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Last updated: 01 Feb 2019
1. APPROACH TO PRIVACY
2. PERSONAL DATA WE COLLECT ABOUT YOU
2.1 We collect personal data from you when you voluntarily submit information directly to us or via our platform. This can include information you provide when you register to use the platform, create an account on our platform, set up a profile on Services and interact with other users, visit one of our showrooms, use a tablet or similar device in one of our showrooms, complete a form, provide feedback or reviews on our products or platform, enter competitions through our platform, correspond with us, purchase products from the platform, subscribe to our email lists or respond to surveys or promotions.
2.2 The categories of personal data we collect include the following:
- (a) Contact details: Such as your name, your email address, your telephone number and addresses associated with your account.
- (b) Profile information: Such as your contact details (as above) and other any information you share when creating a profile on Services.
- (c) Comments and opinions: Such as, comments and opinions you share on our services, when you provide feedback or reviews on our products or platform, or when you respond to our surveys, competitions and promotions.
- (d) Messages to us or between users: Messages you send to us such as email and written correspondence using grimprove.co.uk’s services.
- (e) Payment and transaction information: Records of the products and services you purchase from us and the payment method, and credit/ debit card details, you use for the transaction.
- (g) Your preferences: Choices you make such as notification and messaging preferences or choices about how the platform is displayed.
- (h) Information about products you have looked at: We collect information about the products that you have looked at on the platform, or that you have added to your basket on the platform on a tablet or similar device.
- (i) Information about how you use and connect to the online service:
- (i) We automatically collect information about how you use the platform such as the pages and links you access, the time you access the platform and duration you are on it, the platform you come to the platform from or go to after leaving the platform and selections and choices you make when using the platform.
- (ii) We also automatically collect information about the computer or other electronic devices you use to connect to the platform such as details about the type of device (which can include unique device identifying numbers), its operating system, browser and applications connected to the platform through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).
- (iii) Typically, the information we collect about how you use or connect to the platform is associated with your device.
- (j) Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location but this will be no more precise than the city, state or country you are using your device in.
- (k) Information provided by other users: Sometimes, other visitors to our platform provide your personal data. For example, other visitors may provide your personal data to us when they invite you to use the platform or through grimprove.co.uk’s services.
- (l) Information from fraud prevention organisations: Where permitted by law, if fraudulent activity is suspected relating to your account, we may be provided with information by credit reference, fraud and crime prevention organisations.
2.3 We also automatically collect personal data indirectly from you such as information about the pages you look at on the platform or the device you connect to the platform with.
2.4 We may also collect personal data about you from Facebook via its Connect functionality: The received information includes login details and profile information such as your log-in token, user name and photo and other information from that service as permitted by you and that service.
3. HOW WE USE YOUR INFORMATION
3.1 We will also use your personal data for the purposes specifically described below:
- (a) Contact details: we will use your contact details so that we can communicate with you directly via phone, SMS messaging, or email, in particular, about queries, issues, problems we have detected or concerns you or other users have. We may also use your contact details to send you information about similar products and services that we think may be of interest to you (such communications will be in accordance with your marketing preferences as explained in more detail in section 5 below).
- (b) Profile information: we use your profile information to provide grimprove.co.uk’s services to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
- (c) Comments and opinions: we will use your comments and opinions to determine similar products and services that may be of interest to you and to provide our grimprove.co.uk’s service to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
- (d) Payment and transaction information: we will use payment and transaction information you provide to process payment for any product or service you purchase from us. We may also use the history of your transactions with us to determine similar products and services that may be of interest to you.
- (e) Messages to us or other users: we will use messages you send to us to help us respond to any query, issue or concern you raise and to provide grimprove.co.uk’s services to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
- (f) Your preferences: we will use your preference settings which you can set by [insert method by which users can set such preferences] for the purpose of providing notifications, messages, displaying the platform and following other choices you are able to make about how the platform is displayed to you.
- (g) Information about products you have looked at: we use this information to send you reminders and further information about these products. We will also use this information to determine similar products and services that may be of interest to you.
- (h) Information about how you use and connect to the online service: we use this information to present the platform to you on your device. We will also use this information to determine similar topics, products and services that may be of interest to you.
- (i) Information about your location: we may use an approximate location to ensure content on the platform is relevant to the city, state or country you are using your device in. We will not collect or track your precise location without your consent.
- (j) Information about the location of purchases: we use this information to show what types of purchases are being made in a particular area on a searchable map and to allow users to contact other users about their purchases through depending on your preferences which you can set by using the ‘my preference’ functionality on your profile page.
