THE LEGAL BASES ON WHICH WE MAY COLLECT AND USE YOUR DATA
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting the Company to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalised offers.
We will also use your address details to send you direct marketing information by post or email, telling you about products and services that we think might interest you.
WHEN DO WE COLLECT YOUR PERSONAL DATA?
- When you visit our website, visit one of our showrooms or contact us by email or phone to buy products and services.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask us to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about an employee who provided that service, it may be passed on to them if requested.
- When you use our showrooms which may have CCTV systems operated for the security of both customers and employees. These systems may record your image during your visit.
WHAT SORT OF PERSONAL DATA DO WE COLLECT?
- Your name, billing/delivery address, orders and receipts, email and telephone number.
- Details of your interactions with us through contact centres, in showroom, or online. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, web pages you visit and how and when you contact us.
- Details of your shopping preferences. For example, which of our showrooms you prefer to visit.
- Details of your visits to our website, and which site you came from to ours.
- Personal details which help us to recommend items of interest.
- Payment card information: input to Barclaycard online portal; not stored.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit a showroom or car park.
- Any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
HOW AND WHY DO WE USE YOUR PERSONAL DATA?
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website or in-showroom. If we don’t collect your personal data during the transaction process, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our customers, premises, assets and employees from crime, we may operate CCTV systems in our showrooms and car parks which record images for security. We do this on the basis of our legitimate business interests.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts,
- Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To comply with our contractual or legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
- To process your booking/appointment requests. Sometimes, we’ll need to share your details with a third party who is providing a service such as delivery couriers. We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfill your request.
HOW WE PROTECT YOUR PERSONAL DATA
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. Sensitive data such as payment card information is secured and tokenised to ensure it is protected.
HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We sometimes share your personal data with trusted third parties, for example, delivery couriers.
Examples of the kind of third parties we work with are:
- Operational companies such as delivery couriers.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.
We do not share your data with third parties for their own purposes.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
WHERE YOUR PERSONAL DATA MAY BE PROCESSED
The only element of your personal data that may be shared with suppliers outside the European Economic Area (EEA) is your name, and this is done purely for the purpose of identification of the product(s) that you have purchased.
WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
- Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
- That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You can contact us to request to exercise these rights at any time by email or telephone – contact details are supplied on our website.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration of an extended warranty.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
CONTACTING THE REGULATOR
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.