Privacy notice

Introduction

Welcome to the C.Brewer & Sons Limited's (Brewers) privacy notice.

Brewers respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. Important information and who we are

    Purpose of this privacy notice

    This privacy notice aims to give you information on how Brewers collects and processes your personal data through your use of its websites, including any data you may provide through our websites when you interact with us, for example, sign up to our newsletter, purchase a product or service or take part in a competition.

    Our websites are not intended for children and we do not knowingly collect data relating to children.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

    Our websites include brewers.co.uk, brewershome.co.uk, caneadam.co.uk, designerpaint.com, and wallpaperdirect.com.

    Controller

    C. Brewer & Sons Limited is the data controller and responsible for your personal data (referred to as “Brewers”, "we", "us" or "our" in this privacy notice).

    We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

    Contact details

    Our full details are:

    Full name of legal entity:
    C.Brewer & Sons Limited
    Name or title of data privacy manager:
    Group Legal Adviser
    Email address:
    data@brewers.co.uk
    Postal address:
    Customer Services, C.Brewer & Sons Ltd, Maple Road, Eastbourne, BN23 6NY, United Kingdom.
    Telephone number:
    toll free 00-0800-1008-833

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

    Changes to the privacy notice and your duty to inform us of changes

    This version was last updated on 14 May 2018.

    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.

    Third-party links

    Our websites may include links to third-party websites, plug-ins and applications. 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 statements. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.

  2. The data we collect about you

    Personal data, or personal information, 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 and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes first name, last name, username or similar identifier, title, and date of birth and, if opening an account, passport no, driving licence or similar identification document as proof of identity together with a utility bill as proof of address.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes 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 websites.
    • 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 websites, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  3. How is your personal data collected?

    We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • purchase or apply for our products or services;
      • create an account on our websites;
      • subscribe to our service or publications;
      • request marketing to be sent to you;
      • enter a competition, promotion or survey; or
      • give us some feedback.
    • Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
    • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
      • Technical Data from the following parties:
        1. analytics providers such as Google based outside the EU;
        2. advertising networks such as Quidco based inside the EU; and
        3. search information providers such as Google and Microsoft (Bing) based outside the EU.
      • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal and Barclays based inside the EU.
      • Identity and Contact Data from lead generation campaigns run by third parties such as Awin, BPi and Barbour BP.
      • Identity and Contact Data from trade associations such as the Painting and Decorating Association based inside the EU.
      • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  4. How we use your personal data

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

    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • 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.
    • Where we need to comply with a legal or regulatory obligation.

    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

    Purposes for which we will use your personal data

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

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
    To register you as a new customer
    1. Identity
    2. Contact
    Performance of a contract with you
    To process and deliver your order including:
    1. Manage payments, fees and charges
    2. Collect and recover money owed to us
    1. Identity
    2. Contact
    3. Financial
    4. Transaction
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you which will include:
    1. Notifying you about changes to our terms or privacy policy
    2. Asking you to leave a review or take a survey
    1. Identity
    2. Contact
    3. Profile
    4. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary to comply with a legal obligation
    3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
    To enable you to partake in a prize draw, competition or complete a survey
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
    1. Identity
    2. Contact
    3. Technical
    1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    2. Necessary to comply with a legal obligation
    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    6. Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences
    1. Technical
    2. Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
    To make suggestions and recommendations to you about goods or services that may be of interest to you
    1. Identity
    2. Contact
    3. Technical
    4. Usage
    5. Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business)

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and, in particular, we will always offer an ‘opt out’.

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

    Third-party marketing

    We will get your express opt-in consent before we share your personal data with any company other than Brewers for marketing purposes.

    Opting out

    You can ask us or third parties 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 details set out in Section 1, above. In addition, you can also opt out directly with third parties such as Google Analytics Remarketing by using the opt-out browser add-on https://tools.google.com/dlpage/gaoptout/

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

    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, please note that some parts of the relevant website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

    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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    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 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.

  5. Disclosures of your personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

    • Our other trading divisions, but at all times we shall remain the data controller and your personal data shall only be used for the purpose we collected it.
    • External Third Parties as set out in the Glossary.
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    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.

  6. International transfers

    Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  7. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. 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.

  8. Data retention

    How long will you use my personal data for?

    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.

    By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

    In some circumstances you can ask us to delete your data: see Request erasure of your personal data below for further information.

    In some circumstances we may anonymise your 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 notice to you.

  9. Glossary

    Lawful basis

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    Third parties

    External Third Parties

    • Service providers acting as processors based inside and outside the EU who provide IT and system administration services (for example, Worldapp and Causeway Technologies Limited), and mailing services (for example, HubSpot, MailChimp and MetaPack).
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
    • Service providers acting as processors or joint controllers including review websites such as Trustpilot and Royal Mail.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
    • Fraud prevention agencies, and credit reference agencies based in the United Kingdom when you apply to open an account with us.

    You have the right to:

C. Brewer & Sons Limited
14 May 2018

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