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 email 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 will collect your address details to deliver your purchase and then pass them on to our courier.
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 the company to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and doesn’t materially impact your rights, freedom or interests. For example, we may use your purchase history to send you personalised offers.
When will we collect your personal data?
- When you make an online purchase.
- When you purchase a product or service in-store or by phone.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you choose to complete any surveys we send you.
- When you complete any mandatory forms.
- When you’ve given a third party permission to share with us the information they hold about you.
- When you use our shop, which usually operate CCTV systems for the security of both customers and employees. These systems may record your image during your visit.
What sort of personal data do we collect?
- If you make an order online, we will collect your name, title, billing/delivery address, email and telephone number.
- Details of your interactions with us through contact centres, in-store, over the phone and online may also be recorded. 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, voucher/code redemptions, web pages you visit and how and when you contact us.
- Details of your visits to our websites.
- Personal details that help us to recommend items of interest
- we will only ask for and use your personal data to recommend items of interest and tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
- Truncated card details.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit a shop or car park.
- Your car’s number plate may be recorded at some of our car parks to manage parking restrictions.
- 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.
How and why do we use your personal data?
Data privacy laws allow 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 particular contact permissions, we may not be able to provide certain services.
- We will collect personal data to process any orders that you make on 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 on 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.
- Storing your information enables us to respond to your queries, refund requests and complaints. We may also keep a record of these to inform any future communications 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.
- We will safely and securely store personal data. 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.
- To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our store that record images for security. We do this on the basis of our legitimate business interests.
- We will collect personal data to process payments and 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, 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.
- Personal data may be used to send you relevant, personalised communications by post with relation to updates, offers, services and products. we will 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.
- We may use your personal data to send you communications required by law or that are necessary to inform you about changes to our services. For example, updates to this privacy notice, product recall notices and legally required information relating to your order. 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 build a rich picture of who you are and what you like, and to inform our business decisions, we will combine data captured from Forty Winks Bed Company website, third parties and data from publicly available lists. we will do this on the basis of our legitimate business interest. For example, by combining this data, this will help us to personalise your experience and decide which 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. Sometimes we will need to share your details with a third party who is providing a service (such as a delivery courier). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
- To administer any of our prize draws or competitions you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide. we will do this on the basis of our legitimate business interests. For example, we will 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.
How we protect your personal data?
We know how much data security matters to all of 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 using ‘https’ technology. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured using SSL encryption.
Our local networks are protected using strong encryption mechanisms.
Firewalls are implemented at each internet connection and the internal company network.
We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties like delivery couriers, sub contracted tradesmen and independent quality inspectors and financial ombudsman.
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 service.
- 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:
- 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 – see our cookies notice for details.
- Data insight companies to ensure your details are up-to-date and accurate.
We will only share your data with third parties for their own purposes 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.
- 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 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.
- For further information, please contact our data protection officer.
To help personalise your journey on our websites, we currently use the following companies to process your personal data as part of their contracts with us:
- Google analytics
Where your personal data may be processed?
Protecting your data outside the EEA
Any transfer of personal data will follow the applicable laws and we will treat the information under the guiding principles of this privacy notice.
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, and 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 that they have your permission.
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 email marketing that we send to you. We will then stop any further emails from that particular division.
- Write to Forty Winks Bed Company at: 25-27 Camp Road, Farnborough, GU14 6EN.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems update.
What are your rights over your personal data?
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.
- 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 any decision based solely on the automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time. To ask for your information, you can contact us by post using the following address:
The Data Protection Officer,
Forty Winks Bed Company,
25-27 Camp Road,
Or you can email us at email@example.com
To ask for your information to be amended, please contact us on 01252 543000. 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. The timescale for completing an internal review, will be no longer than one calendar month.
With effect from 25th May 2018