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Protecting Your Privacy

Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Ken Bromley Art Supplies Ltd uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

We may need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

We need your personal data to comply with our contractual obligations.

For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier. We will also collect a contact phone number and email address if possible, so we can keep you updated on the shipping and delivery of the purchase.

Legal compliance

Where 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 Ken Bromley Art Supplies Ltd to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your purchase history to send you or make available personalised offers.

We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.

We will also use your address details to send you our mail order catalogue by post.

When do we collect your personal data?

  • When you visit any of our websites and use your account to buy products, or redeem vouchers from Ken Bromley Art Supplies Ltd on the phone, in a shop or online.
  • When you create an account with us.
  • When you purchase a product by post or by phone but don’t have an account.
  • When you join a Ken Bromley Art Supplies loyalty programme.
  • When you contact us by any means with queries, complaints etc.
  • When you enter prize draws or competitions.
  • When you choose to complete any surveys we send you.
  • When you comment on or review our products and service.

What sort of personal data do we collect?

  • If you have a website account with us: your name, billing/delivery address, orders, email address and telephone number. For your security, we’ll also keep an encrypted record of your login password. We also record your IP address.
  • Details of your interactions with us by phone to our customer services or on-line.
    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, gift list and wish list choices, voucher redemptions.
  • Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies on our web site.
  • Personal details which help us to recommend items of interest.
    For example, if you buy oils, acrylics or watercolour materials or a combination.
    Of course, it’s always your choice whether you want us to recommend items that are of interest by email.
  • Your comments and product reviews.

How and why do we use your personal data?

We want to give you the best possible customer service.

We use the data to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows 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 certain contact permissions, we might not be able to provide some services you’ve asked for.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

  • To process any orders that you make by using our website or in our shop. 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 will need to be passed to a third party to supply or deliver the product or service that you ordered, and we will keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. 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 and understanding how we can improve our service based on your experience.
  • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll do all of this as part of our legitimate interest.
    For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
  • To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our shop which record images for security. We do this on the basis of our legitimate business interests.
  • To process payments and to 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 is 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 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 at any time.
  • To send you our mail order catalogue by post in relation to updates, offer and products. We’ll 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.
  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you.
    For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. 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 administer any of our prize draws or competitions which you enter based on your consent given at the time of entering.
  • 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.
  • To send you survey and feedback requests to help improve our service. These messages will not include any promotional content and do not require prior consent when sent by email. We have a legitimate interest to do so as this helps improve our products or service we provide you with.
    Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.

How we protect your personal data

We know how much data security matters to all 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 our complete website including 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 not stored by us. Payments are made directly through WorldPay or PayPal on their secure web sites.

We regularly monitor our system for possible vulnerabilities and attacks.

How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:

Orders

When you place an order, we’ll keep the personal data you give us for up to ten years so we can comply with our legal and contractual obligations.

Warranties

If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

Who do we share your personal data with?

We share your personal data with trusted third parties.

For example, delivery couriers such as DPD, FedEx and Royal Mail, for fraud management, catalogue mailing house.

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 services.
  • 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:

  • IT companies who support our website and other business systems.
  • Operational companies such as delivery couriers who are DPD, FedEx and Royal Mail.
  • To those suppliers who we use to ship items directly to you.
  • MailChimp who help us manage our email communications with you.

Sharing your data with third parties for their own purposes

We will only do this in very specific circumstances, for example:

  • For fraud management, 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.
  • We may also be required to disclose your personal data to the police 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.
  • We may in the future sell Ken Bromley Art Supplies Ltd and this may involve the transfer of the business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
  • For further information please contact our Privacy Officer at Ken Bromley Art Supplies offices.

Where your personal data may be processed

Sometimes we will need to share your personal data with third parties outside the European Economic Area (EEA), such as Australia or the USA. The third parties involved would be involved in the delivery of goods to our customers outside the EEA.

When we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA.

For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Privacy Officer.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

What are your rights over your personal data?

An overview of your different rights

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 made based solely on automatic processing of your data (i.e. where no human has yet reviewed the decision).

You have the right to request a copy of any information about you that Ken Bromley Art Supplies Ltd holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact the Privacy Officer, Ken Bromley Art Supplies, Unit 13, Lodge Bank Estate, Horwich, Bolton BL6 5HY or email:info@artsupplies.co.uk. To ask for your information to be amended, please update your online account, or contact our Customer Services team on 01204690114.

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.

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.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We use your address to send out our mail order catalogue within the UK only and we use your email address to send out special offers and information on new products and other items of interest. 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 they have your permission to act.

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 communication that we send you. We will then stop any further emails from us.
  • If you have a web site account, log in your account and change your preferences.
  • Write to customer services to add or remove you from our mailing list for catalogues or emails.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. (See the section below if you live outside the UK)

If you live outside the UK

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

For example, we will have to supply your contact details to our delivery providers in order to ship any order to you.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

Australia

For the purposes of this Privacy Notice, ‘personal data’ means any information about an identified individual, or an individual who is reasonably identifiable.

If you are in Australia you may submit any questions, comments or complaints to our Privacy Officer who will come back to you within 30 days.

If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.

We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.

If we have not come back to you within 30 days, or you are not happy with the response that you’ve received, you may submit a complaint to the Office of the Australian Information Commissioner.

We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.

Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Commonwealth).

USA

To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our Cookies Notice.

Canada

The personal data we process may be accessed by people within Ken Bromley Art Supplies Ltd, or by our third-party service providers, such as the delivery companies, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.

If you have any questions, please contact our Privacy Officer.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.

South Korea, Malaysia, Singapore, Qatar

Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).

By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.

Hong Kong

When you agree to receive direct marketing emails from us, we’ll send you promotions on products we sell at Ken Bromley Art Supplies Ltd.

If you are in Hong Kong you may submit a complaint to our Privacy Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive, you may submit a complaint to the Office of the Privacy Commissioner for Personal Data)

Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

  • Email us at info@artsupplies.co.uk
  • Or write to The Privacy Officer, Ken Bromley Art Supplies, Unit 13, Lodge Bank Estate, Horwich, Bolton BL6 5HY
This notice was last updated on 4/5/2018
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