General Data Protection Regulation (GDPR)
Protecting your privacy
This Privacy Notice 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 and how we use your data.
It’s likely that we’ll need to update this Privacy Notice 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 basis which 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 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.
3. When do we collect your personal data?
• When you visit any of our websites, and use your account to buy products and services on the phone, in person 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 person or by phone but don’t have (or don’t use) an account.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you email about a product or service.
• When you enter prize draws or competitions.
• When you’ve given a third party permission to share with us the information they hold about you.
4. What sort of personal data do we collect?
• If you have a web account with us: your name, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
For example, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions and how and when you contact us, either by phone or email.
We collect data via Google Analytics, this data is anonymised and therefore can’t be used to personally to identify a user.
• Details of your visits to our websites or apps, and which site you came from to ours.
• Payment card information.
• Your comments and product reviews.
• 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?
• To process any orders that you make by using our websites, or in person. 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 legitimatee 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 logins from unexpected locations.
• 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.
• 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 trading points 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 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 Notice, product recall notices, 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 products and so on. We do so on the basis of your consent to receive notifications from 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 purch- chase 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
Of course, you are free to opt out of receiving these requests from us at any time by by updating your preferences in your online account
We 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.
Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
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 bet- ter, overall understanding of you as a customer, 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.
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 using ‘https’ techno- logy. 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.
8. How long will we keep your personal data?
We will keep your personal data for the duration of the period you are a customer of Suay. We shall retain your data only for as long as necessary in accordance with applicable laws.
On the closure of your account, we may keep your data for up to 7 years after you have cancelled your services with us. We may not be able to delete your data before this time due to our legal and/or accountancy obligations. We may also keep it for research or statistical purposes. We assure you that your personal data shall only be used for these purposes stated herein.
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 anony- mous.
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.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
For further information please contact our Data Protection Officer.
We currently use the following companies who will process your personal data as part of their contracts with us:
• Campaign Monitor
• Simian Enterprises
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
If you are based outside the UK and place an order with us, we will share the personal data that we collect from you to some of the companies listed above in order to process your order.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such as Australia or the USA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. 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.
• That we stop using your personal data for direct marketing (either through specific channels, or all chan- nels).
• 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 can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact The Data Protection Officer, Suay Design PO Box 5309, BN50 8BE or email firstname.lastname@example.org. 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 Notice.
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.
12. 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 from that particular division.
• If you have an account, log in into your account, visit the ‘My Account’ area and change your preferences.
• Write to us
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.