PRIVACY POLICY

The Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, transfer, and otherwise process different kinds of personal data about you which we have grouped together as follows:

• Identity Data: Includes name, username or similar identifier, marital status, title, date of birth, and gender.
• Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
• Financial Data: Includes bank account and payment card details.
• Transaction Data: Includes details about payments to and from you and other details of products/services you have purchased from us.
• Technical Data: Includes information collected when you access our website or mobile applications, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or mobile applications.
• Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: Includes information about how you use our website, mobile applications, Wi-Fi, and similar electronic services.
• Marketing and Communications Data: Includes your marketing and communication preferences.
• CCTV Data: Includes footage from CCTV and other similar equipment which we operate in our stores.

Failure to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to provide you with products/services). In this case, we may have to cancel a product/service, but we will notify you if this is the case at the time.

How We Collect Your Personal Data

We use different methods to collect data from and about you, including as set out below:

1. Direct Interactions: You may give us your personal data in your direct interactions with us (e.g., Identity Data, Contact Data, and Financial Data) by filling in forms, through our mobile applications, or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
   • Enquire about, apply for, or order our products/services
   • Create an account
   • Subscribe to our communications
   • Request marketing to be sent to you
   • Enter a competition, promotion, raffle, or survey
   • Give us feedback or contact us
2. Website, Mobile Applications, and Cookies: As you interact with our website and mobile applications, we will automatically collect Technical Data about your device, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Notice for further details.
3. Technical Data from Third-Party Providers: Technical Data from third-party analytics providers, advertising networks, and search information providers.
4. Contact Data, Financial Data, and Transaction Data: Contact Data, Financial Data, and Transaction Data from providers of technical, payment, and delivery services.

How We Process Your Personal Data

We will only process your personal data when the law allows us to do so. Most commonly, we will process your personal data in the following circumstances:

• Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal or Regulatory Obligation: Where we need to comply with a legal or regulatory obligation that we are subject to.
• Consent: Where you have given us consent to process your personal data for a specific purpose. With limited exceptions (e.g., some of our electronic marketing), we do not rely on consent as a lawful basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes and Lawful Bases for Processing Your Personal Data

We have set out below a description of all the ways we plan to process your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

1. To register you as a new customer

   • Type of personal data: (a) Identity Data, (b) Contact Data
   • Lawful basis of processing: Performance of a contract

2. To process and deliver your order (including managing payments, fees, and charges, and collecting and recovering money owed to us)

   • Type of personal data: (a) Identity Data, (b) Contact Data, (c) Financial Data, (d) Transaction Data, (e) Marketing and Communications Data
   • Lawful basis of processing: (a) Performance of a contract, (b) Legitimate interests (to recover debts due to us)

3. To manage our relationship with you (including notifying you about changes to our terms or this notice and asking you to leave a review or take a survey)

   • Type of personal data: (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Marketing and Communications Data
   • Lawful basis of processing: (a) Performance of a contract, (b) Legal or regulatory obligation, (c) Legitimate interests (to keep our records updated and understand how customers use our products/services)

4. To enable you to take part in a prize draw, competition, raffle, or complete a survey

   • Type of personal data: (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data
   • Lawful basis of processing: (a) Performance of a contract, (b) Legitimate interests (to understand how customers use our products/services, to develop them and grow our business)

5. To administer and protect our business, website, and mobile applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)

   • Type of personal data: (a) Identity Data, (b) Contact Data, (c) Technical Data
   • Lawful basis of processing: (a) Legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise), (b) Legal obligation

6. To deliver relevant content and advertisements to you and measure or understand the effectiveness of our advertising

   • Type of personal data: (a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data, (f) Technical Data
   • Lawful basis of processing: Legitimate interests (to understand how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)

7. To use data analytics to improve our website, mobile applications, products/services, marketing, customer relationships, and experiences

   • Type of personal data: (a) Technical Data, (b) Usage Data
   • Lawful basis of processing: Legitimate interests (to define types of customers for our products/services, to keep our website and mobile applications updated and relevant, to develop our business, and to inform our marketing strategy)

8. To make suggestions and recommendations to you about products/services that may be of interest to you

   • Type of personal data: (a) Identity Data, (b) Contact Data, (c) Technical Data, (d) Usage Data, (e) Profile Data, (f) Marketing and Communications Data
   • Lawful basis of processing: Legitimate interests (to develop our products/services and grow our business)

9. To keep our stores safe and secure

   • Type of personal data: CCTV Data
   • Lawful basis of processing: Legitimate interests (to keep our stores secure and those within them safe)

Change of Purpose

We will only process your personal data for the purposes that we collected it, unless we reasonably consider that any further processing is compatible with the original purpose. If you would like an explanation as to how further processing is compatible with the original purpose, then please contact us.

If we need to process your personal data for an unrelated purpose, then we will notify you, and we will explain the lawful basis which allows us to do so.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing and Exercising Your Right to Opt-out of Marketing

You will receive marketing communications from us if you have requested information from us or purchased products/services from us and you have not opted out of receiving that marketing.

If you ask us to stop processing your personal data for marketing purposes (e.g., by following the opt-out links on any electronic marketing sent to you or by otherwise contacting us), then we will do so.

No Third-Party Marketing

We do not share your personal data with any third parties for their own marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, then some parts of our website or mobile applications may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice.