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, 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 under the 2018 General Data Protection Regulations, and how primarktool uses your data; for example, we will explain things such as our identity checking procedure and how we use data to build a picture of you. 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 again 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. Who are we?

In this Privacy Policy, references to “we” or “us” are to primarktool Online Limited,

3. Explaining the legal basis we rely on

The General Data Protection Regulations 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 primarktool 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.

4. When do we collect your personal data?

• When you visit our website and use your account to buy products and services.
• 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 join our loyalty scheme.
• When you contact us by any means with queries, complaints etc.
• When you ask one of employees to email you information about a product or service.
• When you enter prize draws or competitions.
• When you fill in any forms.
• When you receive an e-receipt.

For example, if an accident happens in 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 (such as Land Registry) when you have given them your consent to share information or where the information is made public as a matter of law.

5. 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 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, items viewed or added to your basket, wish list choices, reward redemptions, web pages you visit and how and when you contact us. This helps us to provide you with the best service and to understand how we can improve our service based on your experience.

• Copies of documents you provide where necessary, to prove your identity in support of a purchase. (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.

For example, which of our shops you prefer to visit and where you redeem your rewards.

• Details of your visits to our website and which site you came from to ours.
• Information gathered using cookies in your web browser. Learn more about how we use cookies.
• Personal details which help us to recommend items of interest.

For example, you might tell us your shoe size, 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.

• Payment card information.
• 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.

6. 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.

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 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 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, 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 send 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 sign in and using automated monitoring of IP addresses to identify possible fraudulent sign 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. We aim 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 new collections, trend stories, sales, 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 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, we’ll use data we hold about your favourite products and so on. We do so, on the basis of legitimate interest to enhance your experience on our site.

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 prize draw 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 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 our business, 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 what content to share with you.

• For Loyalty scheme members, to determine the most appropriate information to show you and to keep you updated on any points and reward balances outstanding. We do so on the basis of the consent you give when you become a Loyalty scheme member. If you don’t want to continue receiving Loyalty scheme offers, you’ll be unable to continue your Loyalty scheme updates.

For example, Loyalty scheme members are informed by email of the rewards they have earned and the time frame they have, to spend it in. Without the data to do this, Loyalty scheme members may miss the opportunity to spend their rewards.

7. 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 across our business as described above. 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.

8. 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 have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

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 by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks.

9. 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.

10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. They provide an integral part of the service we provide to you and support our business operations. 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; Parcelforce and DPD
• 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.
• Google/Facebook to show lookalike audiences products that might be of interest while they are 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.

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.

The following companies may process your personal data as part of their contracts with us:

• Oracle
• Metapack
• HSO
• Adyen
• DPD
• Yodel
• Royal Mail
• Parcelforce
• Google
• Facebook
• Twitter
• Narvar
• Emarsys
• Rakuten
• Apple
• Wunderkind
• PayPal
• WhatsApp

We take all reasonable steps to ensure these third parties use any personal data in strict accordance to the 2018 General Data Protection Regulations.

For further information please contact our Data Protection Officer.

11. Where your personal data may be processed

Where your personal data is transferred outside the EU, we take all reasonable steps to ensure that the protection offered by the GDPR travels with the data.

12. What are your rights over your personal data?

An overview of your different rights

Under the General Data Protection Regulations, 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.
• Review by an employee 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 primarktool holds at any time, and also to have that information corrected if it is inaccurate.or email support@primarktool.com. To ask for your information to be amended, please update your online account, or contact our Customer Services team.

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.

13. 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 direct marketing email communication that we send you. We will then stop any further direct marketing emails.
• If you have registered online, sign in to your account, visit the ‘My Account’ area and update your communications options.
• email support@primarktool.com. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

14. 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.

15. 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 one of the following:

• Email the Data Protection Officer at support@primarktool.com.

This Privacy Notice was last updated in November 2019.