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MandM Direct Privacy Statement V2.2

Introduction

We are committed to protecting and respecting your privacy.

Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

The data controller is MandM Direct Limited of Clinton Road, Leominster, Herefordshire, UK. HR6 0SP.

Privacy Policy Updated 05 October 2018

We have changed the lawful basis under which we do our direct marketing (Purposes For Which We Will Use Your Personal Information).

We have provided an example of our data retention policy (How Long We Will Store Your Personal Information).

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:

  • processed lawfully, fairly and in a transparent manner,
  • processed for specified, explicit and legitimate purposes,
  • adequate, relevant and limited to what is necessary,
  • accurate and kept up-to-date,
  • kept for no longer than is necessary, and
  • processed in a manner than ensures appropriate security.

We may collect, use, store and transfer different kinds of personal information about you, including:

  • Identity Data, such as your name, title and date of birth,
  • Account Identity Data, such as your email address and your password,
  • Contact Data, such as your billing address, delivery address, email address and telephone numbers,
  • Financial Data, such as bank account and payment card details,
  • Transaction Data, including details about payments to and from you, and other details of products you purchase from us,
  • Technical Data, including IP addresses, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website,
  • Profile Data, including purchases or orders made by you, feedback and survey responses,
  • Usage Data, including information about how you use our website, products and services, and
  • Marketing Data, such as your preferences in receiving marketing from us and our third parties, and your communication preferences.

Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as 'special category' data.

During the course of dealing with you, we do not expect to collect any 'special category' data about you.

To set up an account with us and use our services, you must be at least 16 years of age. If you are under the age of 16, you must have the consent of your parent or guardian to use our services. If you are under the age of 18, we will protect your data as required by Irish and European data protection law.

We may obtain personal information by directly interacting with you, such as:

  • placing orders for products via our website,
  • creating an account on our website,
  • participating in discussion boards or other social media functions on our website,
  • browsing our website while logged into your MandM myAccount,
  • entering a competition, promotion or survey organised by us, or otherwise providing us with feedback,
  • subscribing to our publications, or otherwise requesting marketing material to be sent to you, or
  • corresponding with us by phone, email, letters or otherwise.

We may obtain personal information via automated technology when you interact with our website by using cookies, server logs and other similar technologies.

We may also collect personal information about you from third parties or publicly-available sources, such as:

  • analytics providers (such as Google),
  • fraud prevention agencies,
  • providers of technical, payment and delivery services,
  • LinkedIn.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • you have given us consent,
  • we need to perform a contract we are about to enter into, or have entered into, with you,
  • where it is necessary for our or a third party's legitimate interests, and your interests and rights do not override those interests, or
  • where we need to comply with a legal or regulatory obligation.

We do not use 'special category' information.

We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the 'legal basis' that allows us to use your information, as follows:

Purposes for which we will use the information you give to us Legal basis
To register you as a new customer It will be necessary for the performance of the contract between you and us
To process your order and, if accepted, to deliver the products to you (including managing payments, fees and charges) It will be necessary for the performance of the contract between you and us
To manage your queries or complaints It will be necessary for the performance of the contract between you and us
To collect and recover money owed to us It will be necessary for our legitimate business interests, namely to ensure we receive payment for products and services that you have ordered from us
To notify you about changes to our terms of sale or this privacy policy It will be necessary for our legitimate business interests, namely to ensure you are aware of our current terms and conditions
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website. We will comply with our cookie policy when processing this information
To enable you to participate in a prize draw, competition or complete a survey It will be necessary for our legitimate business interests, namely to study how customers use our products, to develop them and help grow our business
To create customer profile types that are used to help identify new customers from other sources. These profiles DO NOT contain personal data. This will be done after you give your consent for us to do.

