1. Respecting your privacy
We are committed to protecting your privacy, and to be in compliance with applicable privacy laws which set out standards for the management of personal information. This policy outlines our personal information management practices. Specifically:
· the kinds of personal information we collect and hold;
· how we collect and hold it;
· the purposes for which we collect, hold, use and disclose it;
There are some matters to which this policy does not apply. These are referred to in clause 9 below.
We collect and hold personal information that is reasonably necessary for the operation of the Site, which may include:
· your personal details such as your name, email and/or physical addresses, telephone numbers, employer, date of birth, age and gender;
· your order number, customer reference number or loyalty card number;
· any rewards and redemption details applicable to your membership of one of our loyalty programs;
· what, how and when you buy from us or have expressed an interest in buying from us; and
· demographic information such as your postcode and your stated or likely preferences, for example whether you may be interested in particular products or promotions.
You generally have the option of not identifying yourself or of using a pseudonym when dealing with us, but not where this is impractical (for example when you shop online with us) or where the law or a court order provides otherwise.
Collection of personal information:
When we collect personal information about you, we do so by making a record of it. We do this when:
· you visit our websites;
· you purchase products from us online;
· you register with us, for example to create an account, to become a member of one of our loyalty programs or to send you information;
· you communicate with us online;
· you take part in our promotions, competitions, testimonials, surveys and focus groups;
· you deal with us in other ways involving a need for personal information to be provided such as when you contact one of our call centres or chat lines or bring a claim against us.
We may also collect personal information about you by accessing data from other sources and then analysing that data together with the information we already hold about you in order to learn more about your likely preferences and interests. When you visit our websites, social media pages or mobile applications or click on our advertisements on online media, we may collect information about you using technology which is not apparent to you, for example “cookies“. For information about our use of this technology, refer to the Cookies Statement at end of policy.
The personal information we collect and hold about you is from your direct dealings with us, but there are some instances where we may collect your personal information other than from you directly. For example from other suppliers who, in common with us, have a relationship with you, or on whose behalf we process your purchases.
Holding of personal information:
Personal information we hold is stored on our web servers in secure environments. These servers may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.
All credit/debit card information you provide is through the PayPal secure website not our website. We don’t hold any of your financial details.
Your personal information is password-protected to prevent unauthorised access to it. You should not divulge your password to anyone.
When we collect, hold, use and disclose your personal information, we do so primarily to sell and promote our products and services to you and to improve on the range of our offerings. For example:
· to learn of your likely preferences so that we may promote our products and services to you in a way which may be of most interest to you; and
· to assist in investigating your complaints and enquiries.
We disclose personal information we collect for purposes which are incidental to the sale and promotion of our products and services to you. For example, we may disclose your personal information within our group, to service providers who assist us in our day-to-day business operations and as part of buying or selling businesses.
We may collect, hold, use and disclose your personal information for other purposes which are within reasonable expectations or where permitted by law. When marketing to you, your personal information is only ever used or disclosed for our own purposes or those of our group companies or our carefully selected commercial partners. You may opt out of our direct marketing to you at any time. Our direct marketing materials will tell you how to do this.
We may de-identify your personal information. We may do this for use and disclosure of the anonymous data to determine preferences and shopping patterns.
It is our policy to require all sharing of personal information to be done in a way which requires observance of strict privacy and security standards. We may allow your personal information to be shared with those who are in countries other than your own location. We do this:
· where we have made a business decision to host our websites or store our data with trusted service providers who are in the business of providing website hosting, data storage and/or data processing services. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in; and
· for disclosures between our group companies.
· when our business which collected your personal information is in a different country to your location;
· when our relevant commercial partners are located in a different country to your location;
· when our supply to you necessarily involves overseas disclosures. For example where we need to provide certain of your personal information to one or more of our overseas product suppliers in order to fulfil your order;
· where you are involved with public liability issues concerning a product we may disclose your personal information to a supplier of such a product in the course of managing those issues.
This is a policy. There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us and on our particular businesses. There are also separate terms governing the use of our sites and the purchase of products from our sites.
About this statement
Cookies may be arranged (“set”) by us or by others under an arrangement with us, such as companies whose business it is to analyse information. We may also access information from cookies set by others (“3rd party cookies”).
Why should you know about cookies?
You should know about cookies because they involve the collection of information about you (which may or may not be personal information) in a way which may not be obvious to you.
What is a cookie?
Cookies are small pieces of information captured when your device is used to access online content. Cookies are stored in your device by the person who arranges for the cookie to be set. This person may be the provider of the content being accessed, or it might be a 3rd party. 3rd party cookies are used to provide information about your device’s access to more than one discrete site or data set.