This policy is provided in a layered format so that you can click through to the specific areas set out below.
1. Important Information and Who We Are?
Purpose of This Policy
This website is not intended for children under 16, and we do not knowingly collect data relating to children.
Retail Marketing is the controller and responsible for this website and your personal data (collectively referred to as “Retail Marketing,” “we,” “us” or “our” in this policy).
Our Data Privacy Manager is accountable for managing questions concerning this privacy notice. If you have any questions, including any requests to exercise your statutory rights, please contact using the information provided below.
3. Contact Details
If you have any questions regarding this policy or our privacy practices, please reach us in the following ways:
Full Name of Legal Entity:
Data Protection Officer:
4. Changes to This Policy and Your Duty to Inform Us of Changes
It is essential to make sure that the information we hold about you is accurate and current. So please keep us informed if your personal data changes during your relationship with us.
5. Third-party Links
6. The Data We Collect About You
Personal data means a piece of information that can help us identify you. It does not include anonymous data (data where the identity has been removed).
We may collect, use, store, and transfer your personal data which we have grouped together as follows:
- Identity Data – It includes first name, last name, username or similar identifier, title, date of birth, gender, photos, or other images.
- Contact Data – It includes billing address, delivery address, email address, and telephone numbers.
- Financial Data – It includes your bank account and payment card details.
- Transaction Data – It includes information about the products and services you have purchased from Retail Marketing.
- Marketing and Communications Data – It includes your preferences in receiving marketing from us and your communication preferences.
- Technical Data – It includes your IP address, login data, browser type, and its version, time zone setting and your location, browser plug-in types and their variants, operating system and platform, device identifiers, geographical information, and other technology on the devices you use to access this website.
- Profile Data – It includes the username and password you can use to access our systems, commissions, or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data – It includes information about how you use this website and its products and services.
We do not collect any Special Categories of Personal Data about you (this includes information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, health information, genetic and biometric data, political opinions, and trade union membership). Also, we never collect any information about criminal convictions and offenses.
7. If You Fail to Provide Personal Information
We need to collect personal information by law, or under the terms of a contract, we have with you. If you fail to provide this data whenever requested, we may not be able to perform the contract we have or are trying to enter into with you. In such a situation, we may have to cancel an order or service you have with us. However, we will notify you if this is the case at the time.
8. How is Your Personal Information Collected?
We utilize different methods to collect data from and about you. This includes through:
Direct Interactions – You may give us your Identity, Contact, and Financial Data by filling in the forms or by corresponding with us by telephone, post, email, social media, or otherwise. It includes the personal information you provide when you:
- Create an account on our website
- Contact us through the website or otherwise (by phone, post, email, or social media)
- Request marketing to be sent to you
- Place an order with us for our products or services
- Enter a competition, promotion or survey
- Give us some feedback
Third Parties or Publicly Available Sources. We may receive your personal data from various third parties and public sources, as shown below:
- Technical Data from the following parties:
- Analytics providers (like Google) based outside the EU
- Advertising networks (like Google Ads) based inside or outside the EU
- Search information providers based inside or outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU and HM Revenue & Customs (HMRC)
- Identity and Contact Data from publicly available sources based inside the EU
- Technology providers we use, including support and inquiry ticketing systems, client relationships, and marketing platforms, and other hosting and communications providers based inside or outside the EU.
9. How We Use Your Personal Information?
We will only use your information when the law allows us to do so. Most commonly, we will use it in the following circumstances:
- Where we need to perform the contract, we have entered into with you or are about to enter into.
- Where it is necessary for our legal interests (or those of a third party), and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data. We just need it to send you marketing or third-party direct marketing communications via email or text message. You may unsubscribe at any time to withdraw consent to marketing.
10. Purposes for Which We Will Use Your Personal Information
Below, we have set out (in a table format) a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that depending on the specific purpose for which we are using your data, we may process your information for two or more lawful grounds. Please check below if you need details about the particular legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose or Activity
Types of Data
Lawful basis for processing, including the basis of legitimate interest
To register you as a new customer or user.
Performance of a contract with you.
To process and deliver your order or service, including:
To manage our relationship with you, including:
To enable you to take part in a prize draw, competition, or complete a survey.
To administer and protect our business and this website (this includes data analysis, troubleshooting, testing, system maintenance, support, reporting, and data hosting).
To provide you with relevant website content and advertisements and measure or understand the effectiveness of the advertising we serve to you.
Necessary for our legal interests (to study how customers use our products or services, to develop them, grow our business, and inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.
Necessary for our legal interests (to define types of customers for our products and services, to develop our business, to keep our website updated and relevant, and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Necessary for our legal interests (to develop our products or services and grow our business).
