Privacy Policy

Last updated: 25 August 2026

This Privacy Policy explains how Ikon Nightlife Ltd, trading as Home and Basement, collects, uses, stores and protects personal data when you use our live-screen photo and shout-out experience, join Home Insider, receive or reveal offers, visit our digital services, or otherwise interact with us through this platform.

The live-screen platform and related technology are provided and operated on our behalf by Wenlock-Simpson Management Limited.

1. Who We Are

Ikon Nightlife Ltd, trading as Home and Basement, is the data controller responsible for deciding how and why personal data collected through this service is used.

Company number: 16902016
ICO registration: ZC159320
Pure
239 Broadway
Bexleyheath
Kent
DA6 8DB

Wenlock-Simpson Management Limited acts as our technology and software provider and processes personal data on our instructions in connection with hosting, operation, maintenance, support and development of the platform.

For privacy questions, data-rights requests, deletion requests or complaints, contact:

operations@ikonnightlife.co.uk

2. Information We Collect

Live-Screen Photo and Shout-Out Submissions

You can submit a photo or shout-out without joining Home Insider. Depending on the type of submission, we may collect:

• the photo or shout-out text you submit;
• the date and time of submission;
• the relevant venue, campaign or night associated with the submission;
• moderation, approval, rejection and display status;
• duplicate-submission and misuse-prevention information;
• technical information such as IP address and browser/user-agent information;
• cookie and consent choices recorded at the time of submission.

Home Insider

Home Insider is an optional 18+ marketing programme. If you choose to join, we may collect:

• your mobile telephone number;
• your full date of birth;
• your marketing-consent choice and the date/time it was recorded;
• email address if we introduce email collection in future and you provide it;
• records of venue, brand and platform interactions linked to your profile;
• offers issued to you, offer expiry information and offer-code reveal activity;
• marketing engagement and campaign-response information;
• audience, segment and profiling information derived from those interactions.

Joining Home Insider is optional. Submitting a photo or shout-out does not, by itself, sign you up for future marketing.

Offers and Conversion Measurement

Where you qualify for an in-night offer, we may record:

• which offer was issued;
• when it was issued and when it expires;
• the offer code associated with the issue;
• whether and when you chose to reveal the code;
• the recorded value of the offer at the time it was issued.

Revealing a code is treated as an attempted-redemption or conversion signal for reporting and marketing measurement. It does not necessarily prove that a purchase was completed.

Technical, Analytics and Advertising Information

Our systems and, where you consent, third-party analytics and advertising technologies may process information such as:

• IP address;
• browser and device information;
• operating system and screen/device characteristics;
• page views, clicks, interactions and journey completion events;
• cookie identifiers, advertising identifiers and similar online identifiers;
• campaign, referral and attribution information;
• diagnostic, security and error logs.

3. How We Use Personal Data

We may use personal data to:

• receive, process and moderate photos and shout-outs;
• decide whether submitted content is suitable for live-screen display;
• display approved submissions on venue screens;
• manage the order and frequency in which approved content appears;
• operate, secure, maintain and improve the platform;
• detect duplicate submissions, fraud, misuse and attempts to manipulate the service;
• issue, manage and measure in-night offers;
• measure offer-code reveals and other conversion signals;
• manage Home Insider membership;
• verify that Home Insider members are aged 18 or over;
• use date of birth for birthday offers, age-based segmentation and relevant marketing;
• send marketing by WhatsApp, SMS and email where you have provided the relevant contact details and consented;
• promote venues, brands, events and offers operated by Ikon Nightlife Ltd;
• build a customer profile across repeat interactions, submissions and Ikon-operated venues or brands;
• segment customers and personalise marketing;
• create and use custom advertising audiences and similar/lookalike audiences;
• measure marketing performance, attribution and engagement;
• produce aggregated and anonymised reporting and business insights;
• comply with legal, regulatory and safeguarding obligations;
• establish, exercise or defend legal claims.

4. Photos, Shout-Outs and Live-Screen Display

Photos and shout-outs submitted through the platform are collected for moderation and possible display on live venue screens.

Submission, approval or successful moderation does not guarantee that content will be displayed. We may decide whether, when and how often approved content appears.

Photos and shout-outs submitted through this service are not intended to be reused by us for later social-media advertising or external marketing campaigns.

Photos and shout-outs will normally be deleted within 90 days of submission unless limited retention is reasonably necessary for legal, regulatory, security, safeguarding, complaint-handling or misuse-prevention purposes.

5. Automated Moderation

Submitted images may be analysed by an artificial-intelligence moderation provider. Automated moderation may approve or reject an image without a human reviewing it first.

The effect of this automated decision is limited to whether the image is eligible for possible display on the live venue screens. It does not determine entry to a venue, Home Insider membership, employment, credit, or another decision intended to have legal or similarly significant effects.

Automated moderation decisions are final for that submission and we do not provide an individual human-review process for rejected live-screen submissions.

6. Home Insider and Marketing

Home Insider is strictly for people aged 18 and over.

We will only use your contact details for Home Insider direct marketing where you have actively chosen to join and have provided the relevant contact details.

Marketing may include venue news, event information, drinks and other offers, birthday promotions, competitions, ticket or booking information and promotions relating to other venues or brands operated by Ikon Nightlife Ltd.

Depending on the details you provide, we may contact you by WhatsApp, SMS or email.

You can withdraw your marketing consent at any time by using any unsubscribe or opt-out method included in a message, where available, or by contacting: operations@ikonnightlife.co.uk .

We may retain limited suppression information after an opt-out where necessary to ensure that your marketing preference continues to be respected.

