent duplicate records and decide whether there is a room we think you should know about.
| DATA | WHY | LAWFUL BASIS |
|---|---|---|
| Name | To identify you, create or link the correct record and personalise communication. | Legitimate interests |
| Date of birth | To confirm that you meet Adderley’s age requirement. | Legitimate interests |
| City | To understand which rooms may be relevant to you. | Legitimate interests |
| Email address | To review your introduction and contact you about its outcome or a relevant invitation. | Legitimate interests |
| Mobile number | To identify you accurately and, where permitted, communicate about your introduction or a room. | Legitimate interests |
| Instagram handle | To help us verify identity and understand who is introducing themselves. | Legitimate interests |
| Referral details | To check and record whether an existing guest or member referred you. | Legitimate interests |
| Photograph | To put a face to your name and help us recognise you if you attend. Optional. | Legitimate interests |
| Submission information | To keep an accurate record, prevent duplicates, diagnose errors and understand how an introduction reached us. | Legitimate interests |
The photograph is optional. If you add one, we use it to put a face to your name and help us recognise you when you attend. We do not use facial-recognition technology or use your appearance to make an automated decision.
If an applicant provides a referrer’s name or email address, we use that information only to check and record the referral. We do not use referral details for unrelated marketing.
Rooms and membership
If you are invited to or attend an Adderley room, we keep the information needed to operate the room safely, accurately and calmly.
| DATA | WHY | LAWFUL BASIS |
|---|---|---|
| Invitations and responses | To manage invitations, capacity, confirmations and cancellations. | Contract / legitimate interests |
| Attendance history | To keep an accurate record of rooms attended and support the returning-room model. | Legitimate interests |
| Payment records | To take payment, issue refunds, reconcile rooms and meet accounting obligations. We do not store full card details. | Contract / legal obligation |
| Dietary or access information | To make reasonable arrangements for a room when you choose to provide it. | Consent where required |
| Room communications | To send essential information about a room, including timing, location and changes. | Contract / legitimate interests |
| Room photographs or film | To document rooms and tell Adderley’s story. We will make guests aware when photography or filming is taking place. | Legitimate interests / consent where required |
Dietary or access information can reveal sensitive information about health or beliefs. Please share only what is needed for us to accommodate you. You can withdraw optional information by contacting us, although we may no longer be able to make the requested arrangement.
The Adderley app
If you use the Adderley iOS app, we process the following information to provide and protect the app:
| DATA | WHY | LAWFUL BASIS |
|---|---|---|
| Email address | To sign you in using a one-time code. | Contract |
| Authentication session | To keep you signed in securely. | Contract |
| Messages you send | To respond to requests and keep a support history available to you. | Contract |
| Photos you add | To let you build your personal record of rooms. Optional. | Consent |
| Device and app information | To diagnose problems and support the correct devices and app versions. | Legitimate interests |
| Crash and error diagnostics | To fix bugs, protect the service and keep it stable. | Legitimate interests |
| Push notification token | To deliver notifications you have enabled. | Consent |
The app does not currently track you across apps or websites owned by other companies. We do not use advertising identifiers or third-party advertising trackers. If this changes, we will update this notice and ask for any permission required through Apple’s standard controls.
Payments
Payments for rooms are processed by Stripe through hosted Checkout. Adderley does not see or store your full card details. We retain limited transaction information, such as the amount, payment status and refund status, to administer the room, reconcile our records and meet accounting obligations.
Email, WhatsApp and marketing
We may send service messages that are necessary to deal with an introduction, invitation, booking, payment or room you are attending. These are not general marketing messages.
We send general news or promotional messages by email or WhatsApp only where we have a valid lawful basis and, where required, your consent. You can opt out at any time using the method in the message or by emailing us.
We do not sell personal information or share it with other organisations for their own marketing.
Security
We use reasonable technical and organisational measures to protect personal information against unauthorised access, loss, alteration or misuse. These include encrypted connections, access controls, private storage for photographs and restricted administrative access.
No system is completely secure. If we identify a breach that creates a risk to you, we will respond and notify you or the regulator where the law requires it.
How long we keep it
- Introductions accepted into Adderley
- For the duration of the relationship, plus 12 months.
- Introductions not selected
- 12 months from the decision date.
- Introductions kept under consideration
- Until a decision is made or 24 months, whichever is sooner.
- Withdrawn introductions
- Deleted within 30 days of a valid request, unless we must keep a limited record.
- Invitation and attendance records
- For the duration of the relationship, plus 12 months.
- Payment and accounting records
- Six years from the end of the financial year they relate to, or longer where required by law.
- Support conversations
- For the duration of the relationship, plus 12 months.
- Crash and diagnostic data
- Up to 90 days.
- Consent, objections and opt-outs
- As long as needed to demonstrate and respect the choice.
We may keep information for longer where the law requires it, where it is needed for a legal claim, or where a limited suppression record is needed to respect an opt-out or objection.
Your rights
Under UK data protection law, you may have the right to:
- ask for a copy of the personal information we hold about you;
- correct information that is inaccurate or incomplete;
- ask us to delete information in certain circumstances;
- ask us to restrict how information is used;
- object to processing based on legitimate interests;
- receive certain information in a portable format; and
- withdraw consent at any time where we rely on consent.
These rights are not absolute and the right available depends on the lawful basis and the circumstances. To exercise a right, email hello@theadderley.com. We may need to verify your identity before acting on a request.
Deleting your information
You can ask us to close your Adderley record or delete personal information by emailing hello@theadderley.com. If an account-deletion option is available in the app, you can also use it to remove your app sign-in and associated app content.
Deleting an app account does not automatically remove financial records or other information that Toma Group Ltd must retain for legal, accounting, safety or dispute purposes.
Contact and complaints
Contact us first if you have a question or concern. Email hello@theadderley.com and we will do our best to resolve it.
You also have the right to complain to the Information Commissioner’s Office. Visit ico.org.uk or call 0303 123 1113.
Changes
We may update this notice when Adderley’s services or use of personal information changes. We will update the date at the top and, where a change is material, bring it to your attention in an appropriate way.