Your consent can be withdrawn by changing your preferences using the My Account functionality on our website.
To provide you with relevant marketing communications that inform you of special offers, sales and new products. It will be necessary for our legitimate interest to develop our offers and services in order to improve customer interaction and retain customers.
To prevent customers from trading with MandM Direct who have been abusive or who have abused or misused the products and/or services that we supply. It will be necessary for our legitimate business interests, namely to prevent the misuse of our products or services
To prevent customers from trading with MandM Direct who have been fraudulent and to pass their details on the relevant legal/regulatory organisation. It will be necessary in the public interest to help prevent fraudulent or dishonest behaviour.
To notify you when you have products in your basket that have not been through the ordering process It will be necessary for our legitimate business interests, namely to ensure we provide the quality of service you expect from us
(Where goods and/or services are being provided to MandM Direct).

To have a contractual relation with you to supply goods and/or service.
It will be necessary for our legitimate business interests, in order to fulfil our contractual obligations.
To allow you to review our products and services It will be necessary for our legitimate business interests, namely to provide the best products and services to our customers based on their feedback, thus establishing and maintaining an excellent and mutually beneficial relationship.

We will only use your personal information for the purpose(s) 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

It is a contractual requirement for you to provide us with certain information, namely your name, delivery address, phone number and email address. During the ordering process you will be required to provide payment information to our chosen payment service provider. We do not hold any of your bank or credit/payment card details. If you do not provide us or payment service provider with that information, we may be unable to accept and process your order and deliver the products to you, and/or we may have to cancel your order. You may also be liable to pay additional costs, if this is applicable it will be described in our terms of sale.

Our website uses encrypted cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. These include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of billing services.
Analytical / performance cookies They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to identify issues with our site and improve the way our website works.
Functionality cookies These are used to recognise you when you return to our website. This enables us to personalise our content to you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in our Cookie Policy.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. The following instructions explain how to adjust your settings in the most commonly used browsers, and you can also visit www.aboutcookies.org, which gives comprehensive information on managing cookies in a wide variety of browsers.

Google Chrome

  • * Open the 'Menu' (icon) on the toolbar
  • * Choose 'Settings'
  • * Open 'Advanced Settings'
  • * Go to the 'Privacy' section and click on 'Content Settings'
  • * In the 'Cookies' section, you can choose how cookies are used when you browse using Chrome

Mozilla Firefox

  • * Open the 'Edit' menu
  • * Choose 'Preferences'
  • * Open 'Privacy & Security'
  • * Choose 'Cookies'

Internet Explorer

  • * Open the 'Tools' menu
  • * Select 'Internet Options'
  • * Open the 'Security' tab
  • * Choose the 'Internet' zone
  • * Identify the security level 'High' for this zone
  • * Click 'OK'.

We may share your personal data with trusted third parties. For example, to delivery your orders, to handle complaints, for fraud management, to help us personalise our offers to you and so on.

This is 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.
  • We have a data processing agreement in place with any third party we share your personal data with.
  • We require all third parties to respect the security of your personal information and to treat it in accordance with the law.
  • We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
  • 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.

Third parties we work with are:

Courier Services Delivery of your orders, including proof of delivery and tracking information. Depending on the service chosen this will be one of Hermes, DPD, Parcel Force or United Broker.
Data Insight Behavioural analysis that allows us to personalise your experience and the information we provide to you. We use Google Analytics, Google Big Query, RedEye, Qubit and The Blueberry Wave.
Email Services How we manage our electronic communication with you. This is done through either IBM, RedEye and Fresh Relevance.
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.
IT Services We use a number of partners to support our website and other business systems but only share your information with Google
Legal Services When necessary we will enlist BPE or Eversheds solicitors for resolution of legal matters.
Mailing Services Addressing of printed material will be provided by Metromail and then delivered by either Whistl or the Royal Mail.
Payment Services During the payment process you will be directed to options to Adyen, PayPal depending on your preference.
Review Services Should you wish to comment on our products or service you will be able to do so via our chosen review service provider, FEEFO.
Social Media So we can show you products that might interest you while you are browsing the internet, we use the services of Google, Facebook, Twitter and Instagram.
Law enforcement We may 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.
Regulatory bodies When appropriate your personal information may be shared with The Revenue Comissioners, the UK Information Commissioner’s Office, regulators and other authorities who require reporting of processing activities in certain circumstances.
Affiliate Partners So we can confirm your purchase to your chosen affiliate and ensure you receive your cashback or they can receive their commission, we use AWIN (who in turn may use other affiliate partners).

