PROTECTING YOUR PRIVACY
GEORGE PRAGNELL LIMITED
CONTENTS OF PRIVACY NOTICE
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- Combining your data for personalised direct marketing
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Contacting the Regulator
- If you live outside the UK
This policy (together with any privacy notice displayed on https://www.pragnell.co.uk (“our site”) or otherwise notified to you) sets out the basis on which we will process any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (2016/679) (“GDPR”) the data controller is George Pragnell Limited of 5-7 Wood Street, Stratford-upon-Avon, CV37 6JA. We will, in processing your data, comply with the GDPR and all other data protection and privacy laws applied in England from time to time.
This Policy 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 know that there’s a lot of information here, but we want you to be fully informed about your rights, and how George Pragnell Limited (which we’ll refer to as ‘George Pragnell’) uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
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 sign up 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.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, for us to conduct a home visit for any need we’ll collect your address details to deliver your purchase.
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 George Pragnell 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 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 use your address details to send you direct marketing information by post, sending you invitations or telling you about products and services that we think might interest you.
3. When do we collect your personal data?
When you visit our shops or website, and use your account to buy products and services
When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
When you have an account created 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 colleagues to email you information about a product or service.
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.
When you fill in any forms. For example, if an accident happens in store, a colleague may collect your personal data.
When you’ve given a third party permission to share with us the information they hold about you.
When you use our shops, which usually have CCTV, systems operated for the security of both customers and Partners. 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, memorable dates, orders and receipts, preferences, email and telephone number. For your security, we will also keep an encrypted record of your login password.
· For the avoidance of doubt, we do not store any payment card details
Details of your interactions with us in store, or online.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, brands you show interest in, 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 license). 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 visits to our websites.
· Personal details which help us to recommend items of interest.
For example, you might tell us your favourite item of fine jewellery, which we’ll use to guide our suggested items.
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.
· Your comments and product reviews.
· Your image may be recorded on CCTV when you visit a shop.
· 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, 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 invites to events, 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.
For example, if you’ve asked us to let you know when an item comes 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 website, or in store. If we do not collect your personal data during checkout, we will not 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 send you email notifications when you place a product in your basket and you abandon browsing before completing your checkout. We do this based on our legitimate interest.
· 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 will also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We will 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 staff 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. 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, and telephone about relevant products and services including invitations to 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, service reminders 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 will use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive 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 have 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 send you communications required as part of our legitimate business interests to inform you of product becoming available for collection
· 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 are free to opt out of receiving these requests from us at any time by contacting us either in the showroom, by letter or by email.
· To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across George Pragnell, 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.
· To process your booking/appointment requests. Sometimes, we will need to share your details with a third party who is providing a service (such as delivery couriers visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we would be unable to fulfil your request.
· Data may be used to create / find lookalike customers on the legal basis of legitimate interest and be shared with third parties for this purpose. Communications may be sent to lookalike customers, as a result of this work, again on the basis of legitimate interest.
6. Combining your data for personalised direct marketing
We want to bring you invitations to events, and product details 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 across George Pragnell as described 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 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.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us indefinitely (or unless requested otherwise by yourselves) so we can comply with our legal and contractual obligations, and provide a record if needed by customers for insurance purposes.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties for legitimate purposes.
For example for fraud management, to handle complaints, or to help us personalise our offers to you. In these instances, we demand these organisations 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:
· Our payment processing companies who process payments on our behalf
· 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.
· 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:
· 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.
· We may be asked to share data with our suppliers. We will only do so with your prior consent.
· We may, from time to time, expand, reduce or sell George Pragnell and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
10. 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.
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 George Pragnell 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.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. 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.
· 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
· 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. You have the right to request a copy of any information about you that George
Pragnell holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information or for amendments to the information, please contact the Chief Operating Officer, George Pragnell Limited, 5-7 Wood Street, Stratford-Upon-Avon, CV37 6JA or email [email protected]
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.
12. How can you stop the use of your personal data for direct marketing?
Please write to the Chief Operating Officer, George Pragnell Limited, 5-7 Wood Street, Stratford-Upon-Avon, CV37 6JA or email [email protected].
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113 Or go online to WWW.ICO.ORG.UK/CONCERNS (opens in a new window; please note we can't be responsible for the content of ex
outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
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.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.