- (k) Information provided by other users: we will use your personal data that is contained in messages sent to us by other user to respond to any query, issue or concern they raise or to provide grimprove.co.uk’s services service to you and ensure that you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by [insert method by which users can set such preferences]. We will use your personal data that is contained in forms submitted by other users to contact you, if you indicate you would like to receive a communication from us.
- (l) Information about fraudulent activity relating to your account: we will use information about fraudulent activity relating to your account for the purposes of preventing fraud or crime.
- (m) All personal data on an aggregated basis: we will use all the personal data we collect to: (i) monitor and improve the platform and our procedures and processes; and (ii) to help us develop new products and services.
3.2 We may anonymise and aggregate any of the information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the platform, developing new products and features or displaying information about the purchases made via our platform such as the most popular purchases or purchases based on an approximate location.
3.3. We process your personal data (i) with your consent, (ii) when we need to do this to fulfil a contract with you (for example, the contract of sale), (iii) where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation), and/or (iv) when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in offering and providing grimprove.co.uk products and services, deter fraud and carry out direct marketing.
4. INFORMATION WE SHARE WITH THIRD PARTIES
4.1 We may share your personal data with the following parties:
- (a) Our users: we and you may share your information with other users as part of our services service so you are able to interact with our users as permitted by the functionality of the service and your preferences which you can set by using the ‘my preference’ functionality on your profile page.
- (c) Service providers, partners and advisors: third parties who provide a service to us, partner with us on certain business activities, advise us or that we work within other business capacities. For example, we use a third party delivery service to deliver any products you buy to your postal address. We may also pass your personal data to our marketing and other business partners and other carefully selected third parties who may wish to offer you other goods or services that we or they have identified as likely to be of interest to you. These third parties will only be allowed to use your personal data in accordance with our instructions or your marketing preferences (where applicable) and will be required to keep your information secure.
- (d) Purchasers of our business: personal data may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of the sale.
- (e) Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal data to or who we need to disclose your personal data to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.
4.2 We do not disclose personal data to anyone else except as set out above, where permitted by law and/or with your consent. We may provide third parties with aggregate statistical information and analytics about users of the platform but we will make sure that no one can be identified from this information before we disclose it.
5. MARKETING AND ADVERTISING
5.1 Email Marketing – From time to time we may contact you by email with information about our similar products and services which we think you may be interested in if you agree [at the point of registration / sale]. Thereafter, if you do not want us to send you email marketing, please use the contact details provided in section 13 below . You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
5.2 Email Notifications On Behalf of Users – We may send you notifications that users may wish to contact you about purchases you have made through our platform. If you wish to speak to the user, you may do so by signing up to Services. If you do not want us to send you these notifications, please let us know by using the contact details provided in section 13 below.
5.3 Email Notifications About Your Order or Changes to the Services We Provide – We may send you email notifications in relation to your order or changes to the way we provide our services to you.
5.4 Advertising on the Site and other social media websites – We, or our advertising partners, may show advertisements to you on our platform or on other platforms. To do this we, or our advertising partners, may collect information about how you use the platform or the types of other web pages, content and ads you, or others who are using the device you connect to the platform, interact with, visit or view. The information collected might also include the IP address of the device you connect to the platform or the e-mail address you provide to us or our platform. We, or our advertising partners, use the information that is collected to make sure adverts you see either on the platform or other platforms or apps (where our partners have advertising space) are more relevant to you.
5.5 The techniques our advertising partners use recognize the device or e-mail address you are using. Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our Cookies Policy.
6. STORING AND TRANSFERRING YOUR PERSONAL DATA
6.2 We put in place European Commission approved standard contractual clauses or rely on alternative transfer mechanisms to protect this data. A copy of these clauses is available for your review upon request to us using the contact details provided in section 13 below.
7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
7.1 You may have various rights with respect to our use of your personal data:
- Marketing: As stated above in section 5, you may opt-out of receiving such emails from us by using the contact details provided in section 13 below, or by clicking on the unsubscribe link in the emails we send to you.
- Access, rectify, port, block, complete, delete and update: You have the right to access, rectify, block, port, complete, delete and update your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data.
- Object: In certain circumstances, you also have the right to object to the processing of your personal data by us.
7.2 You can exercise the above rights by contacting us using the details provided in section 13 below at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum.
7.3 There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law.
7.4 We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to the competent data protection authority.
7.5 When we ask you to supply us with your personal data we will make it clear whether the data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
8.1 We will retain your information, whether or not your account is active, for as long as we believe it is necessary to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.
9. LINKS TO THIRD PARTY SITES
9.1 The platform may, from time to time, contain links to and from third party platforms of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these platforms, please note that these platforms have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those platforms.
10. CHANGES TO THIS POLICY
11. NOTICE TO YOU
12. CONTACTING US