247 Home Furnishings Ltd (“247 Blinds”/”we”/”us”) is registered with the Information Commissioners Office. Our registration number is Z3651543. The person who oversees data protection at 247 Blinds is our Data Compliance Manager.
247 Blinds is a “data controller”. This means that we are responsible for deciding how we hold and why we use data about our customers (“customer”/”you” includes, but is not limited to, persons who order products or samples from us and persons who contact us with product or service enquiries (by any means such as via our website, via email or via telephone), to provide feedback or to send a complaint).
We are required under data protection legislation to notify our customers of the information contained in this privacy notice. We have a duty to keep the personal data about our customers secure and maintain confidentiality and we will do so.
What personal data do we process?
We may collect the personal data of our customers either through our online website, by way of email correspondence or over the telephone.
The personal data which we retain and process about our customers include the following:
- Full names;
- Delivery and billing postal addresses;
- Email addresses;
- Telephone numbers;
- Order and enquiry details and contents;
- Method of payment (e.g paid by paypal, mastercard, visa or bank transfer)
- Bank details (in limited circumstances such as when processing refunds, NOT when a customer places an order through our website). We do not retain payment card details when a customer places an order with us through our website. This data is processed and retained by our third-party payment gateway service of whom we have an agreement with.
We may also request and process documents which evidence the customer’s identity in circumstances when we must verify the identify of our customers for fraud or data request purposes.
Our website automatically collects certain types of usage data which is anonymous to us. This is processed and retained through Google Analytics. This data may include IP addresses, location data as well as the times and dates you have visited our website and what products you have placed in the online basket on our website/in your account with us. Please see our cookies policy for more information. This information is anonymous to us therefore we cannot identity you solely through this data.
How might we use your data?
We may use the personal data of our customers, which we hold, in one or more of the following ways (all of which can be placed into a ‘lawful basis’ of processing):-
- to administer and provide samples, goods and services which our customers order or have made an enquiry about (including by means of online, email and telephone correspondence);
- to fulfil our contractual obligations regarding the provision of samples, goods and services with our customers or to enter into a contractual agreement with them;
- to enable us to administer any offers or promotional material which our customers request/enter in to or enquire about;
- to communicate with our customers regarding any products or services you have enquired about;
- to provide our customers with information about other goods or services we offer that are similar to those that you have already contracted with us to provide, or enquired about. You many opt out of receiving any marketing information/offers at any time by contacting us or by ‘unsubscribing’;
- to carry out market analytics (using anonymous data) in order that we can improve the goods and services we offer to our customers;
- to generate anonymous statistics relating to the use of our website;
- to notify our customers of any changes in terms or conditions, or about the goods or services which we offer;
- for identification and payment verification (to process orders and refunds, in certain circumstances);
- to deal with or respond to any feedback or complaints made by our customers;
- if required to do so by law or by a relevant authority (such as the ICO or HMRC).
What about third-party disclosure?
We disclose our customers personal data to our third-party service providers such as courier companies, suppliers and payment providers for the purposes of fulfilling a contract and providing services and goods to our customers.
For example, we send our customers’ delivery address and contact details to our contracted courier companies so they are able to deliver the customers’ order to them. However, when we use third party service providers, we disclose only the personal data that is necessary to deliver the service and we have an agreement in place that requires them to keep your information secure. You have the right to request copies of your personal data which we have disclosed to third-parties.
We may also share your personal data with third-party marketing agencies which we engage, to legal or regulatory bodies such as the ICO, HMRC or the Police for law enforcement purposes, to our appointed lawyers, accountants and auditors, and to businesses that are part of the same group of companies as us.
We will not sell your personal data to third-parties.
What are your personal data rights?
You are entitled to request copies of the data we hold about you. You are also entitled to receive confirmation from us that we are processing your data, what that data is, and to ensure that your data is correct and ask for it to be rectified if it is not.
In addition, you have the right to object to our processing your data and ask that it be deleted. However, whether we agree to the deletion will depend upon the circumstances and whether we consider it necessary to retain the data for the original purpose for which it was obtained. You also have the right to ask that we transfer data to a third party; provided we have the necessary authority from you to do so.
Contact [email protected] to exercise any of your data rights. We will then consider your request and action the same as necessary although in some circumstances we may have a legitimate reason for refusing to action your request. If this should be the case, then we will notify you with the reason/(s). We may suspend taking action upon a request until we are satisfied with the verification of your identity which may include processing identity documents.
What about marketing?
On the lawful basis that it is a legitimate interest of our business, we may retain the contact details of our customers indefinitely (being name, address, contact numbers and email address) for marketing purposes in order to keep you updated with information, including email mailshots with details of products and product offers (which relate to blinds, curtains, shutters and other products of a similar nature which we sell/supply) which we believe may be of interest to you. This is known as ‘soft-opt in’ marketing. We do however provide an option to all customers who place an order with us through our website on whether they want to receive marketing from us, at the time of placing their order, or not. We do not use ‘pre-ticked’ opt-in boxes.
This contact data may be shared with third-party marketing agents who will process the data on our behalf, through use of ‘mailshots’, for these specific marketing purposes (subject to a written agreement with them). You have the right to ‘unsubscribe’ to any marketing emails from us at any time. The action to ‘unsubscribe’ is included at the bottom of each marketing email sent; alternatively email [email protected] to unsubscribe manually.
If you would like to exercise any of your rights or object to our marketing on the above basis, please email [email protected]
What about if we change the purpose of processing your data?
We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How will we keep your data secure?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties, most pertinently our suppliers and contracted courier companies who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We retain the personal data about our customers in electronic format on the company’s secure, internal computer system and sometimes in paper-format kept in the company’s premises’.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will we keep your data for?
We will only keep the personal data of our customers for as long as we need to in order to fulfil the purpose for which is was originally collected (which will usually be on the basis of fulfilling a contract with our customers) or for any subsequent purpose provided the subsequent purpose is compatible with the original purpose and it is in our legitimate interests to do so, or for as long as necessary to comply with a legal obligation (including for tax and limitation periods). We review our data retention periods (including the statutory minimum periods) on a regular basis.
At the end of the relevant retention period, the data of our customers will either be securely disposed of 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 (subject to marketing purposes for existing customers).We may keep customer’s contact data indefinitely for the purposes of marketing provided that the customer has opted-in to our marketing material and has not since opted-out.
The company’s computer system automatically retains email addresses that have been used by the company. The company considers that this is necessary in the legitimate interests of the company and the potential impact of the holder of the email address is minimal. The company’s email addresses includes an email footer explaining on what basis we retain email addresses and what steps they can take to ask us to delete their email address from our system.
How can you contact us?
- By email at: [email protected]
- Or write to us at:
FAO: Data Compliance Manager
247 Home Furnishings Ltd
172 Blackmoorfoot Road
You have the right to lodge a complaint about us with the Information Commissioner’s Office. Phone the ICO’s helpline on 0303 123 1113 for further details on how to do this.