Updated May 2018.
1. Data Controllers and Data Protection Officer
A data controller is an organisation that collects and uses personal data and has responsibility for how the personal data is used and managed.
Homestyle Nationwide Limited provides your goods and is the data controller of personal data that you provide when you order goods. Homestyle Nationwide Limited’s websites are www.homestyle4u.co.uk and www.homestyle247.com.
In the context of this privacy notice, when we use the term ‘we’ it means Homestyle Nationwide Limited.
The Data Protection Officer for Homestyle Nationwide Limited can be contacted at firstname.lastname@example.org
2. How We Use Your Data
We use your personal data to provide goods and services to you and to enter into and administer any credit accounts or financial services products you may have with us including your Rainy Day Savings Account if opened.
We will use your personal data in the following ways:
- To provide goods and services and to manage your retail account including administering payments, returns and responding to queries.
- To assess whether to offer you a credit facility and for ongoing administration of any credit facility.
- To administer any financial services products that you have.
- To administer any prize draw or competition you may enter.
- To analyse your shopping preferences or how you interact with or use our websites.
- For research and statistical purposes.
- To send you special offers or discounts and to tell you about our products and services. You control your preferences in respect of how your personal data is used for marketing and you can change these preferences when you log in to My Account.
- To inform you when items are available that you add on your wishlist.
- To possibly record and monitor outbound and inbound telephone conversations with you to ensure consistent service levels, to prevent or detect fraud, to resolve queries and complaints and for performance management and training purposes.
We will collect personal data directly from you when you purchase goods or services, apply for a account or savings account, or change any of your details (such as your name or address) via My Account. We require you to provide personal data in order to assess whether to enter into a contract with you or to perform our contract with you and if you do not provide the personal data we request, we will be unable to enter into or fulfil this contract.
We obtain data from third party sources such as publicly available information relating to you on the internet (for example on social media websites).
We may also obtain personal data from third party companies for the purposes of sending marketing communications to you. Such marketing communication may be sent by ourselves or by the third parties. These third parties must check you have given your permission for such contacts to take place.
3. Why We Need Your Personal Data
We need to process your personal data for a number of different reasons and these are our legal bases for processing. We also need to keep your personal data for as long as is necessary for us to operate our business and to comply with legal and regulatory obligations.
We rely on one or more of the following legal bases for processing personal data:
- To perform our contract with you or to enter into a contract with you
We need to process your personal data to fulfil our contract with you or to assess whether to enter into a contract with you, whether this is in selling and delivering goods and services to you or providing credit facilities or other financial services products to you.
- To comply with legal obligations to which our business is subject.
We have to comply with relevant law and regulation in order to provide retail and financial services products and we will need to process your personal data in order to comply with these legal obligations.
If we are relying on consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.
We will keep your personal data for the purposes set out in this privacy notice and only for as long as any legal basis continues to apply. Below is a non exhaustive list of some of the reasons we need to retain your personal data:
- Compliance with the requirements of the Financial Conduct Authority
- Compliance with Anti Money Laundering Regulations
- Ensuring we have relevant information in the event of any queries or complaints
- Being able to identify if you have purchased a product which is subject to a product recall
- Being able to service any product or service guarantee you have purchased
- To assist with the establishment, exercise or defence of legal claims
The length of time we need to keep the personal data will vary depending on the nature of the personal data and the reason we are obliged to hold it.
4. Who We Transfer Data To
Transferring personal data to other organisations needs to take place with appropriate safeguards and you can be assured that we will only share the personal data that is needed for these organisations to be able to provide the right service to you or support us in doing so.
We may transfer your personal data to the following third parties:
- Other companies within the Homestyle group of companies – including for credit assessment purposes or for fraud prevention purposes
- Technology service providers – our partners who provide IT and website services.
- Delivery companies – our couriers, parcel firms and mail firms who deliver your goods or services and manage any returns on our behalf.
- Distributors and manufacturers of goods – our partners who fulfil orders and deliver products to you and manage any returns on our behalf.
- Product service providers – our partners who provide products and services such as insurance or extended warranties.
- Marketing service providers – our partners who work with us to make sure we send your information about products, services and special offers that are of interest to you.
- Regulators and other governmental agencies or law enforcement agencies.
We will only transfer your personal data to third parties who adhere to appropriate data security standards and controls. From time to time we may need to transfer your personal data to other countries. Where this is the case, we will ensure that the transfer is subject to appropriate safeguards to protect your personal data and complies with applicable law which may include having standard contractual clauses in place with the third party. For further information on how data can be transferred to other countries, please find enclosed a link to the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection_en
5. Your Rights
You have certain rights in respect of your personal data and we have processes to enable you to exercise these rights.