11. General Marketing
We strive to provide you with options regarding specific personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Surveys & Promotional Offers From Us – We may use your Identity, Contact, Usage, Technical, and Profile Data to expect what we think you may want or need, or what may be interested to you. This is how we decide about the products, services and offers that may be relevant for you (we call this marketing).
We may send you product or service renewal reminders close to the anniversary of taking up a product or service or other communications we are obliged to submit under a legal or contractual obligation.
You may receive marketing communications if you have expressly requested us for information about our services, or purchased goods or services, or made an inquiry, or if you provided us with your details when you entered a competition or registered for a promotion.
- Third-party Marketing – We will always get your express opt-in consent before we share your personal data with any company outside of Retail Marketing (for marketing purposes).
Opting Out – You can ask third parties or us to stop sending you marketing messages at any time by logging into our website or by contacting us or by following the opt-out or unsubscribe’ links in any marketing message sent to you.
Where you opt-out of receiving these marketing messages, this will not apply to the personal data you provided us as a result of a product or service commission or order, warranty registration, product or service experience or other transactions, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes.
Change of Purpose – We will use your personal information only for the purposes we collected it, or for another reason that is agreeable with the original purpose. If you want to get an explanation as to how the processing for the new purpose is consistent with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis that allows us to do so.
Please note that in compliance with the above rules, we may process your personal data without your knowledge or consent where it is required or permitted by law.
12. Disclosures of Your Personal Information
We may share your personal information with the parties set out below:
- Internal, External, or Specific Third Parties as set out in the Glossary or elsewhere in this policy.
- Third parties to whom we may sell, transfer or merge parts of our business or our assets. Alternatively, we may also acquire other companies or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
We require all third parties to respect the security of your personal data and to treat it following the law. We do not permit our third-party service providers to use your personal data for their own purposes. We only allow them to process your personal data for specified purposes and per our instructions.
13. International transfers
To deliver our services, we may transfer your personal data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA, so their processing of your personal information may involve a transfer of data outside of the EEA.
Whenever we transfer your personal data outside EEA, we make sure that a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal information to third parties that have signed our own Data Processing Agreement to safeguard and secure your personal data, or which are located in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further information, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use service providers based in the US, we may transfer data to them if they are part of the privacy shield. This requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data in accordance with our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable regulator of a breach where we are legally required to do so.
We seek to use third-party technology providers that are ISO 27001 certified or equivalent (SOC II) where practical.
How Long Will You Use My Personal Information for?
We will only retain your information for as long as required to fulfill the purposes we collected it for. This includes satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of this data, the potential risk of harm from unauthorized use or disclosure of this data, the purposes for which we process this data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we may have to keep necessary information about our members, including contact, identity, and transaction data for up to seven years after they cease being members (for tax purposes).
In case you are an individual located in the EEA, in some conditions, you may ask us to delete your data: see Request erasure below for further information.
16. Your legal rights
Under certain conditions, you have rights concerning your personal data under data protection laws. These include the rights to:
- Request access to your personal information.
- Request the correction of your personal information.
- Request erasure of your personal information.
- Object to the processing of your personal information.
- Request restriction of processing your personal information.
- Request the transfer of your personal information.
- The right to withdraw consent.
If you wish to exercise any of the rights stated above, please contact us.
17. No Fee Usually Required
You would not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
18. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to help us ensure that your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.
19. Time limit to respond
We try to respond to all legal requests within one month. Occasionally, it may take us more than a month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you updated.
You have the right to:
- Request Access – You can request access to your personal data (commonly known as “data subject access request”). This allows you to receive a copy of your personal data that we hold and to check if we are lawfully processing it or not.
- Request Correction – You can request a correction to the personal data that we hold about you. This allows you to have any incomplete or inaccurate data we hold about you corrected (though we may need to verify the accuracy of the new data you provide to us).
- Request Erasure – You can request the erasure of your personal data. This allows you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You may also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (find the detail below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, note that we may not always be able to comply with your request of erasure for specific legal reasons (which will be notified to you, if applicable, at the time of your request).
- Object to Processing of Your Personal Data – You can object to the processing of your personal data where we are relying on a legal interest (or those of a third-party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some circumstances, we may demonstrate that we have compelling legitimate grounds to process your information that overrides your rights and freedoms.
- Request Restriction of Processing of Your Personal Data – This allows you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy
- Where our use of the data is unlawful but you do not want us to erase it
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the Transfer of Your Personal Data to You or a Third -Party – We will provide you or your chosen third party with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information, which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent – You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time, you withdraw your consent.