We take data protection seriously and safeguarding the privacy of our customers is important to us. It is important that you understand how we look after your personal data and how we make sure that we meet our legal obligations to you under the UK data protection rules (including associated guidance) (the "Data Protection Laws"). This policy ("Privacy and Cookies Policy") sets out how your personal data will be used, stored, and shared by us and what we do to make sure it is safe in our hands. This policy supplements any other fair processing or privacy notices provided to you by us.
In this policy, the terms "we" "our" and "us" are used to refer to Bonmarché Limited, a company incorporated and registered in England and Wales with company registration number 07909526 and registered address at Jubilee Way, Grange Moor, Wakefield, WF4 4SJ. For the purposes of the relevant Data Protection Laws, Bonmarché is the data controller of any personal information you provide to us. This means we are responsible for looking after your personal data. We will use your personal data fairly, lawfully, in a transparent manner and in accordance with the Data Protection Laws.
If you have any questions in relation to this policy or generally how your personal data is processed by us please contact our Data Privacy Office by letter addressed to The Data Protection Lead, Bonmarché, Jubilee Way, Grange Moor, Wakefield, WF4 4SJ or email DPO@Bonmarche.co.uk or call us on 0330 026 2728 and select option 3.
Changes to this Policy
This policy was last reviewed and updated in May 2018.
We are committed to protecting the privacy of our customers and treat all your personal data as confidential, although we may disclose your personal data in specific circumstances as described in this policy. We confirm that any personal information that you provide to us is held in accordance with the Data Protection Laws.
What information do we collect about you?We collect your name, address, e-mail address, telephone number, date of birth, password, CCTV images and call recordings.
Each time you visit our website we may also automatically collect information and personal data about your computer for system administration including, where available, your operating system and browser type. We do this to help us analyse how users use the websites (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience. Please see our Cookies Policy for further information about what information may be automatically collected when you visit our website.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you. You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to provide products to you, respond to your queries, fulfil our obligations to you as a customer, or process your job application.
When do we collect your information?
You give us information when:
You share personal data about yourself and your circumstances by:
- Filling in forms on our website, registering to use our website, and continuing to use our website;
- Participating in customer research, surveys or competitions and events;
- Interacting with Bonmarché on social media;
- Purchasing products from us either online or through our contact centre;
- Registering to join our Bonus Club scheme either online, through our contact centre, or in-store;
- Giving us information about yourself in any communications with us either by telephone, e-mail, post or otherwise, either in connection with your account or to report a complaint or issue; and/or
- Submitting a job application or CV to us;
- When you visit our website, which captures details of your visits, including but not limited to, Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, cookies and other communication data, and the resources that you access. For more information please see our Cookies Policy.
- When you visit one of our stores, CCTV images;
- When you call our contact centre or contact us through another channel, including information about complaints, services and products. We monitor and/or record calls between our staff at our contact centre and you for the purposes of resolving complaints, training and to improve our quality and service standards;
- When you use your Bonus Club loyalty card where we collect information about your purchases;
Where do we get this information from?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our website or store through your communications with us.
We also obtain some information from other third parties including demographic data that we overlay to help us to better understand who our customers are and to inform changes to our products, services and communications.
Additionally, when you participate in surveys and leave product or service reviews we can access the information you supply and use this to make improvements to the customer experience.
We may receive personal data about you from other third parties, including:
from your previous employer, or similar, where we request references if you are applying for a job with us.
Why do we need your information?
The main purpose for which we use your information is to provide you with the information, products or other services that you request from us.
We use your personal information for the following purposes:
- Processing of your orders for example, fulfilment of an online or contact centre telephone order;
- To personalise your repeat visits to our website;
- To make improvements to the look and feel and the way that our website works;
- To tailor offers and incentives to you based on your past purchases;
- To research about our customers' behaviours and our products generally;
- To monitor how best to present our products in-store;
- To improve the products and services we offer you;
- To provide the Bonus Club Spend and Save Scheme and manage the Bonus Club programme;
- To contact you with news on our products and services, offers and incentives where you have given us consent;
- To contact you with updates about your orders;
- For statistical or survey purposes to improve our website and its services to you;
- To administer our website;
- To make your experience more efficient and provide you with a personalised service;
- To keep our stores safe and secure;
- To communicate with you where you are a supplier (or an employee of a supplier) providing services to us; and
- To review your CV and suitability for a role
When you shop with us online you have the option to checkout without creating an online account. The information you provide when you purchase products using the guest checkout, including your name, address and contact details, will be used for the purpose of fulfilling your order and to keep you informed on the status of your order. We will also use your information along with your order information for analytical purposes to help us improve our products, services and shopping experience. We keep personal data given to us when you use the guest checkout option for 6 years. This is in order to respond to any queries or complaints that you may have relating to your order. After this time we will anonymise your personal data, except where you have consented to receive marketing from us.
