Customer Privacy Policy for VFI Members

What is the purpose of this document?

  • This Privacy Policy template (“Template”) can be used by publican members to notify individuals about the personal data which publicans hold about them and how they can expect their data to be used.
  • The Template will act as a guide only and members should seek legal advice if their processing activities differ from those listed in the Template, or contact VFI Head Office for further guidance.
  • The Template should be read with the accompanying guidance note in relation to the GDPR.
  • The Template aims to address the main processing activities that publicans engage in and how publicans process personal data about individuals (e.g. customers, vendors and suppliers). The Template does not, however, provide an exhaustive list of members’ data processing activities.
  • The Template assumes that the purposes for which the personal data are collected are for: (1) use on social media, (2) CCTV monitoring, (3) reservations and bookings; (4) loyalty and reward schemes.
  • The Template does not cover the personal data which members may process about their staff. A separate privacy policy will be required to cover this type of data processing.
  • Publican members should ensure that they make the completed Template easily accessible to individuals (e.g. by making it available on the publican’s website).
  • This Template has been drafted on the assumption that publicans do not rely on the consent of individuals’ to process their personal data (but rather largely rely on the publicans’ legitimate business interests).
  • The Template assumes that no sensitive personal data (which includes data about race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data or data about a person's sex life or sexual orientation) is collected from individuals.
  • The Template assumes that no personal data is collected from persons other than the individuals themselves. If you obtain personal data about individuals from other sources, then separate considerations apply.
  • The Template assumes that no personal data is collected via the publican’s own website (other than reservation/booking information). To the extent that publican members do collect personal data via their website (such as online identifiers, information via web forms etc.), this should be provided for in the Template or in a separate website privacy policy.
  • The Template contains drafting notes and certain optional processing activities. These should be deleted before use or if not applicable to the member’s business.
  • A separate privacy policy relating to employees will be available on the VFI website in due course.

Template Privacy Policy

  1. Purpose and scope

The purpose of this Privacy Policy (“Policy”) is to inform you about how we collect, use, store and share your personal data. This Policy applies to all customers, potential customers, business partners, vendors and suppliers (“you” or “yours”) of Acetalab Limited. (“we” “ours” or “us”) The Riverfront is the controller of your personal data. We will use your personal data only for the purposes and in the manner set out in this Policy.

  1. What kinds of personal information do we collect and process?

We collect and process your personal data including, but not limited to, the following types of personal data:

  • name;
  • contact details such as phone number, email address, postal address, social media profile;
  • [demographic information such as age, gender, employer, profession, geographic location;
  • [photographs;
  • [audio or visual recordings;
  • [CCTV images or footage;
  • [financial details such as credit or debit card information which you provide us to secure a booking.

6. Your Rights

  • You have certain rights as a data subject in relation to your information. While some of these rights are general and unrestricted, other rights only apply in certain circumstances.

    Your rights include:

    • Access – you are entitled to obtain a copy of the personal data which we hold about you.
    • Rectification – you can request rectification of your personal data if it is inaccurate or incomplete.
    • Restriction – you can restrict our use of your personal data.
    • Deletion – you are entitled to request that we erase your personal data.
    • Objection – you can object to the processing of your personal data where our legal basis for processing your data is our legitimate interests.

    These rights may be restricted in certain circumstances for instance where they may be needed to comply with our legal obligations or for the defence or exercise of legal claims.

    You can exercise these rights by contacting us at

    In circumstances where you are not satisfied with our use of your personal data or you are not satisfied with how we have responded to your request to exercise your rights, you have the right to lodge a complaint with the Office of the Data Protection Commission who can be contacted at or Lo Call 1890 25 22 31.

    1. Policy updates

    This Policy may be updated from time to time. If we make changes that are material we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.