When you are using the Biagio the Jewellers website, Biagio the Jewellers Ltd is the data controller.
For simplicity throughout this policy, ‘the Company’ means the Site and the Stores.
2. LEGAL BASES FOR DATA COLLECTION AND USE
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent, for example, when you tick a box to receive newsletters.
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 need to collect your address details to deliver your purchase and will pass them to our courier.
If the law requires us to, we may need to collect and process your data. For example, we can pass on the details of people involved in fraud or other criminal activity affecting the company to law enforcement.
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 impact your rights, freedom or interests. For example, we will use your purchase history to send you or make personalised offers. We may also combine the shopping history of many customers to identify trends and ensure we keep up with demand, or to develop new products and 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 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 Store or on the Site.
- 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 purchase a product or service in-store or by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask one of our employees to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event, for example, a wedding rings event.
- 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 employees 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 a Store, an employee may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
- We collect data from publicly-available sources 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 Stores which have CCTV systems operated for the security of both customers and employees, these systems may record your image during your visit.
4. PERSONAL INFORMATION WE COLLECT
- When you make a purchase or attempting to make a purchase through the Site, we collect certain information from you, including 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 in-store, online, by phone or post. 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.
- Details of your shopping preferences. For example, which of our shops you prefer to visit and where you redeem your vouchers.
- Details of your visits to our website and which site you came from to ours.
- When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.” We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons”, “tags” and “pixels” are electronic files used to record information about how you browse the Site.
- 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.
- Additionally, your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information.”
5. HOW AND WHY DO WE USE YOUR PERSONAL INFORMATION?
We want to give you the best possible customer experience, so to help get to know you we may combine 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.
If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. However, please note that 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 an example how we’ll use your personal data and why:
- To process any orders that you make by using our website 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 log-in and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
- To protect our customers, premises, assets and employees from crime, we operate CCTV systems in our stores 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. Our 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 and telephone 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 website, 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 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 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
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you do not have to complete them.
- To build a picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the Company, third parties and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.
6. HOW WE PROTECT YOUR DATA
We understand 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 to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
7. HOW LONG DO WE KEEP YOUR 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.
8. WHO WE SHARE YOUR 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.
- Data insight companies to ensure your details are up to date and accurate.
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 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.
To help personalise your journey through the Site we currently use the following companies, who will process your personal data as part of their contracts with us:
- Brighter Splash
For example, we use Mailchimp to collect subscription email addresses–you can read more about how Mailchimp uses your Personal Information here: https://mailchimp.com/legal/privacy/.
We also use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.
You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
9. WHERE YOUR DATA IS 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.
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Company 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.
10. WHAT ARE YOUR RIGHTS?
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.
- 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).
- 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 (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 Company holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Biagio the Jeweller, Pioneer Square, Bicester, Oxfordshire, OX26 6FA or email email@example.com. 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.
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. BEHAVIOURAL ADVERTISING
We use your personal data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
12. DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
13. HOW TO STOP THE USE OF YOUR DATA FOR 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 online account, log-in into your Biagio account, visit the ‘My Account’ area of the Site and change your preferences.
- Write to Biagio the Jewellers, Pioneer Square, Bicester, Oxfordshire, OX26 6FA or you can also complete the form http://www.biagiothejewellers.com/my-preferences to amend your contact 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. IF YOU LIVE OUTSIDE THE UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
If you have any further questions or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org or by mail using the details provided below:
Biagio the Jewellers, Pioneer Square, Bicester, Oxfordshire, OX26 6FA, United Kingdom
Phone: 01869 252323
Last Updated: 16/05/2018