Updated 22 March 2018
Smarterbuys Store (“SBS”) respects an individual’s right to data privacy and data protection in line with data protection legislation. By this we mean the Data Protection Act 1998 up to and including 24 May 2018 and the General Data Protection Regulation (GDPR) thereafter.
This Privacy Statement has been developed in order to advise you of how SBS will collect, store, use, share, and protect (collectively known as ‘process’) the personal/sensitive personal/special category information (collectively known as ‘information’) it comes into contact with. If you have an HP Agreement with us it may contain further information about our processing of your information.
By giving SBS your information or by using our website or platforms you are confirming that you are accepting the practices outlined in this Privacy Statement. If you do not accept the outlined practices, please do not give us any information or use our website/platforms/portals.
We reserve the right to make changes to this Privacy Statement at any time and we recommend that you regularly review this Privacy Statement to ensure that you are aware of any changes and how your information may be used. We anticipate making further changes to this Privacy Statement as part of our compliance and planning for the introduction of the GDPR.
For the purposes of the data protection legislation, SBS is the Data Controller (i.e. the company who is responsible for and controls the processing of your personal data) of the information that you supply it with and on occasion this information may be shared with a third party who will act as a Data Processor to carry out a specified function on behalf of SBS.
If you have any requests concerning your personal information or any queries with regard to this Privacy Statement please contact us on 0300 500 0975.
Who are we?
The Smarterbuys Store Limited is a charity (1144676) and a private company limited by guarantee without share capital (07526461) that offers household goods for sale on hire purchase agreements and who is authorised and regulated by the Financial Conduct Authority FRN 713746, and whose registered office is at Greengates House, Amos Drive, Greencroft Industrial Estate, Stanley, Co Durham, DH9 7YE.
SBS is listed with the Office of the Information Commissioner as a Data Controller with the reference number: ZA168104
What does this Privacy Statement apply to?
This Privacy Statement applies to personal/sensitive personal/special category information (collectively known as ‘information’) that we collect from or about our customers or visitors to our websites, platforms or portals.
The methods in which we collect this information are:
- The SBS website
- Third party social platforms such as Facebook and Twitter
- SBS landlord portals
- Call centre
- Application forms
- Personal interviews
- Data from other sources
- This is information that we may obtain about you from other sources. An example of this is that we may hire a third party organisation to collect information on our behalf to conduct tenancy surveys, this would be done in order to provide us with additional information on our tenants in order to shape service delivery.
What information is being collected?
How you interact with us determines what information we collect from you.
We aim to limit the amount of information we process to that which is reasonably necessary to provide you with our services.
In order to limit information requests we will combine information that we receive from different sources and process it together.
The types of information that we collect from you can be categorised as:
This is information that could be used to identify you as an individual:
- name (including previous names)
- date of birth;
- marital status;
- residential status; and
- national insurance number.
This type of information is what SBS would have collected from you in order to access a service or apply for/enter into a contract with SBS.
Sensitive personal information / Special category information
In order to access some SBS services and for legislative requirements it may be necessary to collect your sensitive personal/special category information. This type of information includes details on your:
- physical or mental health medical needs;
- incomes and outgoings; and
- bank and/ or payment details.
Personal contact information
This is the information that you have given us in order for us to be able to contact you and includes:
- telephone numbers;
- email addresses;
- alternate postal addresses, and in some cases
- Next of Kin or Support Worker details.
Account login information
If you set up an online account with SBS this would refer to the username, password and answers to the security questions you would have use to manage your online account.
Technical computer information
This is information about the computer/ smart phone/ tablet used to access a website, platform or portal. This information is usually collected through cookies and can include the IP address, operating system and browser; if accessing through a smart phone this can also include the phones unique ID.
This is information you voluntarily share with us about your experiences with SBS and includes unsolicited comments, suggestions and feedback which is typically collected in surveys, user groups, contact forms and emails.
Social network information
This refers to any information that is part of your profile on a third party platform (i.e. Facebook and Twitter) that you allow the third party social network to share with us. For example your name, birthday and profile picture.
Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.
We may monitor and record communications with you (such as telephone conversations and emails) for the purposes of quality assurance, staff training, fraud prevention and dispute resolution.
What do we use your information for?
The following describes the various purposes for which SBS process your information and the different types of information that might be collected from you.
Please note that not all of the uses will be relevant to every customer/visitor.
HP Agreement Management
In order to maintain your account with us we may use the information that was given to us when the account was initially set up, this would include your personal information and contact information.
In order to for us to provide services to manage your HP account it may be necessary to process a customer’s sensitive personal/ special category information. An example of this is when advising of a change in financial circumstances and affordability, and we would use a customer’s income and outgoings to establish what type of payment would be affordable, and ask for permission to refer that customer into their landlords debt advice service or another free debt advice service.
Customer Services can be provided through different means i.e. in person, by email or over the phone. During these interactions we may collect and use your personal and account information to validate your identity and your contact information to respond to your enquiry.
In order to encourage customer/visitor engagement we may collect contact or feedback information.
Contests and promotions
On occasion we may run competitions wither through SBS or a third party platform such as Facebook and Twitter which for entry purposes require a customer’s/ visitor’s personal and contact information.
For compliance purposes the winner’s names and general location may be published or shared.
We may collect and use your personal and contact information to send you marketing communications, such as emails, text messages, and postal mailings. These communications will keep you up-to-date on the latest offers, news and events, from SBS that may be of interest to you.
