IMPORTANT INFORMATION & WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

PERSONAL DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you or your employees which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website article. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2.2 SENSITIVE AND SPECIAL PERSONAL DATA

Some information is subject to a higher threshold of protection because it is more sensitive. This information is commonly known as Sensitive Personal Data or Special Categories of Personal Data. Sensitive/ Special Categories of Personal Data includes:

§ information about your or a person’s physical or mental health or condition;

§ racial or ethnic origin or religious beliefs or other beliefs of a similar nature;

§ political opinions;

§ information about a person’s sexual life;

§ the commission or alleged commission of any offence (i.e. criminal matters);

§ any proceedings for any offence committed or alleged to have been committed by the data subject, the disposal of such proceedings or the sentence of any court in such proceedings;

§ whether you are a trade union member or not;

§ information about a person’s genetics; and

§ information about a person’s biometric data.

We do not routinely collect sensitive personal data. However, if and where we do, we do not share sensitive/special categories of personal data with any third parties without your express written consent in the case of individual customers and employees. In the case of data provided by customers about their employees, ex-employees, directors or ex-directors (or equivalent), applicants for jobs, volunteers, contractors, workers or agency workers, where we hold special categories of data about any such data subject we will be processing that data solely as necessary for our customers and to carry out specific instructions received from customers and in accordance with the guidance provided by the ICO which can be found by clicking here.

2.3 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

The vast majority of the time we collect personal data when you voluntarily provide us with the same when you are using our website. This can include information you provide when you register to use our website, create an account, set up a profile, complete a form, order a product, provide feedback or reviews on our products or website, enter competitions, correspond with us, purchase products from us, subscribe to our email lists or respond to surveys or promotions.

The different methods which we use to collect data from and about you include:

HOW WE USE YOUR PERSONAL DATA

4.1 OVERVIEW OF USE

We will only use your personal data when the law allows us to. We only process data for the purposes we have agreed with you or where it relates to:

§ providing our products to you or the company/organisation whom you work for (as applicable) – we need to consider the data in order to give the best and most appropriate advice and service;

§ complying with legal requirements (such as taking all necessary details from you so as to process a credit or debit card payment);

§ pursuing our legitimate interests (such as being able to communicate with you and update you regarding our products), and your interests and fundamental rights do not override those interests;

§ something necessary for the protection of a person’s vital interests (this is likely to be exceptional but may be related to someone’s health in an emergency);

§ considering any application(s) for employment and/or your employment status with us;

§ something you have consented to; and

§ data that has been made public by you.

Generally, we do not rely on consent as a legal basis for processing your personal data so that we can provide our products to you other than in relation to individual customers where marketing communications are sent to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

4.2 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please tell us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

4.3 MARKETING & PROMOTIONAL OFFERS FROM US

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical and Usage to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

We may from time to time send out bulk emails or letters to customers marketing our services. However, you will mostly receive correspondence from us which relates to specific products or to your specific purchase.

We may from time to time and on an ad hoc basis provide you with tailored product updates and other information and news which we may consider to be useful to you. In respect of any such correspondence, we have established the following personal data control mechanism: we will seek your consent to send you regular product updates.

4.4 THIRD-PARTY MARKETING

We do not sell, rent or share your personal data with any third parties for marketing purposes.

4.5 OPTING OUT

You can ask us to stop sending you marketing messages at any time by contacting us. This includes any messages which you may consider marketing messages even if they are not intended to be.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of previous or current instructions given to us and the provision of our products pursuant to such instructions.

4.6 COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We do not deliberately collect data about you using cookies. However, we use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system when necessary.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can set your internet browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

4.7 CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.2 above.

• External Third Parties as set out in the Glossary.
• Any of our group companies
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses 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 in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA SECURITY STORAGE

We store data in a number of ways, including in computer storage-facilities, paper-based files and other records.

We have put in place appropriate security and data encryption measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 on 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 will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

8.1 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We generally keep basic information about our customers and (prospective) employees (including but not limited to: Contact, Identity, Financial, Advice, and Purchase Data) for a minimum of six years after they cease being customers mainly for tax and insurance purposes. In some instances, we may keep certain records indefinitely.

In some circumstances you can ask us to delete your data: see Request erasure of your personal data below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

9.1 YOUR GENERAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you that you have given to us and to check that we are lawfully processing it. The data requested will be provided in a structured, commonly used and machine-readable format or in hard copy format.

• Request correction of the personal data that we hold about you. This enables 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 of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (Request restriction of processing of your personal data – see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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 where we are relying on a legitimate 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 cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 to a third party. We will provide to you, or a third party you have chosen, 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 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 to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

9.2 NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the 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.

9.3 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 personal data (or to exercise any of your other rights). This is a security measure to ensure that 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 in relation to your request to speed up our response.

9.4 TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

10.1 LAWFUL BASIS

• THIRD PARTIES

Internal Third Parties

External Third Parties include (but are not limited to):

• Service providers based in the UK who provide telephone, IT and system administration services: generally, they are accessing our systems for the legitimate interest of diagnosing and dealing with IT related problems. We are satisfied that our contractual relationships with those providers contain provisions dealing with the security of all data and that they take appropriate measures to prevent unlawful access to the data.
• Furniture designers or designers and delivery companies or couriers with whom we may work with or provide/collect information to/from in order to provide our products to you.
• Professional advisers including lawyers, bankers, accountants, tax advisors, auditors and insurers based in the UK who provide consultancy, banking, accounting, legal, insurance and accounting services to our firm. Generally, they are not accessing personal data when providing us with advice and support but they are likely to have access to such data especially when carrying out an audit of our financial affairs.
• Her Majesty’s Revenue & Customs based in the UK as regulators have the power to require access to any files we hold in order to ensure that we have operated within the regulatory rules imposed from time to time. If they do so, these regulators will have duties to you as a Data Controller in their own right and you should ask them for their Privacy Notice in this regard.
• Her Majesty’s Courts and Tribunal Service.
• Companies House.
• Experts who we instruct. It may become necessary during the course of your purchase to instruct experts to assist with the design or manufacture of products or
• Debt-collectors or County Court Bailiffs or High Court Enforcement Offices based in the UK acting as joint controllers who will have access to Financial Data and Identity Data in order to enforce the debts and possession orders either on your behalf or against you.