We may also disclose your information to 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 information in the same way as set out in this policy.

When you access our website from Ireland, the information you provide to us is stored on our secure servers in the United Kingdom, or within the EU.

We will take all steps reasonably necessary to ensure that your data is treated securely, including a formal review of the security provisions of 3rd party Data Controllers we use, including taking the following safeguards:

  • Network security. We deploy security and monitoring tools that restrict access and alert us to any unauthorised behaviour on our network and systems.
  • Data Transfers. All data transfers are carried out using multi-layered security measures to ensure data integrity and privacy.
  • Firewalls and encryption. We apply industry-standard firewall protection and use up to date, not compromised, encryption technology.
  • Auditing and Testing. We carry out regular penetration testing and employ ethical hackers to ensure our infrastructure is secure and any intrusion would be quickly detected.
  • PCI DSS standards. We comply with the Payment Card Industry Data Security Standards in relation to debit/credit card payments made on our website.
  • Building entry controls. Our premises and those of the 3rd parties we use are access controlled and monitored always, with on-site security and CCTV traceability.
  • Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
  • Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
  • Access and control. We maintain strictly controlled access to systems and data based on the authorised roles of staff.
  • Training. We ensure our employees are trained in the importance of data security.
  • Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Union, to recipients in countries approved by the European Commission, to recipients that are party to the EU-US Privacy Shield, or by using specific contracts approved by the European Commission).

If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

The length of time that we will store your data will depend on the 'legal basis' for why we are using that data, as follows:

Legal basis Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is in the public interest We will use/store your data for as long as it remains a matter of public interest for us to do so. The law sets out what matters are considered to be in the public interest, and we will use/store your data in accordance with those requirements
Where we use/store your data because it is necessary for our legitimate business interests We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)
Where we use/store your data because you have given us your specific, informed and unambiguous consent We will use/store your data until you ask us to stop

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements, for example, we will retain information relating to orders you place with us for 6 years so we can meet our statutory obligations.

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

  • You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
  • You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
  • You have the right to ask us to erase the information we hold about you (the 'right to be forgotten'). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
  • You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
  • You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
  • Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
  • Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
  • You have the right to object to us using/storing your information for direct marketing purposes.

If you wish to exercise any of your legal rights, please contact our customer services team by writing to the address at the top of this policy, or by emailing us at privacy@mandmdirect.com.

You also have the right, at any time, to lodge a complaint with the UK Information Commissioner's Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you. You can also lodge a complaint with the Irish Office of the Data Protection Commissioner, who may then refer your complaint to the Information Commissioner’s Office in the UK.

You can ask us to stop sending you marketing communications at any time by:

  • Using the unsubscribe link in our emails.
  • My Account holders can update their preferences on the website.
  • Contacting our customer services team by:

We may undertake 'profiling' to ensure you only receive information that we believe is relevant to you (for example, where we had a special offer that was relevant only to young adults under the age of 25, we would profile those of our customers to whom we can legitimately send marketing emails to ensure that the marketing email is sent only to appropriate recipients).

We will not carry out “profiling” if you have provided us with information that indicates that you are under the age of 18.

We may undertake credit reference checks with Experian.

Otherwise, we do not make any decisions that produce legal effects concerning you, or which would otherwise significantly affect you, by means of an automated decision-making process.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.

Questions, comments and requests regarding this policy are welcomed and should be addressed to our customer services team by writing to the address at the top of this policy, or by emailing us at privacy@mandmdirect.com.

