If you have any questions at all about the way we handle your personal data as set out in this policy, please contact the Data Protection Officer (“DPO”) for Marshalls, C.E. Baxandall, at the above address, or by email to firstname.lastname@example.org. Our DPO represents the Marshalls Group as a whole, and any enquiries about how personal data is used by any Group entity should be directed to the DPO.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our site www.marshalls.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, request product samples or technical information, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your:
- Postal/delivery address;
- E-mail address;
- Telephone number;
- Financial and credit card information;
- Information regarding your marketing preferences;
- Details of your property;
- Technical specification;
- Personal description and photograph;
- Details of your business activities;
- Contact details for your employees, agents or contractors.
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information we receive from other sources. Where you have provided information or visited another of our websites, we may share that information across all the websites that we operate and combine it with information collected on this site. We are also working closely with third parties (including, for example, business partners, register members, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to communicate with you about your order for a product or service;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you including special offer and discounts. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form at the point of entering your data, or advise us in writing at the address and/or the email given in this Policy (see “Your rights”);
- to communicate with you about your order for a product or service;
- to review past purchases and viewing history on our website to tailor your online experience and special offers
- to contact you about leaving a review on a product/service or providing feedback once your order has been completed or the service has been provided;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer or other device.
- to help us review, develop and improve our product and services. For example monitoring sale and customer support calls for quality and training purposes.
- to carry out security checks to protect against fraudulent transitions and to detect and prevent criminal activity
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer or other device;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any other member of the Marshalls group, which means Marshalls plc and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, third party service providers, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, we may engage third party service providers to deliver orders, SMS text messages and email, process payments and refunds, carry out surveys and market research, provide customer service and handle claims. These third parties will have access to personal information needed to perform their functions, but may not use it for any other purpose.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We will only pass this information to a credit reference agency when we specifically tell you this.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If the company in the Marshalls group that is holding your personal information or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers and/or individuals with whom it has dealings in the course of its business will be one of the transferred assets.
We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where:
- we have your consent (if consent is needed), for example your consent to send you marketing emails;
- we need to use the information to comply with our legal obligations (for example, recording footage of your visit to our premises using our CCTV system);
- we need to use the information to perform a contract with you (for example, where you have ordered goods or services from us or our business partners or where you are supplying goods or services to us or to a business partner of ours); and/or
- it is fair to use the personal information either in our interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services, or to use non-privacy invasive technologies.
Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations.
We will not collect or use any personal information of this kind.
WHERE WE STORE YOUR PERSONAL DATA
We may need to transfer your personal information to territories that are outside the EEA. We will only transfer your personal information outside the EEA where either:
- the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or
- we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal information is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will never retain your personal information for any longer than is necessary for the purposes we need to use it for. We have a Document Retention Policy that explains how long data is kept for. If you would like to see a copy of this, please contact the DPO via email (email@example.com). In general terms:
- Where we have been using your personal information to provide you services, we will retain this information for a period of 7 years after the date you last used the service through our website.
- We may hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings.
You are entitled to exercise any of the following privacy rights:
- Right to object: You can object to our processing of your personal information. Please contact us as noted below, providing details of your objection.
- Access to your personal information: You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge by contacting us as noted below.
- Right to withdraw consent: If you have given us your consent to use your personal information to send you marketing emails, you can withdraw your consent at any time or by clicking the "unsubscribe" link in any marketing email which you receive.
- Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
- Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
- Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Please make all requests to exercise your privacy rights in writing to the DPO (firstname.lastname@example.org). We are required to verify your identity in order to process your request and may ask you to provide valid identification documents to allow us to do so.
We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection law.
THIRD PARTY WEBSITES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
CONTACT AND COMPLAINTS
You can make a complaint to us by emailing email@example.com or to the data protection supervisory authority, the Information Commissioner's Office in the UK, at https://ico.org.uk/.