E.T. Harvey Ltd. is a company registered in the UK (collectively referred to as “Harveys”, “we” or “us” in this policy)
Maintaining the security of your data is a priority at Harveys and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Harveys is also dedicated to being transparent about what data we collect about you and how we use it.
This policy, which applies whether you visit our store, use your mobile device or go online, provides you with information about:
- How we use your data
- What personal data we collect
- How we ensure your privacy is maintained and
- Your legal rights relating to your personal data.
Explaining the legal bases we rely on
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 subscribe 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.
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 Harveys 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.
We may also use your personal details to send you direct marketing information by post, email or phone, telling you about products and services that we think might interest you.
How we use your data
Harveys uses your personal data:
- To provide goods and services to you
- To make a tailored website available to you
- To manage any registered accounts that you hold with us
- To verify your identity
- With your agreement, to contact you electronically about promotional offers and products and services which we think may interest you
- For market research purposes – to better understand your needs
- To enable Harveys to manage customer service interactions with you
- Where we have a legal right or duty to use or disclose your information
Harveys uses your personal data for electronic marketing purposes (with your consent) and may send you postal/electronic mail or phone to update you on the latest Harveys’ offers.
Harveys aims to update you about products and services which are of interest and relevant to you as an individual.
You have the right to opt out of receiving promotional communications at any time, by:
- Changing marketing preferences by contacting us
- Making use of the ‘unsubscribe’ link in emails
We may analyse your browsing and purchasing activity, both online and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allows us to ensure that we contact you with information on products and offers that are relevant to you. To do so, we use software and other technology (automated processing).
Sharing data with third parties
Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing services providers.
Harveys only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which means they can only use your data to provide services to Harveys and to you, and for no other purposes.
Other third parties
Aside from our service providers, Harveys will NOT disclose your personal data to any third party, except as set out below. We will never sell or rent out customer data to other organisations for marketing purposes.
We may share data:
- To comply with legal obligations
- For the protection of our employees and customers
- With credit reference agencies where necessary for card payments
- Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so
- To exercise our legal rights
- For the prevention, detection, investigation of crime or prosecution or offenders.
How long do we keep your data?
We will not retain your data for longer than necessary for the purpose set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 10 years.
When do we collect your personal data?
- When you visit our website, and use your account to buy products and services, or redeem loyalty points, on the phone, in a shop or online.
- When you make an online purchase.
- When you create an account with us.
- When you purchase a product or service in store or by phone and you use your loyalty card.
- When you engage with us on social media.
- When you join the Harveys privilege loyalty scheme.
- When you contact us by any means with queries, complaints etc.
- When you ask us to email/message you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about a member of our staff who provided that service, it may be passed on to them if requested.
- When you fill in any forms. For example, if an accident happens in store, a member of staff may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
What personal data do we collect?
Harveys may collect the following information from you:
- Your name, age/date of birth and gender
- Your contact details: postal address, telephone numbers (including mobile numbers) and email address
- Purchases and orders made by you
- Your online browsing activities on the Harveys website
- Your communication and marketing preferences
- Your location
- Your correspondence and communications with Harveys
- Personal details which help us to recommend items of interest.
For example, you might tell us your clothing size, which we’ll use to guide our suggested items. Or you might share information on your skin type which allows us to recommend appropriate beauty brands.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
Our website is not intended for children and we do not knowingly collect data relating to children. This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this policy. Some of the personal data is collected directly, for example when you sign up for a privilege card or click to subscribe to our newsletter. Other personal data is collected indirectly, for example your shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
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 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 send 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.
- To protect our customers, premises, assets and staff members from crime, we operate CCTV systems in our stores which record images for security. We do this on the basis of our legitimate business interests.
- 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.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, 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 when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To administer any of our prize draws or competitions which you enter, 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.
- 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. 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 inspiration or content to share with you.
How we protect your data
Harveys is committed to keeping your personal data safe and secure. Our security measures include:
- Security controls which protect Harveys IT infrastructure from external attack and unauthorised access and
- Internal policies setting out our data security approach and training for employees.
You have the following rights:
- The right to ask what personal data we hold about you at any time
- The right to ask us to update and correct any out of date or incorrect personal data that we hold about you free of charge, and
- The right to opt out of any marketing communications that we may send you.
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.
If you wish to exercise any of the above rights, 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.
- Write to us at E.T. Harvey Ltd, 9 Rawson Street, Halifax HX1 1LJ
- Email us at email@example.com
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
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.
In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email, test messages or telephone calls.
Customers have the right to withdraw consent at any time.
Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Harveys, including:
- Selling and supplying goods and services to our customers
- Protecting customers, employees and other individuals and maintaining their safety, health and welfare
- Promoting, marketing and advertising our products and services
- Sending promotional communications which are relevant and tailored to individual customers (including administering our loyalty scheme)
- Understanding our customers’ behaviour, activities, preferences and needs
- Improving existing products and services and developing new products and services
- Complying with our legal and regulatory obligations
- Preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies
- Handling customer contacts, queries, complaints or disputes
- Managing insurance claims by customers
- Protecting Harveys, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Harveys
- Effectively handling any legal claims or regulatory enforcement actions taken against Harveys and
- Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders
What are cookies?
How are cookies managed?
The cookies stored on your computer or other device when you access our website are designed by:
- Harveys, or on behalf of Harveys, and are necessary to enable you to make purchases on our website
- Third parties who participate with us in marketing programmes
- Third parties who broadcast web banner advertisements on behalf of Harveys.
What are cookies used for?
The main purposes for which cookies are used are:
- For technical purposes essential to effective operation of our website, particularly in relation to online transactions and site navigation
- For Harveys to market to you, particularly web banner advertisements and targeted updates
- To enable Harveys to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc.
- To enable Harveys meet its contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.
How do I disable cookies?
If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
What happens if I disable cookies?
This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies, you will be unable to complete a purchase on our site.
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.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
To deliver products and services to you, it is sometimes necessary for Harveys to share your data outside of the European Economic Area.
This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers.
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at firstname.lastname@example.org
- Phone 01422 331188
- Or write to us at Data Protection Officer, E.T. Harvey Ltd. 9 Rawson street, Halifax, HX1 1LJ
You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at ico.org.uk.
This policy was last updated in May 2018