General Data Protection Regulation Policy
Description of processing: The following is a broad
description of the way we process personal data.
We promise that we will value the personal information
entrusted to us and make sure we respect that trust.
Go further than just the letter of the law when it comes to handling personal
information and adopt good practice standards.
Consider and address the privacy risks first when we are planning to use or hold
personal information in new ways, such as when introducing new systems.
Be open with individuals about how we use their information and who we give it
and make it easy for individuals to access and correct their personal
Keep personal information to the minimum necessary and delete it when we no
longer need it.
Have effective safeguards in place to make sure personal information is kept
securely and does not fall into the wrong hands.
Provide training to staff who handle personal information and treat it as a
disciplinary matter if they misuse or don’t look after personal information
Put appropriate financial and human resources into looking after personal
information to make sure we can live up to our promises and regularly check that
we are living up to our promises and report on how we are doing.
This Privacy Notice explains in detail the types of personal data we may collect
about you when you interact with us. It also explains how we’ll store and handle
that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully
informed about your rights, and how we use your data; for example we
will explain things such as our credit checking procedure, and how we store
It’s likely that we may need to update this Privacy Notice from time to time.
We hope the following will answer any questions you have but if not, please do
get in touch with us.
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
For example, when you tick a box or opt-in to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data
is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our
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 Partnership 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
We also combine the shopping history of many customers to identify trends and
ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing
information by post, telling you about products and services that we think might
When do we collect your personal data
- When you visit any of our websites, and use your account to buy
products and services, or redeem vouchers on the phone or online.
- When you make an online purchase and check out we collect
- When you create an account with us.
- When you purchase a product or service by phone but don’t have (or
don’t use) an account.
- 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
- When you enter prize draws or competitions.
- When you book any kind of appointment with us.
- 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
- When you fill in any forms. For example, if you have an accident
on our premises, we will need to collect your personal data.
- When you’ve given a third party permission to share with us the
information they hold about you.
- We collect data from publicly-available sources (such as Land
Registry) when you have given your consent to share information or where the
information is made public as a matter of law.
- When you visit our premises or use our car park we have CCTV
systems operated for the security of both customers and staff. These systems
may record your image during your visit.
What sort of personal data do we collect?
- If you have an account with us: your name, gender, company name,
billing/delivery address, orders and receipts, email and telephone number.
For your security, this information is password protected.
- Details of your interactions with us via email, shop online
transactions or visiting our premises.
For example, we collect notes from our conversations with you, details of any
complaints or comments you make, details of purchases you made, items viewed or
added to your basket, voucher redemptions, brands you show interest in, web
pages you visit and how and when you contact us.
- Details of your shopping preferences.
For example, which of our products you prefer and where you redeem vouchers.
- Details of your visits to our websites and which site you came from to
- Personal details which help us to recommend items of interest.
- Payment card information.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit our premises or
- To deliver the best possible web experience, we collect technical
information about your internet connection and browser as well as the
country and telephone code where your computer is located, the web pages
viewed during your visit, the advertisements you clicked on, and 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?
We want to give you the best possible customer experience. One way to
achieve that is to get the richest picture we can of who you are by
combining the data we have about you.
We then use this to offer you promotions, products and services that are
most likely to interest you.
The data privacy law allows this as part of our legitimate interest in
understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details
in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse
certain contact permissions, we might not be able to provide some services
you’ve asked for.
For example, if you’ve asked us to let you know when we launch new products,
we can’t do that if you’ve withdrawn your general consent to hear from us.
Here is how we use your personal data and why:
- To process any orders that you make by using our websites, in person, or
over the phone. If we don’t collect your personal data during checkout, 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 staff from crime, we
operate CCTV systems on our premises 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. Our
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
about relevant products and services including tailored special offers,
discounts, promotions, events, competitions and so on.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 will 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 send you communications required by law or which are necessary to
inform you about our changes to the services we provide you. For example,
updates to this Privacy Notice, product recall notices, and legally required
information relating to your orders. These service messages will not include
any promotional content and do not require prior consent when sent by email
or text message. If we do not use your personal data for these purposes, we
would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites, we’ll use
data we hold about your favourite products and so on. We do so on the basis
of your consent to receive notifications and/or for our website to place
cookies or similar technology on your device.
For example, we might display a list of items you’ve recently looked at or
offer you recommendations based on your purchase history and any other data
you’ve shared with us.
- To administer any of our prize draws or competitions which you enter,
based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide
to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll record your feedback on our products and our services.
- To comply with our contractual or legal obligations to share data with law
- 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
How we protect your personal data
Of course, you are free to opt out of receiving these requests from us at
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.
We secure access to all transactional areas of our websites using ‘https’
Access to your personal data is password-protected, and sensitive data (such
as payment card information) is secured by SSL encryption.
Your credit or debit card information provided during the ordering process
is protected by 128-bit industry-standard Secure Sockets Layer (SSL)
technology to provide encryption of personal information. This server
encrypts information while it is being transmitted across the Internet so
that unauthorised people cannot read it.
We do not see or collect your card details as this is securely handled by
Cookies are used on this shopping site where they are strictly necessary for
the site functionality. They are used to aid navigation, and to keep track
of the contents of your shopping cart. If you log in to an account, your
logged-in status is recorded in a temporary cookie. If you select the
'Remember Me' Option in the checkout, a cookie will be used to remember your
details. You can turn off cookies by blocking them in your browser Privacy
settings. If you turn off cookies, you will be unable to place orders or
benefit from the other features that use them.
We regularly monitor our system for possible vulnerabilities and attacks,
and we carry out testing to identify ways to further strengthen security.
How long do 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
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for five
years so we can comply with our legal and contractual obligations.
If your order included a guarantee, the associated personal data will be
kept until the end of the guarantee period.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, technicians visiting your home, for fraud
management, to handle complaints, to help us personalise our offers to you
and so on.
Here is the policy we apply to those organisations to keep your data safe
and protect your privacy:
- We provide only the information they need to perform their specific
- They may only use your data for the exact purposes we specify in our
contract with them.
- We work closely with them to ensure that your privacy is respected and
protected at all times.
- If we stop using their services, any of your data held by them will either
be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Direct marketing companies who help us manage our electronic
communications with you.
- 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.
- Data insight companies to ensure your details are up to date and accurate.
- For fraud management, we may share information about fraudulent or
potentially fraudulent activity in our premises or systems. This may include
sharing data about individuals with law enforcement bodies.
- 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
- We may, from time to time, expand, reduce or sell the Partnership and this
may involve the transfer of divisions or the whole business to new owners.
If this happens, your personal data will, where relevant, be transferred to
the new owner or controlling party, under the terms of this Privacy Notice.
What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most
- The correction of your personal data when incorrect, out of date or
- 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).
- 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.
- Review by a Director of any decision made based solely on automatic
processing of your data (i.e. where no human has yet reviewed the outcome
and criteria for the decision).