7. Profiling, Audience Matching and Advertising

Where permitted, we may combine information from your interactions with us across multiple visits, submissions, offers, venues and brands to create an ongoing customer profile.

We may use that profile to understand engagement, segment audiences, personalise marketing and determine which communications or promotions may be more relevant to you.

Where the appropriate consent and platform requirements are met, we may also use customer information with advertising and audience-matching platforms to create custom audiences and similar/lookalike audiences, suppress existing customers from selected campaigns and measure advertising effectiveness.

Marketing partners and technology providers act on our behalf or provide services to us. This Privacy Policy does not give those partners permission to independently use your Home Insider data to market their own unrelated products or services to you.

8. Cookies, Pixels and Similar Technologies

The service uses essential technologies required for security, session management, consent preferences and core website functionality.

With your consent, we may also use non-essential analytics, advertising, conversion-measurement and audience-building technologies, including pixels, tags, cookies and similar identifiers.

These technologies may be used to:

• understand how the platform is used;
• measure photo and shout-out journeys;
• measure Home Insider signups;
• measure offers issued and codes revealed;
• attribute activity to marketing campaigns;
• build and refine advertising audiences;
• improve the customer experience and marketing performance.

Non-essential analytics and advertising technologies are intended to operate only where the required consent has been given. You can reject optional cookies without losing access to the core photo or shout-out submission experience.

Third-party technology providers may apply their own retention periods and controls to data processed through their platforms.

9. Our Legal Bases

Depending on the activity, we rely on one or more of the following legal bases:

• Consent: for Home Insider direct marketing and non-essential cookies, pixels and advertising technologies where consent is required.
• Legitimate interests: to operate, moderate, secure, measure and improve the live-screen service; administer offers; prevent fraud and misuse; understand business performance; and maintain appropriate records, where those interests are not overridden by your rights and interests.
• Legal obligation: where processing is necessary to comply with law or regulatory requirements.
• Legal claims and protection: where data is reasonably required to establish, exercise or defend legal rights, protect individuals, investigate misuse or respond to complaints.

10. Sharing Personal Data

We may share personal data with trusted service providers and other recipients where necessary, including:

• Wenlock-Simpson Management Limited as our platform/software provider and data processor;
• UK hosting, database and infrastructure providers;
• AI moderation providers;
• analytics, advertising and audience-matching providers where the appropriate consent has been given;
• communications and marketing service providers acting on our behalf;
• professional advisers, insurers, regulators, law-enforcement bodies or authorities where appropriate or legally required;
• a purchaser, successor or relevant party in connection with a sale, merger, restructuring or transfer of the business or relevant assets.

We do not sell your personal data.

Service providers may only process personal data as required to provide services to us, follow our instructions where applicable, or meet their own legal obligations.

11. International Processing

The core Home Insider and live-screen database is hosted and stored in the United Kingdom.

Some specialist providers, including AI moderation, analytics, advertising and communications providers, may process information outside the United Kingdom.

Where UK personal data is transferred internationally, we will take appropriate steps required by applicable data-protection law to protect that information, which may include adequacy arrangements, contractual safeguards or other recognised transfer mechanisms.

12. Data Retention

Photos and Shout-Outs

Photos, shout-outs and associated submission technical information will normally be retained for up to 90 days after submission.

Home Insider

Home Insider contact details, date of birth, consent records and linked profile information may normally be retained for up to five years from your most recent meaningful interaction with Ikon Nightlife Ltd.

If you opt out earlier, we will stop using your details for direct marketing and may retain only limited information where necessary to record and honour your opt-out.

Legal, Security and Suppression Records

Information may be retained for longer where reasonably necessary for legal or regulatory obligations, fraud and security prevention, safeguarding, complaint handling, legal claims or maintenance of a marketing suppression list.

Aggregated and Anonymised Data

Aggregated or genuinely anonymised information that no longer identifies an individual may be retained indefinitely for reporting, trends, platform analysis, offer-performance measurement and marketing effectiveness.

13. Security

Information submitted through the service is transmitted using encrypted HTTPS connections where supported by the service.

Access to administration and moderation functions is restricted to authorised personnel. We use technical and organisational measures designed to protect information from unauthorised access, alteration, disclosure, loss and misuse.

No online service can be guaranteed to be completely secure. If we become aware of a personal-data breach, we will assess and respond to it in accordance with applicable law.

14. Your Rights

Depending on the circumstances, you may have rights to:

• request access to personal data we hold about you;
• ask us to correct inaccurate or incomplete information;
• request deletion of your information;
• restrict or object to certain processing;
• withdraw consent where processing is based on consent;
• request portability of certain information;
• ask for information about how your data is used;
• make a complaint about our handling of personal data.

To exercise your rights, contact: operations@ikonnightlife.co.uk .

We may need to request information to verify your identity and locate the relevant records.

Deletion rights are not absolute. We may retain limited information where required or permitted by law, including for legal claims, regulatory obligations, fraud/security prevention or to maintain a suppression record.

You also have the right to complain to the UK Information Commissioner’s Office.

15. Business Transfers

If Ikon Nightlife Ltd, Home, Basement or relevant assets are sold, merged, reorganised or transferred, personal data may form part of that transaction where permitted by law. Any recipient would be required to handle the information in accordance with applicable data-protection requirements.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to the platform, our venues, our services, technology or legal requirements.

The latest version will be published through the service with an updated “Last updated” date.

17. Contact Us

Ikon Nightlife Ltd, trading as Home and Basement
Company number: 16902016
ICO registration: ZC159320
Pure, 239 Broadway, Bexleyheath, Kent, DA6 8DB

Email: operations@ikonnightlife.co.uk