Protecting Your Privacy – Robert Geary Ltd.

CONTENTS OF PRIVACY POLICY

1. Introduction

This Privacy Notice explains 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 here, but we want you to be fully informed about your rights, and how Robert Geary Ltd. uses your data. 

We hope the following sections will answer any questions you have but if not, please do get in touch with us. 

Our products and services are aimed at those aged 16 and over. 

It’s likely that we’ll need to update this Privacy Notice from time to time. 

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 company 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 will also send you direct marketing emails when you shop with us and do not choose to opt out – this is often called a ‘soft opt in’ 

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.  

With your consent, or when you shop with us and do not choose to opt out from receiving our emails (‘soft opt in’) we will use your personal data, preferences and details of your transactions to keep you informed by email and web. about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.  

3. When do we collect your personal data? 

When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the company on the phone, in a shop 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 shop online, we capture information through cookies and similar technologies, you can manage these when you visit our site. 

When you engage with us on social media. 

When you enter prize draws or competitions. 

When you comment on or review our products and services. 

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. 

Personal details which help us to recommend items of interest. 

We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.  

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? 

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. 

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. 

Here’s how we’ll use your personal data and why: 

To process any orders that you make by using our websites. 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 website. 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 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, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email 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 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. 

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 

We record your interactions with us e.g. looking at how often you might shop with us or how much you spend. We do this to create a profile on how you interact with the Partnership and, in turn, that can affect how we engage you. For example, if you shop with us regularly, then this can affect what offers and rewards you might receive from us. We rely on our legitimate interest to undertake this activity.

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 we have gathered, for example your shopping history. 

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 website using ‘https’ technology. 

Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected. 

We regularly monitor our system for possible vulnerabilities and attacks.  

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. 

Some examples of customer data retention periods:  

Warranties 

If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

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 anonymous. 

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. See our Cookies Notice for details. 

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 example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them. 

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. 

10. What are your rights over your personal data? 

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. 

The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).  

A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible. 

Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.  

That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances. 

That we stop using your personal data for direct marketing (either through specific channels, or all channels). 

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 (so 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 by completing an online form. 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. 

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. 

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.