- Sets out the types of personal information we collect;
- Explains how and why we collect and use your personal information;
- Explains how we protect the personal information we collect; and
- Explains the rights and choices you have in relation to your personal information.
This Policy applies if you use our services (referred to in this Policy as “our Services”). Using our Services means:
- Buying / Ordering services or products from any of our subsidiaries over the phone, in store, or online
- Using any of our platforms, including websites (“our Websites”), public Wi-Fi networks, or mobile applications (“our Mobile Apps”)
- Taking part in our promotions & competitions and registering to receive our newsletters and offers
This Policy also applies if you contact us or we contact you about our Services.
PERSONAL INFORMATION WE COLLECT
When you register to our services, we may collect:
- Your personal details, including your postal and billing addresses, email address (es), phone number(s)
When you shop with us online, browse our our Mobile Apps, or connect to Wi-Fi networks we provide, we may collect:
- Information about your online purchases (for example: what, when, where you ordered / bought and how you paid);
- Information about your online browsing behavior on our Websites, Mobile Apps and public networks and information about when you click on one of our adverts (including those shown on other organizations’ websites);
- Information about devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers); and
- Information about your precise geolocation.
When you use any of our loyalty program(s) to shop with us, we may collect:
- Transaction information, including the in-store and online purchases you earn points for and how you use your points, coupons, and vouchers within our subsidiaries or with other partners.
When you contact us or we contact you or you take part in promotions, competitions, surveys or questionnaires about our Services, we may collect:
- Personal information you provide about yourself;
- Details of emails and other digital communications we send to you including information about the emails you open and links in them that you click on; and
- Your feedback and contributions to customer surveys and questionnaires.
Other sources of personal information:
We may also use personal information from other sources, such as specialist companies that supply information, online media channels, our partners and public registers. We may collect the following types of personal information about you from other sources: contact details, credit history, purchases, interests, preferences, or other types of publicly available information. This other personal information helps us to:
- review and improve the accuracy of the data we hold; and
- improve and measure the effectiveness of our marketing communications, including online advertising.
We may be required by law to collect personal information about you or as a consequence of any contractual relationship we have with you.
If you choose not to provide your personal information to be used in accordance with this Policy, you will still be able to visit our Platforms but you may not be able to access certain options, products or services, and in some cases we may not be able to fulfil a service you request.
WHY AND HOW WE USE YOUR PERSONAL INFORMATION
Make our Services available to you:
We use your personal information to provide the services you have requested, including:
- Processing your orders and refunds; and
- Managing the accounts, you hold with us.
This is so we can provide the services to you in line with our contractual obligations to you.
Personalize your experience:
We may use your personal information to personalize the marketing messages we send to you and to make them more relevant and interesting, as this is in our legitimate business interests. Where necessary we will obtain your consent first. We may use your personal information for this purpose in the following ways:
Contact and interact with you:
- Using your online browsing behavior as well as your in-store and online purchases to help us better understand you as a customer and provide you with personalized offers and services;
- Providing you with relevant marketing communications (including by email, post, telephone, SMS, or online advertising), relating to products and services we offer, and those of our suppliers and partners. As part of this, online advertising may be displayed on Our Websites and on other organizations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of our suppliers and partners;
- To help us to better understand you and provide you with services and marketing communications, that are relevant to your interests, we combine personal information we collect when you make purchases in-store with personal information collected from our Websites, Mobile Apps.
We may use your personal information when we communicate with you, in order to:
- Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us;
- Manage promotions and competitions you take part in, including those we run with our suppliers and partners;
It is in our legitimate business interests that we are able to provide you with appropriate responses and provide you with notice about our services.
Manage and improve our day-to-day operations
We analyze information about how you use our services to:
- Manage and improve our Mobile Apps;
- Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you;
- Detect and prevent fraud or other crime.
It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our services to improve it.
SHARING PERSONAL INFORMATION
We may share the personal information collected by any of our subsidiaries with our other subsidiaries for the purposes listed above.