Cookies and Security

We use the following cookies:

Type Purpose Who
Strictly necessary cookies. These are cookies that are required for the operation of our website. These include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of billing services. Website cookies
Analytical / performance cookies They allow us to recognise and count the number of visitors and to see how visitors move around our website when they’re using it. This helps us to identify issues with our site and improve the way our website works.
  • App Dynamics
  • Google Analytics
  • Redeye
  • Adrum
  • Akamai
Functionality cookies These are used to recognise you when you return to our website. This enables us to personalise our content to you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Site cookies
  • Qubit
  • Fresh Relevance
Targeting cookies These cookies record your visit to our website, the pages you’ve visited and the links you’ve followed. We’ll use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
  • Google Adwords
  • Bing AdCenter
  • DoubleClick
  • Facebook
  • Affiliate Window
  • Instagram
  • Twitter
  • Silverpop

Please note that the exact names may change from time to time and there may be a slight delay in the table being updated. Third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

We currently have an “implied consent” policy in place. This means that we’ll assume by your continued use of our website that you are happy for us to use the cookies listed above unless you take certain steps to opt out of using the same. You have the ability to accept or decline cookies by modifying the settings in your browser. The majority of browsers will allow the user to alter the settings used for cookies. The help menu on your browser will have further details. You may also notice that some cookies that are not related to MandM Direct, and are in fact third party cookies. As we are unable to control these cookies, we would encourage you to look at the third-party’s website for more information about their cookies. Further information on how to change your browser settings can also be found by visiting aboutcookies.org

Turning cookies off will restrict your access to our website. If you have your browser set to disable all cookies then you will not be able to access many parts of our website. If your browser is set to prompt you when cookies are being used, you will have to answer ‘yes’ when prompted to gain full access.

To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout

Sale of business
In the event that MandM Direct is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchaser and their advisers and will be passed on to the new owners of the business.

Updating your details
If any of the information that you’ve provided to us has changed, e.g. you change your email address, name or payment details, let us know by emailing customerservices@mandmdirect.com, or sending a letter to MandM Direct Limited, Customer Services Dept, Clinton Road, Leominster, Herefordshire, HR6 0SP, UK.

Disclosure of information
We comply with and are registered under the Data Protection laws in the United Kingdom. We take all reasonable care to prevent any unauthorised access to and use of your personal data. We maintain a responsibility to keep your information confidential and will only use it to offer relevant products and services to you. We’d also like to send you information about special features of our website or any other service or products we think may be of interest to you. If you do not wish to receive any mailings, email unsubscribe@mandmdirect.com with your email address, customer number or name and address details.

Your consent
By submitting your information you consent to the use of your information as set out in this Policy. If we change our Privacy Policy we will post the changes on this page, and may place notices on other pages of the website, so you will be aware of the information we collect and how we use it at all times. Continued use of the service will signify that you agree to any such changes. Owing to the global nature of the internet infrastructure, the information you provide may be transferred to companies based in countries outside the European Economic Area that do not have similar protections in place regarding your data and its use as set out in this policy. However, we have taken the steps outlined above to try to improve the security of your information, and where we pass your information to such companies (other than in transit across the internet), we will ensure that they treat your information with the same level of protection as if we were dealing with it ourselves. By submitting your information you confirm your consent to these transfers.

Advertisements on our site are provided by another organisation. Our advertising partner will serve ads that it believes are most likely to be of interest to you, based on information about your visit to this and other websites (this information is anonymous in that it does not include your name, street address, e-mail address or telephone number). In order to do this, our advertising partner may need to place a cookie (a small text file) on your computer. For more information about this type of online behavioural advertising, about cookies, and about how to turn this feature off, please visit youronlinechoices.com/uk

We take your security very seriously, and we’ve invested in a totally secure and safe website for you to shop. Once you checkout, we encrypt all your details using Internet standard encryption technology (TSL/SSL).

If a site is secure, a padlock will appear in the bottom right hand section of your screen when you are in the personal data/ payment card entry area. Occasionally the padlock will not be visible but the page is still secure. If you do not see the padlock, you can check by right-clicking anywhere on the page (except on an image) and select Properties. If the URL starts https: the s indicates that the page is secure.

If you have any questions about the online security of MandM Direct please email customerservices@mandmdirect.com

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