Privacy Policy

Fenn, Wright & Manson Limited

PRIVACY Policy

We are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data 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 data and how we will treat it.

For simplicity, throughout this notice “we” and “us” mean Fenn, Wright & Manson limited (Company number 08002796) of Unit 4, 28 York Way, London N7 9AG, UK.  Under the relevant Data Protection Laws (including the ED General Data Protection Regulation), we are the data controller of the data you give to us.

1.    What Personal Data we collect from you

We collect and process the following data about you:

  • When you make an online purchase or place an order over the phone we collect and process transaction-based data which may include your payment card information, billing/delivery address, orders and receipts, email and telephone number. We may also collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, for the purposes of fraud screening.
  • When you create an online account with us we collect and process the information you provide including (where provided by you) your name, gender, date of birth, billing/delivery address, email and telephone number.  For your security, we’ll also keep an encrypted record of your login password.
  • When you shop with us, we may collect and process details of your transaction history and shopping preferences including details of purchases you made, items viewed or added to your basket.
  • When you engage with us on social media.
  • When you contact us by any means with queries, complaints etc.
  • When you enter Fenn, Wright & Manson prize draws or competitions.
  • When you choose to complete any surveys we send you. 
  • When you comment on or review our products.
  • When you’ve given a third party permission to share with us the information they hold about you.
  • Details of your interactions with us through our customer service or online.

2.    How we collect Personal Data

We collect personal data from you by the following means:

  • Information you give us. You may give us information about you by: entering into transactions, opening an account on our site www.fennwrightmanson.com (our site), filling in forms or providing information in store, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when:
    • You purchase goods online;
    • Register an online account on www.fennwrightmanson.com
    • Search for a product;
    • Participate in discussion boards or other social media functions;
    • Enter a competition, promotion or survey; and
    • When you report a problem with our site.

The information you give us may include your name, address, e-mail address and phone number, debit or credit card information, personal description and photograph.

  • If you choose to create an account, you will be able to manage your personal data online via www.fennwrightmanson.com . If you do not choose to do so, you will not be able to view or modify this information. If you wish to change any preferences and you have not created an account, please contact Customer Services.
  • With regard to each of your visits to our website we may automatically collect the following information:
    • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
  • Our website uses 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 site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
  • We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) and may receive information about you from them.

3.    How we use your personal data

We may collect and process your personal data for a number of reasons including:

3.1.  Consent

Where we have collected data with your consent, we will process such data in accordance with the consents that you have provided.  For example:

    • Where you have consented to receive direct marketing from us, we will use your personal data, preferences and details of your transactions to keep you informed about relevant products including tailored special offers, discounts, promotions, events, competitions and so on.  We shall keep you informed in line with your marketing preferences.  You are free to opt out from any such marketing communications (see section 8 of this policy for further details).
    • Where you provide us with personal data for a specific purpose (such as complaints, claims, online transactions) we will process such personal data for that specific purpose.
    • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
    • To display the most interesting content to you on our website, we may use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive notifications for our website to place cookies or similar technology on your device.
    • Where you provide us with images of you in relation to a promotion, blog or prize draw and consent to us using such images.

 3.2.  Contractual Obligations

We may need your personal data to comply with our contractual obligations. For example, we will need to process personal data to deliver goods you have purchased online.

3.3.  Legal Compliance

If required by law, we may need to collect and process your data.  For example, we may need to process personal data to comply with our legal obligations to share data with law enforcement or to comply with an order from the court.

3.4.  Legitimate Interest

We process your data to 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.

These legitimate interests include the following:

 

3.4.1.    Direct Marketing and good customer service

It is a legitimate interest of our business to contact our customers for the purposes of direct marketing. 

Subject to their marketing choices, we send customers who have transacted with us personalised communications in relation to new products and ranges and offers by email and we do so on the basis of our legitimate interests.

We use the data we have to offer you promotions and products that are likely to be relevant to you.

You can, of course, decide not to receive any direct marketing from us.  Section 8 provides details as to how you can opt out of direct marketing from us or change your marketing preferences.

3.4.2.    Surveys

From time to time, we may send you requests to take part in a customer survey to improve our products or your shopping experience.  It is entirely optional as to whether you wish to take part in any such survey.  These messages will not include any promotional content and do not require prior consent when sent by email. We have a legitimate interest to do so as this helps make our products more relevant to you.

Of course, where we ask you for personal data to improve your shopping experience, it is always your choice as to whether you give us that information.  If you want to change how we use your data, please see the details in the section 8 of this policy.

3.4.3.    Process orders

We will need to collect and process data in order to process any orders online.  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. 

We may share personal data with Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, your details will need to be passed to a third party to deliver product ordered online.

If you are looking to pay by debit or credit card we will need to process your payment card data in order to complete the transaction. We process card payments in accordance with the Payment Card Industry Data Security standards. 

Following a transaction, we may keep your details for a reasonable period afterwards in order to fulfil contractual obligations such as refunds.

3.4.4.    Refunds and complaints

We have to process personal data in order to respond to your queries, refund requests and complaints.

