Data Protection Laws
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
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.
In certain circumstances, 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.
If 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 Pepper Sq business to law enforcement.
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.
When do We Collect Your Personal Data?
- When you visit any of our websites and use your account (if you have one) to buy products and services, use our incentives, rewards, and promotion schemes when you shop online.
- When you make an actual online purchase and check out. In this case we will ask you to create an account with us to collect transaction-based data. This data will be stored for the next six months according to the law if you will not have returned to us. Your account will remain active in case you are a returning customer.
- When you create an account with us.
- When you engage with us on social media.
- When you download or install one of our apps.
- When you contact us by any means with queries, complaints etc.
- When you ask our Customer Service to email you information about a product or service.
- When you choose to complete any surveys, we send you.
- When you comment on or review our products and services on the Website and social media.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
- When you’ve given a third party permission to share with us the information they hold about you.
- We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
What Personal Data do We Collect?
- If you have a personal account with us on the Website: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
- Details of your interactions with us through our Customer Service, online or by using one of our apps. 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, rewards, incentives, promotions chosen, and wish list choices, brands, products and suppliers you show interest in, web pages you visit and how and when you contact us.
- In case requested, copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's license). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your shopping preferences.
- etails of your visits to our websites or apps, and which site you came from to ours.
Personal details which help us to recommend items of interest. For example, you might tell us your room or space size, which we’ll use to guide our suggested furniture items. Or you might share information on your preference with style, colour, material, which allows us to recommend appropriate furniture items and we will build our service around this.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us and enhance our service to you our customers. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and product reviews.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
How and Why do We use Your Personal Data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards. 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 websites and apps or in store. 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 may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may 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 may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. 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 also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. 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 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.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone, social media accounts and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, and the like. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To administer any of our incentives, rewards, promotion schemes, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
- 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 services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. 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.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the Partnership, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country.
- For Pepperq.com members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become a Pepper Sq member. In order to use your shopping preferences to offer you tailored rewards and promotions.
- We will need to share your details with a third party who is providing a service (such as delivery couriers and carriers for your home delivery). Without sharing your personal data, we’d be unable to fulfil your request, such as delivery of Products.
Combining Your Data for Personalised Direct Marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered through your shopping history with Pepper Sq. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.
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 all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
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:
When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations. In the case of certain products, such as electrical items, we’ll keep the data for 10 years.
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 sometimes share your personal data with trusted third parties. For example, delivery couriers, technicians visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
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.
- Direct marketing companies who help us manage our electronic communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Policy for details.
- Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes. For example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.
- 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.
- For further information please contact our Customer Service specifying your queries about Data Protection.
What are Your Rights over Your Personal Data?
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.
- The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
- Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
- That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
- 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 by a Partner of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
- You can contact us to request to exercise these rights at any time by writing an email to our Customer Service centre.
- If we choose not to action your request, we will explain 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, such as administration of an extended warranty.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking Your Identity
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 that particular division.
- If you have an account, log in into your Peppersq.com account, visit the ‘My Account’ area and change your preferences.
- Request to unsubscribe by emailing our Customer Service.
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
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If You live outside the UK
For all Non-UK Customers:
Pepper Sq operates and trades only in the UK. We don’t have operations outside the UK. However, we recognise our customers might reside outside the UK. If this is the case, 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.
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.
This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.
If you have any questions that haven’t been covered, please contact our Customer Service for Data Protection queries, and we will help you to clarify:
- Email our Customer Service for any Data Protection queries email@example.com
- Or write to us at: Data Protection,
Peper Sq Ltd, Kemp House, 128 City Road, London, EC1V 2NX