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CONTENTS OF PRIVACY POLICY
1. Introduction
2. Explaining the legal bases we rely on
3. When do we collect your personal data?
4. What sort of personal data do we collect?
5. How and why do we use your personal data?
6. Combining your data for personalised direct marketing
7. How we protect your personal data
8. How long will we keep your personal data?
9. Who do we share your personal data with?
10. What are your rights over your personal data?
11. How can you stop the use of your personal data for direct marketing?
12. Contacting the Regulator
13. Klarna
14. If you live outside the UK
15. Any questions?
*This Policy was last updated 02/04/2018*
1. Introduction
This Privacy Policy 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 An n’s Cottage uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Policy from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box 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.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
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.
Legal compliance
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 Ann’s Cottage to law enforcement.
Legitimate interest
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 personalised offers.
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 may also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
3. 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 from Ann’s Cottage on the phone, in a shop or online.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you create an account with us.
- When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you join the Ann’s Cottage loyalty programme.
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- When you fill in any forms. For example, if an accident happens in store, a Partner may 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 use our car parks and shops which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.
4. What sort of personal data do we collect?
If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number.
Details of your interactions with us through telephone, in store, online or by using one of our apps.
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, gift list and wish list choices, 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 shops you prefer to visit and where you redeem your vouchers.
Details of your visits to our websites or apps, and which site you came from to ours.
Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.
Personal details which help us to recommend items of interest.
For example, you might tell us your clothing size, which we’ll use to guide our suggested items. Or you might share information on your skin type which allows us to recommend appropriate wetsuit brands.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
· Payment card information.
· Your comments and product reviews.
· Your image may be recorded on CCTV when you visit a shop or car park.
· Your car number plate may be recorded at some of our car parks to manage parking restrictions.
· 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. Learn more about this.
· Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
5. 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. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
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 an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
· To process any orders that you make by using our websites, apps or in store. 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 business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
· To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our stores and car parks which record images for security. We do this on the basis of our legitimate business interests.
· We manage our car parks in conjunction with AS Parking (opens in a new window; please note we can't be responsible for the content of external websites)
· 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 and through our contact centres 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’ll 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 Policy, product recall Policys, 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 or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app 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 browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
· To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of 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 to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
· To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across Ann’s Cottage, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest.
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.
· For Ann’s Cottage members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become an Ann’s Cottage member. If you don’t want to continue receiving my Ann’s Cottage offers, you will need to unsubscribe from newsletters either from them directly or under your account preferences.
· For Ann’s Cottage loyalty cardholders: to provide you with tailored offers, printed with your till receipt at the end of a shopping trip. These are based on an analysis of previous purchases using your Ann’s Cottage card, including the items you’ve just bought. We do this on the basis of our legitimate interest to show you relevant offers. Of course, you’re free to choose whether to take advantage of them.
6. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data as described above, for example your shopping history at Ann’s Cottage. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.
7. How we protect your personal data
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 and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
DATA CENTRES
Your data is held at 2 data centres.
DX3 Servers
‘All our servers are located within IOMART data centres certified to ISO9001 Quality Management System, ISO 27001 Information Security Management System standards & ISO 20000: The International Standard for Service Management. Each UK data centre is built using Tier 1 infrastructure, is N+ in design and is safe, secure and staffed 24 x 7. 24 hour Manned Security, Biometric Access & Intruder Alarms. We surveyed the UKs data centres and Iomart's DCs were simply the best available.’
GiveX Loyalty Data Centre
‘Givex monitors all IP traffic at our firewall using standard and custom processes. All application and data servers reside behind a network firewall. No access to database servers are provided from the public network. All connections need to be TLS 1.2 or higher. Givex is PCI Level I compliant and we also conduct scheduled SSAE 16 internal self-audits.’
8. How long will 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 business planning.
Some examples of customer data retention periods:
Orders
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. In the case of certain products, such as electrical and nursery items, we’ll keep the data for 10 years.
Warranties
If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s 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 services.
· 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. See our Cookies Policy for details.
· Data insight companies to ensure your details are up to date and accurate.
To help personalise your journey through Ann’s Cottage websites we currently use the following companies, who will process your personal data as part of their contracts with us:
· SpringBot
- GiveX
10. 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 cases.
· The correction of your personal data when incorrect, out of date or incomplete.
· 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 Partner 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).
You have the right to request a copy of any information about you that Ann’s cottage holds at any time, and also to have that information corrected if it is inaccurate.
To ask for your information, please contact: Ann’s Cottage Customer Service, Unit 4, Higher Pityme Farm, Pityme Business Centre, St Minver, Wadebridge, Cornwall, PL27 6NU,
or call us on 01208 869924
To ask for your information to be amended, please update your online account, or contact our Customer Services team.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
11. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
If you have an account, log in into your Ann’s Cottage account, visit the ‘My Account’ area and change your preferences.
Write to Customer Service Team, 2A St Columb Industrial Estate, St Columb, Cornwall, TR9 6SF
Call us on 01208 869924
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
12. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
13. Klarna
In cooperation with Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden, we offer you the following payment options.
In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.
General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.
14. If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Policy. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
Australia
For the purposes of this Privacy Policy, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.
If you are in Australia you may submit any questions, comments or complaints to our UK-based Customer Service Team who will come back to you within 30 days.
If you are contacting us to complain about an alleged breach of this Privacy Policy or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.
We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.
If we have not come back to you within 30 days, or you are not happy with the response that you’ve received, you may submit a complaint to the Office of the Australian Information Commissioner. (opens in a new window; please note we can't be responsible for the content of external websites.)
We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
USA
To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our Cookies Policy.
Canada
As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.
The personal data we process may be accessed by people within Ann’s Cottage, or by our third-party service providers, who require access for the purposes indicated in this Privacy Policy, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.
If you have any questions, please contact our Customer Service Team.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, (opens in a new window; please note we can't be responsible for the content of external websites) or in some Canadian provinces, your local Privacy Commissioner.
South Korea, Malaysia, Singapore, Qatar
Terms used in this Privacy Policy shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).
By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Policy and our Cookies Policy, including for analytics and research into website use.
Hong Kong
When you agree to receive direct marketing emails from us, we’ll send you promotions on products we sell at Ann’s Cottage.
If you are in Hong Kong you may submit a complaint to our UK-based Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive, you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.
15. Any questions?
We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Or write to us at Customer Service Team, 2A St Columb Industrial Estate, St Columb, Cornwall, TR9 6SF
Or call us on 01208 869924
This Policy was last updated on 02/05/2018