We may also keep a record of your queries, refund requests and complaints for the following purposes:

-          To inform our future communications with you;

-          To review whether there are any patterns regarding the complaints we receive, for example, quality issues with any particular products;

-          To be able to demonstrate how we dealt with your complaint; and 

-          To consider how we can improve our services based on your experience.

In such circumstances we will process your personal data in accordance with our contractual and legal obligations with you and our legitimate interest to provide you with good customer service. 

3.4.5.    Security

We have a legitimate interest to protect our customers, our business, our employees from criminal and illegal activity such as fraud and theft.  Therefore, we may process personal data as follows as part of our legitimate business interest:

  • Using your personal data to maintain, update and safeguard your online account.
  • Monitoring your browsing activity with us to identify and resolve any problems and protect the integrity of our websites.   This will include checking passwords and using automated monitoring of IP addresses to identify possible fraudulent log-ins.
  • Processing payments and preventing fraudulent transactions.

If we discover any potential criminal activity we will use personal data (such as transaction monitoring, etc.) to investigate the potential criminal activity and, where appropriate, pass the details of such potential criminal activity to the police and other relevant regulatory authorities. For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems with third parties such as law enforcement bodies and the relevant financial institutions.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body upon a valid request to do so. We assess such requests on a case-by-case basis whilst taking the privacy of our customers into consideration.

3.4.6.    Updates on law and our policies

We may send you communications required by law or which are necessary to inform you about changes to our business and/or issues regarding our products.  For example, we may contact you by email regarding updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

4.    Sharing Your Data

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • If Fenn, Wright & Manson Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements; or to protect the rights, property, or safety of Fenn, Wright & Manson Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • In order to support, operate, maintain our website, to assist your user experience of the website and for fraud management we currently use the following IT companies who may process your personal data pursuant to contracts with Fenn, Wright & Manson:
    • Bluebolt Ltd
    • PCR Computers Ltd
    • Mailchimp (The Rocket Science Group)
    • Sage Pay Europe Limited
    • PayPal (Europe) Sarl et Cie, SCA
  • We also use delivery couriers and a third party warehouse to deliver home delivery orders and click and collect orders.  Currently we use the following:
    • DPD UK Ltd
    • Exclusive Logistics Ltd
  • We also work with:
    • 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 Cookie policy for details.
    • Analytical agencies that provide services that will improve the products and services we offer you.
  • We work closely with the third parties with which we share your data to ensure the that the third parties:
    • Have adequate security measures and policies in place;
    • Will respect and protect your privacy;
    • Only use your data when necessary to perform their specific services in place and will protect your privacy;
    • Will delete your data or anonymise when we have stopped using their services.
  • We will only share data with third parties for their own purposes where you have given your specific consent that we may pass that data to a third party for their direct marketing purposes.

5.    Storing your personal Data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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.

Input of personal data is at the user’s discretion. We have strict policies and procedures regarding the storage, processing and transmission of your personal data.

6.    Managing your Personal Data

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Customer Services at help@fennwrightmanson.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

In general, you can choose how we communicate with you, but there are certain communications which are necessary for the operation of this site or which we are required to send by law, and you cannot opt out of these.

7.    How long is Personal Data kept for?

We will only keep personal data 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.

When you place an order, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations.

8.    Your rights

Under the Data Protection Laws you have the following rights.

8.1.  Direct Marketing

When we are sending direct marketing to you on the basis of our legitimate interest, you have the right to decide not to receive any direct marketing from us.

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.

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels.

You can also exercise these rights and update your preferences at any time by contacting us at Customer Services at help@fennwrightmanson.com or by updating your preferences via Fennwrightmanson.com.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

8.2.  Access to personal data

You have the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Laws and is free of charge in most cases.

If you require access to the information we hold about you, please write to Privacy, Fenn, Wright & Manson Ltd, Unit 4 238 York Way, London N7 9AG.

8.3.  The correction of your personal data when incorrect, out of date or incomplete.

You have the right to request any information we hold is corrected if it is inaccurate. To ask for your information to be amended, please update your online account, or contact our Customer Services team.

8.4.  Legitimate Interests

In general, you can choose how we communicate with you, but there are certain communications which are necessary for the operation of this site or which we are required to send by law, and you cannot opt out of these.

Where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop based on your individual circumstances.  We shall stop any such processing unless we believe that we have a legitimate overriding reason to continue processing your personal data.

8.5.  The right to make a complaint

If you do not consider that your data has been handled correctly by us or you are not happy with our response to any requests you have made regarding our use of your personal data, you have the right to make a complaint to the International Commissioner’s Office.   Their contact number for complaints is 0303 123 1113. 

Further details regarding making a complaint to the Information Commissioner’s Office can be found at https://ico.org.uk/concerns/ (please note that we are not responsible for the content of external websites).

9.    Third party websites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10.  Changes to this policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

11.  Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Privacy at gdpr@fennwrightmanson.com

This notice was last updated on 24/05/2018