1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, gender, age, as well as company/employer name and job title (if attending a corporate event or contacting us on behalf of an external venue or third-party supplier).

• Contact Data includes billing address, email address and telephone numbers (including of the lead guest making an event booking).

• Financial Data includes bank card and account details.

• Transaction Data includes details about payments to and from you and other details of services you have purchased from us and our third-party suppliers (we sometimes use these for larger-scale outdoor pursuit activities in connection with events, such as axe throwing or archery).

• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website.

• Profile Data includes bookings made by you, your photograph, short bio and interests, experiences, preferences, feedback and survey responses, and any other personal data you voluntarily provide.   

• Usage Data includes information about how you interact with and use our website and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Health-related Data includes any particular medical or health conditions, disabilities and accessibility needs that would impact participation in the game.

• Recordings Data includes your photograph, image and recordings of you (or your child) and your likeness, voice and appearance, and any other identifying information provided in connection with a photograph or recording of you.

Our experiences may be booked for groups that include children. In these cases, personal data about child participants is provided to us by their parent, legal guardian or the adult responsible for making the booking. We do not knowingly collect children’s data directly from the child. We process children’s data only as necessary to administer the booking, manage attendance, protect the safety of participants and deliver the experience. We do not use children’s data for marketing or unrelated purposes. The adult making the booking is responsible for ensuring that the child’s parent or guardian is aware of this privacy policy and understands how we handle children’s information. We take particular care when handling children’s data and apply additional safeguards where appropriate.

Special category personal data

Some of the data collected above may be considered "Special Category Personal Data" under the GDPR. This could include health-related data (which helps us to design and customise safe games that are bespoke to your needs and run activities safely) or data revealing your sexual orientation or ethnic origin (in the context of game character building and to help enhance the experience). We only collect this information with your explicit consent, which you may withdraw at any time, but this may affect our ability to accommodate your needs or allow safe participation in the game. The data is treated with the highest level of confidentiality and is protected through appropriate technical and organisational measures, including data encryption and access controls.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature or feature of our services in order to analyse general trends in how users are interacting with our website/services to help improve the website and our service offering.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us personal data by filling in online forms (including our website enquiry form) or by corresponding with us by post, phone, email or otherwise, or by taking part in our game experiences. This includes personal data you provide when you:

  • apply for our services, including when you voluntarily supply personal data to us in meetings (including planning calls and event briefings), via emails and otherwise in initial proposals and beyond to help us customize a game experience for you and your group;

  • subscribe to our publications;

  • make a booking and participate in one of our events;

  • request marketing to be sent to you;

  • enter a competition, promotion or give feedback as part of a survey, or otherwise contact us; or

  • agree to be photographed, filmed or recorded during one of our game experiences.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

• Third parties or publicly available sources.

  • When a lead guest makes a booking, they may provide us with personal data about other individuals in their group (for example, names, contact details and any relevant information needed so we can plan and deliver the experience). We process this information for the purpose of administering the booking, communicating with the group, ensuring safety and delivering the event. We rely on the lead guest’s representation that they have the authority to provide this information and that the individuals concerned have been informed about how we will handle their personal data.

  • From external partner venues where a venue introduces you to us as part of its activity packages where you have expressed an interest in our services and consented to this.

  • We will receive Technical Data about you which is collected from analytics providers such as Google based outside the UK.

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

We want to ensure that you are informed and aware of the best services and promotions that we can offer you. When your personal data is collected (for example on our website), you may be asked to indicate your preferences for receiving direct marketing communications from Cloaked Events via email, sms, telephone, post OR You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out/unsubscribe links within any marketing communication sent to you or by contacting us at info@cloakedevents.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to service availability notifications, booking confirmations, updates to our terms and conditions, and checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

4. Disclosure of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above. We may sometimes contract with the following third parties to supply certain products and services:

• External partner venues (where your booking relates to an experience hosted at a partner venue or you consent to an introduction) and in-game third-party activity suppliers to whom you wish to be introduced in connection with our events or services (e.g. where needed for event logistics and safety). Where we put you in touch with such third parties, they may collect and process your personal data in accordance with their own privacy practices. We do not control how those third parties handle your data and are not responsible for their privacy notices or data protection compliance. We encourage you to review the privacy information provided by any such third-party venue or supplier before engaging with them or providing any personal data.

• Squarespace to host and manage our website.

• Google Workspace to manage and store our business email and internal documents as a cloud service provider.

• Accountants and banking partners: We may share customer financial information (such as payment records, invoices and transaction details) with our accountants and our bank as necessary for bookkeeping, tax compliance, financial reporting and processing payments. We currently accept payment by bank transfer only. If we choose to use a third-party payment processor in future (for example, to process card payments), we may share the personal data necessary to complete your payment with that provider. We will update this privacy policy before doing so.

• Photographs and recordings of you (where you have agreed to be photographed/filmed) may be shared publicly, including in digital or printed promotional materials and on our website and social media platforms. Once content is published on third-party platforms (such as social media), it may be subject to those platforms’ own terms and privacy policies.

We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Some of the external third parties to whom we transfer your personal data are based outside the UK and European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the UK/EEA. (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein.) These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and will be fully protected under the UK GDPR, EU GDPR, Data Protection Act 2018 and/or to equivalent standards by law. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;

• Where we use certain service providers, we may use standard contractual clauses (‘SCCs’), approved by the European Commission (or other specific contracts approved for use in the UK) which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;

• Where we use providers based in the US, we will make an assessment to determine whether we can transfer your personal data on the basis of SCCs taking into account the circumstances of the transfer, and put supplementary measures in place if required. The supplementary measures along with SCCs follow a case-by-case analysis of the circumstances surrounding the transfer and this would ensure that U.S. law does not encroach on the satisfactory level of protection guarantee. If we come to the decision, taking into account the circumstances of the transfer and possible supplementary measures, that appropriate safeguards would not be ensured, then we will either suspend the transfer of your personal data until we ensure an adequate level of protection can be provided or we might end the transfer of your personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include (but are not necessarily limited to) encryption, strong passwords, two-factor authentication, access controls and staff training, secure servers, role-based permissions for internal notes and recordings, and regular review of third-party processors. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. For example:

• We retain most personal data relating to game participants for up to two years after an event. This is to enable us to respond to post-event enquiries, gather feedback, maintain safety and incident records, and address any issues or claims that may arise. We retain this data only for as long as necessary for these purposes, after which it is securely deleted or anonymised.

• Participant safety/health information is only retained for the duration of the event plus a short administrative period unless retention is required for incident reporting.

• Venue/supplier records are retained for as long as the relationship is active.

• Children’s data is kept for no longer than necessary and subject to strict minimisation.

• By law we also have to keep basic information about our customers relating to booking and events records (including contact, identity, financial and transaction data) for six years after they cease being customers (for tax and accounting purposes).

• We will retain Recordings Data for as long as it is reasonably required for the purposes described above, unless consent is withdrawn earlier. If consent is withdrawn, we will stop using the recording going forward and will take reasonable steps to remove it from our own channels, where practicable.

In some circumstances you can ask us to delete your data: see paragraph 8 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of Marketing’ in paragraph 3 for details of how to object to receiving direct marketing communications).

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 3 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

  • If you want us to establish the data's accuracy;

  • Where our use of the data is unlawful but you do not want us to erase it;

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details in paragraph 9).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us via email at info@cloakedevents.com.

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in December 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

12. Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.