Privacy & GDPR Policy for Immersion Escapes

1. Introduction

This Privacy Policy explains how Immersion Escapes (an alias of Hallmark AV Ltd) (“we”, “us”, or “our”) collects, uses, stores, and protects your personal data when you use our services, including booking an escape room experience and visiting our premises. We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR), the Data Protection Act 2018, and the Data (Use and Access) Act 2025.

2. Who We Are and How to Contact Us

Hallmark AV Ltd is the data controller responsible for your personal data. If you have any questions about this privacy policy or our data protection practices, please contact our Data Protection Officer:

DPO: David Hall (Director and COO)

● Email: privacy@hallmarkav.com
● Postal Address: 11 Market Square, Alton, Hampshire, GU34 1HD
● Phone Number: 01420 579581

3. The Personal Data We Collect

We collect the following types of personal data:

• Booking Information: When you book an escape room, we collect information necessary to process your booking, including your name, email address, phone number, and billing address. Payment information is processed securely by our third-party providers (Square/Stripe).
• Attendee Records (Digital Waivers): We collect names and digital signatures for all participants (18+) to comply with health, safety, and insurance requirements.
• Surveillance (Video & Audio): Our premises utilise Closed-Circuit Television (CCTV) and live microphones in game rooms and reception areas for safety, security, and game facilitation (hints).
  Communications: If you contact us directly, we may keep a record of that correspondence.
• Communications: If you contact us directly, we may keep a record of that
  correspondence.

4. How We Use Your Personal Data and Our Lawful Basis for Doing So

We collect the following types of personal data:

• To Fulfil Our Contract With You: We process booking information to manage your reservation, take payment, and provide the experience.
• For Our Legitimate Interests:
  • We use contact details to send booking confirmations/reminders, and to monitor surveillance footage, to ensure the safety and security of our customers, staff, and property.
  • We retain records to comply with HMRC tax reporting and Health & Safety at Work regulations.

5. Data Sharing

We do not share your personal data with third parties for marketing purposes. Data is shared only in limited circumstances:

• Internal Access: Access is restricted to staff who require the info for their job duties.
• Remote Oversight: Authorised Data Officers may access secure, encrypted live feeds from off-site for operational safety and oversight.
• Service Providers: We share data with trusted processors (e.g., Square, Airtable) who are contractually bound to protect your data.
• Legal Reasons: We may disclose information if required by law or a valid legal request from authorities.

6. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.

• CCTV & Audio Recordings:Automatically overwritten/deleted after 30 days, unless required for an active investigation.
• Booking & Financial Records: Retained for 6 years to comply with UK tax (HMRC) and accounting regulations.
• Digital Waivers: Retained for 6 years in line with the UK Statute of Limitations for personal injury and contract claims.
• Anonymised Data: Statistical data (date/game played) may be kept indefinitely for analysis.

7. Your Data Protection Rights

Under data protection law, you have the right to access, rectify, or erase your personal information. You also have the right to object to or restrict processing. We do not charge a fee for exercising these rights and will respond within one month. Contact privacy@hallmarkav.com to make a request.

8. CCTV

To ensure the safety of our guests and staff, and to facilitate the escape room experience (providing hints), we utilise an integrated surveillance system.

• Scope of Monitoring:Our premises are equipped with continuous video and live audio recording in all game rooms and reception areas.
• Transparency:Prominent signage at the building entrance and in each game room informs participants that recording is active.
• Access Control:Access to live feeds and recorded footage is strictly limited to Management and authorised Data Officers.
• Data Subject Access Requests (SARs):You have the right to request access to footage or audio clips in which you appear, subject to the privacy of other individuals.
• Data Subject Access Requests (SARs):Surveillance data is stored on a secure local server and automatically deleted after 30 days.

9. Data Security

We have implemented appropriate technical and organisational security measures (including 2FA, MFA, and AES-256 encryption for data at rest) to prevent your personal data from being accidentally lost, used, or accessed unauthorised.

10. Changes to This Privacy Policy

We may update this policy periodically. Any changes will be posted on our website. We encourage you to review this policy to stay informed about how we are protecting your data.
protecting your data.

11. How to Complain

If you have any concerns, please get in touch with us at privacy@hallmarkav.com. You also have the right to complain to the Information Commissioner’s Office (ICO).
ICO Registration Number: C1547541
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113