ABOUT THIS POLICY
It also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation (“GDPR”) and other related legislation which relates to the use of personal data.
We may change this policy from time to time by updating this page.
Additional information may be provided on particular pages of this website for example, on any specific pages where we collect personal data and you should also refer to those. We also operate cookies on our website and information about that is also provided separately in our Cookies Policy.[WU1]
HOW TO CONTACT US
Contact: The Data Protection Officer
Address: Easy Bathrooms, 27 Oakwell Way, Birstall, WF17 9LU
Email: [email protected]
Tel: 0330 660 1120
You have the right to make a complaint to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns before you approach the ICO so please contact us in the first instance using the details above.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. For example, we provide links to our social media pages. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. You should read any policies and other statements on such websites carefully.
We also use the following third-party service providers in relation to our payment and financing arrangements:
- PayPal to offer a facility whereby you can make payment for your order via PayPal. When you make a payment, you will be transferred to PayPal’s website and you will be asked to provide certain personal data and financial information such as credit card details.
- Sage Pay for processing card payments. When making payment for your order, you will be asked to submit certain financial information such as credit or debit card details.
- V12 Retail Finance to offer payment using various financing options (where available). You will be asked to provide certain personal data and financial information if you opt to use this facility (either online or in-store as applicable).
In each of the cases above, any personal data you provide will be collected and dealt with by PayPal, Sage Pay or V12 Retail Finance (as applicable) and you should refer to that applicable party’s privacy policies and notices in relation to this, for information about how the personal data you provide will be used by it.
THE 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 which has been anonymised such that a person’s identity is removed.
We may collect, use, store and transfer different kinds of personal data. The categories of personal data which we use include:
- Identity and Contact Data such as names, titles (including job title) and other identifiers together with delivery addresses, home or business addresses, email address and telephone numbers. This also includes payment information and information a trade customer may supply on a business card or other form of proof of business.
- Technical Data including 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 this website. This may also include information about how you use our website and our products.
- Employment Data such as a candidate or enquirer’s CV, employment references and career history information.
- Profile Data such as username and password details.
- Marketing and Communications Data includes preferences in receiving marketing from us and your communication preferences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, under the terms of a contract we have with you or for another lawful reason and you fail to provide that data (for example in order to take payment from you or to deliver goods to you), we may not be able to fully perform our obligations in accordance with our contract, provide you with the information you require or otherwise properly deal with your request.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect personal data in a number of different ways. For example, we may collect personal data through this website (including via the email contact link on our ‘Contact Us’ page, or via the contact form on the ‘Book an Appointment’ page), by email, over the phone or through face to face interactions in our stores.
The personal data we collect is usually provided by you directly, though in some cases it might be provided by someone else, for example if they place an order on your behalf.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. The information below explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Operating our website
We may process your identity and contact data, technical data and profile data, for the purposes of administering and operating this website. This may include troubleshooting, data analysis, testing, system maintenance and support. This helps us to continually improve this website and the products we can offer. Where you buy products from us, we also use your data for the proper operation of the e-commerce function of the website. We process your data in this way on the basis that this is necessary for our legitimate interests in managing, administering and improving this website, its functionality and the products we offer.
Providing our products to our consumer customers
If you are a consumer customer, we will process your identity and contact data in order to provide and deliver our products to you, and to deal with any ancillary matters such as administering payment from you when you place an order, corresponding with you in relation to your order and assisting with any follow up issues or returns. We process your data in this way on the basis that it is necessary to do so for the performance of the relevant contract that you have entered into with us.
Opening trade accounts and providing products to trade customers
Where you are a trade customer, we may process your identity and contact data in order to open and administer the account which you or the organisation you represent has with us and in order to provide our goods to you, including, for example, to contact you with account queries or deal with invoicing as well as for our internal record keeping. We may also need this information for more general customer service matters. These types of data are used in our legitimate interests in supplying our products to your business, and in ensuring that the products we supply are managed, such as to recover debts due to us.
Responding to enquiries and applications
If you contact us with a comment, enquiry (for example via the email link on our “Contact Us” page) or if you want to speak to us, we will use your identity and contact data in order to respond to you. Processing your data in this way is necessary for our legitimate interests in the operation of our business in order to respond to your enquiry and to provide our customer service to you.
We may also process your identity and contact data and employment data if you apply for a job with us or send us your CV, for example via the email address on the ‘Careers’ page of our website. We do this to assess your suitability as a candidate for any actual or speculative employment positions, and may use it to arrange an interview with you. We process your data in this way on the basis that it is necessary for our legitimate interests in the operation of our business, and to assess your suitability for potential employment placements of interest to you.
Providing our 3D bathroom design service and after sales visits
If you request an appointment with us for our 3D design service, either by attending an appointment at one of our stores, or arranging for us to visit your home, we will process your identity and contact data to contact you to arrange our appointment. We may also use your contact data to find the location of our appointment, or to view any publicly available information about your property such as details on Zoopla, or Google Maps or Google Street View, for example to assist us in understanding the style of your property. We may also use the same data to arrange and attend any after sales visits. We process your data in this way on the basis that it is in our legitimate interests in following up your request and providing our service to you.
Disclosure of data to third parties
We may process your identity and contact data and technical data to ensure that our third-party providers can perform their obligations to us. For example, we will need to disclose name and address details to our couriers and other delivery providers so that your goods can be delivered to you. Processing in this way is necessary to enable us to fulfil our contractual obligations so as to deliver the goods. In other cases, we might need to pass your details to our IT support service providers, for example, if we need their support in operating our e-commerce function. We do this on the basis that it is in our legitimate interests to do so by ensuring that such third-party providers can ensure the proper function of our website and deal with any problems that may arise.
Engaging with service providers and suppliers
We will process identity and contact data and technical data to source and engage with business representatives of our service providers, suppliers and third-party contractors, including our couriers. This may be to get in contact with enquiries or to place orders. Processing data in this way will be necessary for our legitimate interests in both sourcing services and supplies and in ensuring that our providers perform their obligations to us. For example, we may use contact data to manage the relationship with such third parties
Marketing updates and our newsletter
We may from time to time contact you with marketing communications for example, to tell you about new promotions, or other products we offer which we think may interest you, or if you have subscribed to receive our newsletter. To do this we will use your identity and contact data, and may also use technical, profile and marketing and communications data. We process your data in this way as it is necessary for our legitimate interests to develop, market and promote our products. Further information about our marketing activities can be found below.
In addition, we may disclose information about you to the extent that we are required to do so by law, in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention) and/or where we may otherwise do so in accordance with applicable data protection legislation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us and further information is provided about this below.
MARKETING AND PROMOTIONS
From time to time we may use your data including identity and contact data, technical data and profile data and marketing and communications data, to contact you with promotional and marketing communications, and information about our products. You will receive marketing communications from us if you have agreed to be included on our marketing database or in some cases where you have purchased products from us and have chosen not to unsubscribe.
The type and content of marketing messages is outlined when you sign up to our marketing database. Email marketing messages may contain tracking links or similar technologies in order to track user activity within email marketing messages for example so that we can see what products you might be interested in.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time, using the contact details above.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please also note that 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.
If you would like further information about how we use personal data and the purpose which we might use it for, please contact us.
DISCLOSURES OF YOUR PERSONAL DATA
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Union.
We take reasonable, technical and organisational precautions and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
- Request access to your personal data (a “data subject access request”). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
- Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data which override your rights and freedoms.
- Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
- Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.
- Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.
EXERCISING YOUR RIGHTS
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests in which case we will keep you updated.