1. Introduction
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 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 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 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 the Partnership 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 will 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 our websites and use your
account to buy products and services in a shop or online.
When you create an account with us.
When you engage with us on social media.
When you download or install one of our apps.
When you join a 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.
Any individual may access personal data related to
them, including opinions. So if your comment or review
includes information about the Partner who provided that service, it may be
passed on to them if requested.
When you fill in any forms. For example, if an
accident happens in store, a Partner may collect your personal data.
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 Veema UK.
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. For your security, we?ll
also keep an encrypted record of your login password.
Details of your interactions with us through
contact centres, 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.
Copies of documents you provide to prove your age
or identity where the law requires this. (including your passport and driver's
licence). This will include details of your full name, address, date of birth
and facial image. If you provide a passport, the data will also include your
place of birth, gender and nationality.
Details of your shopping preferences.
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.
Personal details which help us to recommend items
of interest.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit a
shop or car park.
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.
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.
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.
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. We 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 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 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 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. 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.
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
gathered as described above, for example your online shopping history. 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.
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.
9. 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), such
as Australia or the USA.
International orders
If you are based outside the UK and place an order
with us, we will process the personal data that we collect from you in the UK.
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.
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.
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.
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 the we holds at any time.
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.
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 from that particular division.
If you have an account, log in into your account,
visit the ?My Account? area and change your
preferences.
Please note that you may continue to receive
communications for a short period after changing your preferences while our
systems are fully updated.
14. Any questions?
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 our Data
Protection Officer who will be pleased to help you:
Email us at info@rupalionline.com
Last updated on 27/04/2018
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