We will only send you marketing materials that you have consented to receive and consent can be withdrawn at any time. Legally there are communication items that we are legally obliged to send you and from which you cannot withdraw consent, an example of this is the annual account statement.
If you participated in a promotion that involved a third party and you agreed to receive marketing information from them you will need to contact them directly to withdraw consent from receiving further marketing materials from them.
We may collect and use your technical computer and account login information to improve and personalise your experience on our websites and platforms, it may also be used to show you specific SBS content tailored to your interests.
Other general purposes
In order to maintain the day-to-day operation and security of our website/ platforms/ portals and conduct demographic studies we may process your technical computer information and consumer feedback.
Where we have received personal information from other sources, we may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Protecting your personal information
We are committed to ensuring that your information is secure. At all times SBS will take both technical and organisational measures to protect the confidentiality and security of personal information, irrespective of the method of collection.
Refusing to give us personal information
There are occasions where you may not want to share with us your information or withdraw previously given consent, it is within your rights to refuse or withdraw consent however it may mean that the services we are able to offer you are limited and you are unable to access personalised features.
Please note that there are some items of information that you cannot refuse or withdraw consent from if you wish to enter into or remain in a contract with SBS.
Disclosing your personal information
We will never share information with any third party that intends to use it for direct marketing unless we have received specific consent from the individuals involved.
Information may be shared with our subsidiary companies which SBS has control through direct or indirect ownership (collectively known as the ‘SBS’), as defined in section 1159 of the UK Companies Act 2006.
There are occasions where we will need to share your information with selected third parties, on these occasions SBS will have a Data Sharing Agreement in place which ensures that the third party keeps information private, secure and processed only in the way specified by SBS.
Information will only be shared with the following types of third parties:
In order to provide a service to you it may be necessary for SBS to appoint a contractor, an example of this would be carrying out a connection or repair to an item in home, and the contractor would need to know your name, address and telephone number in order to make an appointment and carry out the connection or repair.
We may appoint a research company to carry out research on our customers and or partners in order to improve a SBS service, know more about our customers/ partners or establish if there are any gaps in what we are doing, on these occasions if contacted individuals can refuse to participate in the research without prejudice.
Legal and Business transfers
By law there are occasions where we have to disclose your information, for instance if it is necessary to comply with legal proceedings or in order to protect the safety or rights of SBS, its customers or the public.
In the event of a merger/acquisition of part or the whole of SBS the partner/acquirer would have access to the information obtained by SBS and this information could be transferred as part of a reorganisation or similar event if permitted by and carried out in accordance with applicable law.
Internet Based Transfers
Given that the Internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by browsing this web site and communicating electronically with us, you acknowledge and agree to our processing personal data in this way.
Accessing and amending your personal information
You have rights under the Data Protection Act 1998 and the General Data Protection Regulation regarding the information SBS processes about you.
These rights include:
You have the right to ask us not to process your personal data for direct marketing purposes. We will ask you when we collect your personal data if we can use your data for such purposes or if we can disclose your information to any third party for such purposes. You can opt-out of receiving such marketing at any time.
Right of Access
You have the right to access the personal information that we hold about you, to know what we hold, what format it is in, and to have a copy of it if you wish. This is called a Subject Access Request. This is a more formal process than, for example, simply requesting a second copy of your account statement or HP agreement. Our staff will explain when your enquiry falls under the Subject Access Request process.
Right to Rectification
If the information we hold on you is incorrect you have the right to ask us to correct it without undue delay and free of charge. You can exercise this right at any time by contacting us at email@example.com. There may be occasions where we require additional information in order to process your request – such as a name change needing proof of the change of name – and you will be required to specify the information that is incorrect and what it should be replaced with.
Right to Erasure
You have the right to request that all data held by SBS which identifies you is deleted. You can also make this request at any time by contacting us at firstname.lastname@example.org but please note we may be compelled to maintain your information due to specific legislative or regulatory requirements, for example we keep copy invoices in case of an HMRC investigation and if you have held a contract with us we will retain that information.
In some instances SBS will require your specified informed consent to process your information, on these occasions the consent will be recorded and you have the right at any time to withdraw the consent.
Spamming is where unsolicited e-mails are sent to you containing advertisements or marketing related materials without your consent.
In accordance with the Data Protection Act and the General Data Protection Regulation, SBS will not send you spam emails and we will not share your email address with third parties for them to use in this way.
No information you share with SBS will be used for direct marketing unless you give us your consent which can be withdrawn at any time.
If for some reason you believe you have received spam e-mail from the SBS company please contact us.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How long do we keep your personal information?
We will only keep your information as long as is reasonably necessary and in line with our Data Retention Schedule. This does mean that your information may be retained for a period of time after you have stopped using SBS services or the website/platforms.
In accordance with the General Data Protection Regulation, SBS will not seek to capture detailed information of children in the household however, if we hold detailed information, we will seek consent from children in order to process their information as of their 16th birthday or destroy that information.
Links to third party sites
On occasion our website/platforms may have links to third party sites, visiting these sites is done so at your own risk and we do not control or have any responsibility or liability for the content or practices of any third party site, application or feature. Please check the relevant third party’s privacy policies before you submit any personal data to these websites.
SBS registered office is: Greengates House, Amos Drive, Greencroft Industrial Park, Stanley, Co Durham, DH9 7YE. Phone: 0300 500 0975
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Effective from: 26 March 2018