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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, 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 under the 2018 General Data Protection Regulations, and how Russell & Bromley uses your data; for example, we will explain things such as our identity checking procedure and how we use data to build a picture of you. 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 again 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.
The General Data Protection Regulations sets out a number of different reasons for which a company may collect and process your personal data, including:
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.
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.
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 Russell & Bromley to law enforcement.
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.
For example, if an accident happens in store, an employee may collect your personal data.
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, wish list choices, reward redemptions, web pages you visit and how and when you contact us. This helps us to provide you with the best service and to understand how we can improve our service based on your experience.
For example, which of our shops you prefer to visit and where you redeem your rewards.
For example, you might tell us your shoe size, which we’ll use to guide our suggested items. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us.
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:
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, to fulfil any contractual obligations such as refunds, guarantees and so on.
For example, by checking your password when you sign in and using automated monitoring of IP addresses to identify possible fraudulent sign ins from unexpected locations.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
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.
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.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
For example, by combining this data, this will help us personalise your experience and decide what content to share with you.
For example, Loyalty scheme members are informed by email of the rewards they have earned and the time frame they have, to spend it in. Without the data to do this, Loyalty scheme members may miss the opportunity to spend their rewards.
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 gathered across our business as described above. 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.
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 have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We secure access to all transactional areas of our website 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.
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.
We sometimes share your personal data with trusted third parties. They provide an integral part of the service we provide to you and support our business operations. Examples of the kind of third parties we work with are:
In order for us to accept an order on our website, we may disclose some of your personal details to a third-party, registered Credit Reference Agency which may keep a record of that information. You can rest assured that, should we need to do this, it will be for the sole purpose of validating your identity, that a credit check is not performed and that your credit rating will be unaffected. We do this on the basis of the consent you give to such checks being made when agreeing to the Terms and Conditions in the registration process.
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.
The following companies may process your personal data as part of their contracts with us:
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
For further information please contact our Data Protection Officer.
The information that we collect from you will not be transferred to or stored outside of the European Economic Area.
An overview of your different rights
Under the General Data Protection Regulations, you have the right to request:
You have the right to request a copy of any information about you that the Russell & Bromley holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Russell & Bromley Limited, 24-34 Farwig Lane, Bromley, Kent, BR1 3RB 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.
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.
There are several ways you can stop direct marketing communications from us:
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)
We hope this Privacy Notice 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 one of the following:
This Privacy Notice was last updated in May 2018.