Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number, billing address, delivery address
- information to enable us to check and verify your identity, such as your date of birth
- your login details and password
- your gender information and/or marital status, if you choose to give this to us
- location data
- your billing information, transaction and payment card information
- your contact history, purchase history and saved items
- information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
- your preferences in receiving marketing from us and our third parties and your communication preferences
This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing them to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources
- from a third party with your consent
- from cookies on our website—for more information on our use of cookies, please see our cookie policy
- via our IT systems, such as automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems
How and why we use your information
Under data protection law, we may only use your personal information if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations
- for the performance of our contract with you or to take steps at your request before entering into a contract
- for our legitimate interests or those of a third party; or
- where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide products and services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you | For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you |
| Ensuring business policies are adhered to, such as policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, our website and services, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information |
| To comply with our legal and regulatory obligations | |
| Statistical analysis to help us manage our business in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you |
| To comply with our legal and regulatory obligations | |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To comply with our legal and regulatory obligations | |
| For our legitimate interests, or those of a third party, making sure that we can keep in touch with our customers about existing orders and new products | |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations |
| For our legitimate interests, or those of a third party, to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you | |
| Marketing our services and those of selected third parties to: | For our legitimate interests or those of a third party, ie to promote our business to existing and former customers |
| —existing and former customers; | |
| —third parties who have previously expressed an interest in our services. | |
| External audits and quality checks, such as for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
Personal information we collect about you
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it or share it with other organisations for marketing purposes unless we have your consent.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us
- using the opt-out link in emails or ‘STOP’ number in texts
- updating your marketing preferences via the online MyAccount if you are registered customer
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Whom we share your personal information with
We routinely share personal information with:
- HM Revenue & Customs and other regulators or authorities
- third parties we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies
- other third parties we use to help us run our business, such as marketing agencies or website hosts
- third parties approved by you, such as social media sites you choose to link your account to or third party payment providers
- our bank
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, for example, in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Except as described in this privacy policy we will not share your personal information with any other third party.
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 notice or policy of every website you visit.
Where your personal information is held
Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.
How long your personal information will be held
We will keep your personal information while you have an account with us or we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf
- to show that we treated you fairly
- to keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out above. 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 requirements.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring personal information outside the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), for example:
- with your and our service providers located outside the UK/EEA
- if you are based outside the UK/EEA
- where there is an international dimension to the services we are providing to you
These transfers are subject to special rules under European and UK data protection law.
These non-UK/EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our practice is:
- to use standard data protection contract clauses that have been approved by the European Commission; or
- where possible to transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between UK/EEA and the US
If you would like further information please contact us (see ‘How to contact us’ below).
Your rights
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us—see ‘How to contact us’
- let us have enough information to identify you
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill)
- let us know what right you want to exercise and the information to which your request relates
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us.
Changes to this privacy policy
This privacy notice was published on Tuesday 28th July, 2020. We may change this privacy notice in future. When we do, we will inform you via email.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you