Right of Access
This is known as a Subject Access Request. If you want to know if we are processing personal data relating to you and to have access to any such personal data you can call us on 07525 700 840
Right to Rectification
If you believe that we hold inaccurate personal data about you, then you can either update this information directly by logging in to My Account and updating the relevant details or you can request that we carry out a review by calling us on 07525 700 840. Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. If we are satisfied that the personal data is inaccurate we will make the necessary changes.
Right to Erasure
You have a right to ask for your personal data to be erased in certain circumstances. However, this right does not apply where we have to comply with a legal obligation or where we need personal data for the establishment, exercise or defence of legal claims. Therefore we cannot comply with an erasure request where you have a retail shopping account, owe money on a your account or have otherwise bought products and services for which we must keep records. In addition, if you opt out of marketing communications or have previously opted out of marketing communications, we have to keep a record or such opt out to ensure that we don’t contact you in the future.
Right to Restriction
You have a right to request that processing of personal data is restricted in certain circumstances. However, we shall still continue to process the personal data for storage purposes, for the establishment, exercise or defence of legal claims or with your consent
Right to Object
Where we are relying on consent as a legal basis to process your data, you have a right to object to such processing on grounds relating to your particular situation.
If you object to our use of your personal data for marketing purposes, we will opt you out of marketing. You can do this by logging into My Account and amending your preferences or you can call us direct. To enable us to consider any objection we will need to know what specific interests, rights or freedoms relating to your particular situation you believe will potentially be put at risk by our processing. If we do stop processing your personal data (apart from for direct marketing purposes), this may affect our ability to trade with you.
From time to time, in deciding whether to enter into a contract with you, or during the ongoing performance of a contract, we take decisions based on automated processing which produces legal affects or similarly significantly affects you, for example, deciding whether to offer a credit facility or assessing a fraud risk. We use data from a variety of sources in our automated processing for credit scoring and fraud decisioning and we use statistical methods to produce the results. This logic helps us understand the risk posed by individuals by placing a weighting on certain criteria which is then calculated to give an overall score.
There are a number of consequences of such automated processing:
- we may open an account and you can purchase goods and services using this account
- we may increase or decrease your credit limit from time to time
- we may decide to offer you other credit terms such as pre ordering
- we may refuse your application for credit or we may decide not to offer certain credit products which may have an impact on your ability to purchase goods and services from us. This is in line with our obligations as a responsible lender as we have to assess affordability for credit purposes and to protect customers from financial distress and difficulty
- we may conduct a further review or request additional information from you in relation to your request to purchase goods and services if our fraud decisioning highlights any issues
We also use automated processing in relation to the information we hold about you to make recommendations of products and services we think you would be interested in and to improve your experience when you visit our website by making it relevant and tailored to you.
Right to Complain to the Information Commissioner
You have the right to lodge a complaint with the Information Commissioner and more details can be found on their website www.ico.org.uk.
6. Account Applications
We do not use credit reference agencies (‘CRAs’).
Instead we will ask you to supply us with several forms of ID
We will use this information to:
- Assess your creditworthiness and whether you can afford to make the weekly payments
- Verify the accuracy of the data you have provided to us
- Prevent criminal activity, fraud and money laundering
- Manage your account(s)
- Trace and recover debts, and
- Ensure any offers provided to you are appropriate to your circumstances.
7. Fraud Prevention
Before we provide services or goods to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
What We Process & Share
The personal data you have provided, we have collected from you, or we have received from third parties may include your:
- date of birth
- residential address and address history
- contact details such as email address and telephone numbers
- financial information
- employment details
- identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address
When we process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also necessary to enable us to enter into and perform our contracts with you.
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:
- our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct; or is inconsistent with your previous submissions; or
- you appear to have deliberately hidden your true identity
Consequences of Processing
If we determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
Your personal data is protected by legal rights, which include your rights to:
- object to our processing of your personal data
- request that your personal data is erased or corrected
- request access to your personal data
For more information or to exercise your data protection rights, please contact us using the contact details above.
If you are unhappy about how your personal data has been used please refer to our complaints policy.
You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.
8. How To Contact Us
If you have any queries about how we use your information or on data protection generally please call us on 07525 700840, send an email to email@example.com or write us at PO BOX 195, Hailsham, BN27 9BH
From time to time we may contact you with details on special promotional offers or products that we think you would be interested in, via Email, Telephone, SMS, Post or from specially selected Third Parties, If you do not want to receive these communications you can opt out in the following ways:
- Existing customers who have registered their account online – log into My Account, go to Account Details’ / Preference Centre’ and tick each method of contact you wish to opt out of.
- If you don’t have an account or your account isn’t registered online – call us on 07525 700 840 or write us at PO BOX 195, Hailsham, BN27 9BH Please state which contact method you wish to be removed from (existing customers should provide their Account Number). Please clearly state whether you wish to be removed from our email, texts or both.