We may share your personal information with other companies that sell products through our Services ("Retail Partners"). We only share personal information that enables our Retail Partners to provide their services. For example, when you shop online or in-store we will give the relevant Retail Partner your name, contact details, and address so that they can deliver your items.
We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing and combining data, processing payments and delivering orders. We only share personal information that enables our Service Providers to provide their services.
Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products and services, as well as those of our suppliers and our Retail Partners, on those online media channels on our behalf. For example, you may see an advert for our products and services when you use a particular social media site.
SHARING PERSONAL INFORMATION WITH OTHER ORGANISATIONS
We may share personal information with other organizations in the following circumstances:
- If any applicable law or a public authority says we must share the personal information;
- If we need to share personal information in order to establish, exercise or defend our legal rights (this includes providing personal information to others for the purposes of preventing fraud and reducing credit risk);
- To an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organization receiving your personal information can use your personal information in the same way as us
- To any other successors in title to our business; or
- To anyone to whom we transfer or may transfer our rights and duties under our agreement with you.
TRANSFER OF YOUR PERSONAL INFORMATION
Your personal information may be transferred to, stored, and processed in a country that is different from your country of residence or our country of incorporation.
In any case, we have put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your data is adequately protected.
In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.
HOW WE PROTECT PERSONAL INFORMATION
We maintain physical, technical, and organizational safeguards to secure your personal information from unauthorized access, use, alteration and destruction. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorized or unintended access that is beyond our control.
We operate channels, pages and accounts on some social media sites to inform, assist and engage with customers. We monitor and record comments and posts made on these channels about us so that we can improve our services.
However, we will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
All marketing communications we send to you will provide you with a way to withdraw your consent to future marketing. If you no longer wish to receive promotional materials you may opt-out from receiving these communications or change your account settings, this will remove you from marketing lists.
Please note that if you unsubscribe from marketing communications you will still receive operational and service messages from us regarding the services or products you bought from us and responses to enquiries made to us, and that we may hold your details on a suppression list so we don't send you marketing communications in the future.
COOKIES AND SIMILAR TECHNOLOGIES
Improve the way our Websites and Mobile Apps work
Cookies allow us to improve the way our Mobile Apps work so that we can personalize your experience and allow you to use many of their useful features.
Improve the performance of our Mobile Apps
Cookies can help us to understand how our Mobile Apps are being used, for example, by telling us if you get an error messages as you browse. These Cookies collect data that is mostly aggregated and anonymous.
Deliver relevant online advertising
Cookies used for this purpose are often placed on our Mobile App by other organizations, and always with our permission. These Cookies may collect information about your online behavior, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Mobile App and on other organizations’ websites. You may also see adverts for other organizations on our Mobile App.
To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected (e.g. Loyalty program).
Measuring the effectiveness of our marketing communications, including online advertising
Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.
Your choices when it comes to Cookies
You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device.
If you choose to disable some or all Cookies, you may not be able to make full use of our platforms. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use some of our products and services that require you to sign in.
AGGREGATE DATA, DATA ANALYTICS AND SOCIAL MEDIA FUNCTIONALITY
We may aggregate personal information and remove any identifying elements in order to analyze patterns and improve our marketing and promotional efforts, to analyze Platform use, to improve our content and product offerings, and to customize our Platforms’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.
We gather certain usage information like the number and frequency of visitors to our Platforms. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behavior to better understand and serve you.
If you use buttons on our Platforms linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from our Platforms may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers, or generally to anyone who has access to your profile page).
In addition, you have certain rights regarding your personal information, subject to local law. These include the following rights to:
- Rectify the information we hold about you;
- Erase your personal information;
- Restrict our use of your personal information;
- Object to our use of your personal information;
- Withdraw any consents you have provided for our use of your personal information;
- Receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
- Lodge a complaint with your local data protection authority.
If you would like to discuss or exercise such rights, please contact us at the details below.
If you are concerned that any of the information, we hold about you is incorrect, or out of date, please write to the address above to report your concerns and we will take appropriate steps to amend our records.