Website Privacy and Cookies PolicyVersion April 2014
This Privacy and Cookies Policy applies to the http://www.harveysfuniture.co.uk (the “Site”) which is run by Steinhoff UK Retail Limited (“the Company”) of 5th Floor Festival House, Jessop Avenue, Cheltenham, Gloucestershire, GL50 3SH.
The Company regards your privacy as very important and recognises the importance of honest and responsible use of your personal information. This Privacy and Cookies Policy (“Policy”) explains how the Company collects, uses and discloses personal information about you when you visit the Site and when you contact the Company, whether by e-mail, post, fax or telephone using the contact options on the Site. The information you provide to us through the Site will initially be collected by Steinhoff UK Retail Limited, but may then be shared with other Steinhoff Group companies. All references to “the Company” in this Privacy and Cookies Policy therefore include Steinhoff UK Retail Limited and any of its Group companies (“the Group”), unless stated to the contrary. Depending upon your relationship with the Company, we may separately provide you with further details about our use of your personal information.
It is important to us that you feel comfortable in visiting the Site.
What type of information does the Company collect and why?When you visit our Site, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests. This may allow us to find out which parts of the Site are popular or need changing.
If you want to contact us, make a purchase or to use certain other services we provide on the Site, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query, purchase or application. If you do choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.
What type of personal information does the Company collect?Where you choose to provide personal details to us, we may collect the following personal information from you:
• your full name, title and gender; • your work and home contact details eg address, fax number, telephone numbers and e-mail address;• the reason for your contact, which may be an enquiry, a purchase, a request or enquiry on behalf of someone else, a customer service need, providing a comment, a job application, or details in relation to a possible or existing order or service contract;• if you create an account - your username, password, e-mail address and your full name, address and telephone numbers;• employment and personal and educational details you choose to provide to use as part of any application for employment eg your employee ID, including national insurance number, other governmental identity number, and if needed, driver’s license number and/or passport number, your date of birth, place of birth, nationality (and where applicable dual or former nationality) and eligibility (including evidence) to work in the UK;• financial account information, such as credit/debit card number and other payment information;• your contact and marketing preferences, including certain personal circumstances such as home moving and age, see below for more information;• if you take a survey or interact with us in various other ways - demographics• if you take a survey or interact with us in various other ways - demographics information and information about subjects that may interest you;• information necessary for legal compliance (including details of disability); and/or• where you “like” us or make posts on our pages on social networking websites.
This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Group Sites or services.
How does the Company use information about you?The Company may use information about you for purposes described in this Policy or as otherwise disclosed to you on our Site or with our services. For example, we may use information about you for the following purposes:
• to respond and/or deal with your request or enquiry;• to process and administer your job or similar application(s) (including placement or apprenticeship opportunities, as appropriate), your order(s) or purchase(s) of our products and/or services;• to improve our products and services and to ensure that content from the Site is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);• to administer the Site;• for internal record keeping; • to contact you (directly, either by the Company or by the Group or through a relevant partner or agent) by e-mail or phone for the above reasons; • subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have requested;• where necessary as part of any restructuring of the Company or sale of a relevant Group company’s business or assets;• to perform any contract the Company has with you; and• for compliance with legal, regulatory and other good governance obligations.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that the Company maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.
In most cases, the information the Company processes about you is required to deal with your request, purchase or registration, or required by law, or is necessary for the exercise of the Company’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure any such use is proportionate.
The Company or Group may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Company/Group performance. In addition, the Company or Group may use pixels or transparent GIF files, to help manage online advertising. Any information that we collect and share is anonymous and not personally identifiable.
Does the Company share personal information with third parties?Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible management, human resources, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Group. Please note that certain individuals who will see your personal information may not be based at the Company or in your country (please see below).
We may share personal information within the Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside the Group) providing relevant services under contract to the Company, or the Group (see below for further details), such as employment recruiters, human resources support services, marketing agencies, credit card processors, auditors and compliance managers, providers or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. The Company has put in place various security and data privacy measures, including with such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
Some of your personal informationmay be used by marketing agenices, acting on our behalf, to carry out a data matching exercise. This is carried out on behalf if the Company to ensure that we provide you with relevant marketing information (where you have opted in to receiving such marketing). This is sometimes referred to as “profiling”.
Will your personal information be transferred abroad?Some transfers of personal information have been explained above. Individuals within the European Economic Area (“EEA”) should be aware that recipients of their personal information, within the Group or third parties (as set out in this notice), may not be located within the EEA but instead located in countries which do not have equivalent protection for personal information to that within the EEA. Steps will be taken to protect your personal information in that instance consistent with applicable law.
What choices does the Company offer you with regard to direct marketing?The Company may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services and the Group’s products and services. This communication may occur by e-mail, telephone, post or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
What safeguards are in place to protect your personal information?The Company takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of the Company, the Group or their agents.
What rights do you have to review and amend personal information?You have the right to review your personal information held by the Company and have certain inaccurate information about you corrected. Under UK law, a request for access to your personal data needs to be in writing and accompanied by the statutory fee (£10).
If you wish to do so, or to contact the Company in respect of its data processing activities, please contact firstname.lastname@example.org or Data Processing, Steinhoff UK Retail Limited, Huncoat Industrial Estate, Bolton Avenue, Accrington, Lancashire, BB5 6NU
Keeping you informedWe will keep your details on record until we have completely dealt with your request, enquiry or application and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation.
The Company may keep your details on record for as long as is necessary for the purposes set out above and will then securely delete your details in accordance with the Act.
Changes to this Privacy and Cookies PolicyWe keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
By using our Site, submitting your personal information to us and/or registering an account, you consent to the use of your personal information as described in this Privacy and Cookies Policy (as amended from time to time).
Tim MarsdenMarketing and E-Commerce DirectorSteinhoff UK Retail LimitedHuncoat Industrial EstateBolton AvenueAccringtonLancashireBB5 6NU