Automated decision-making and profiling
When you make purchases using your Bonus Club card or account, browse our website, respond to marketing communications or join and make purchases using Bonus Club, we will use data we collect from you to analyse and profile the way you shop with us. We use software and automated processing technology to carry out the analysis and profiling. For example, when we select customers to send our mailings and emails to we will use automated decision-making and profiling to ensure we send targeted and relevant communications.
Additionally, we use the data to understand our customer base more fully. We look at attributes such as spend, length of time as a customer, age, frequency and recency of purchases amongst others. It will also be used to help us develop and create products and services for you in the future.
The results of this analysis, together with other demographic data, allows us to ensure that we contact you about products, services and promotional offers that are personalised and tailored to you where you have given us permission to send you such promotional offers.
It may also be used to protect you by detecting and preventing fraud, for example when you shop online, we limit the number of orders you are able to place in a week to ensure that your account or payment details are not being used fraudulently.
Marketing & market research
We or third parties may contact you, where you have given us consent, to participate in market research. We carry out market research to understand your experiences and improve the products and services we offer to you.
Basis for using your information
1. Necessary for the entry into or performance of a contract
When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (for example, where you buy products from us online, via our contact centre, or when you place an order in-store), we will need to collect, process and share (as further detailed below) your personal data. Failure to provide the requisite personal data when placing your order and payment information (where appropriate) on entering into the transaction or objecting to this type of processing or exercising your deletion rights will unfortunately mean we cannot provide our products to you in a number of circumstances (for example, where you buy products from us online, via our contact centre, or when you place an order in-store).
2. Legitimate business interests
- Provide you with the products that you buy from us or the information that you request;
- Carry out research and analysis to understand our customers and how they use our products;
- Develop and improve our services to you and to our other customers;
- To send you marketing communications when you join Bonus club.
As indicated below, we may also pass your personal data to members of our group and other third parties and this is also necessary for our legitimate business interests. We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.
|Legitimate Interest||We have a legitimate interest in processing your information as:
|Impact of processing||We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.|
We may, on occasion, send you marketing messages by email, SMS and post about us and our events and offers where you have not unsubscribed and where you have purchased similar products from us, or where you have otherwise consented. In addition, where you have consented we may share your information with third parties to allow to you claim your prize where you have won a competition. Where you have consented we, or our third-party partners, may contact you in relation to customer satisfaction surveys.
You have the right to withdraw your consent to processing of this nature, including receiving marketing material from us, at any time by contacting us in the following ways:
- Click the "unsubscribe" link on any marketing email that you receive from us;
- Email email@example.com;
- Call Customer Services on 0330 026 2728;
- Write to Bonmarché, Jubilee Way, Grange Moor, Wakefield, WF4 4SJ;
- Go into “My Account” and updating your communication preferences;
- Go into any UK Bonmarché Store.
Providing your personal data to others
Your personal information may be disclosed to third parties who assist us in processing your order, providing you with products and services, and who provide us with other services such as legal advice. We require all such third parties to treat your personal information as confidential and to comply with all applicable Data Protection Laws.
We also share your personal data with third parties for the following purposes:
- Where you win a competition, it may be necessary for us to provide your personal data to third party companies so that you can claim your prize. However, we will always ask for your consent prior to sharing your personal data with such third parties;
- To allow you to pay with credit/debit cards by passing credit/debit card details to the bank for authorisation;
- To provide you with and manage an online gift card service and to allow you to pay via gift card;
- To host, deliver and personalise the website to you;
- For collation of your name and email when you have completed the customer service survey;
- To manage the main till hub so Bonmarché can identify you as an existing Bonus Club Customer and provide you with the Bonus Club Loyalty scheme points engine (Spend and Save);
- To store and create reports based on your data, marketing preferences and your transactions and behaviour in-store, online and over the phone. This enables us to continually monitor and improve our products, services and online user experience;
- To analyse and profile your information to tailor communications and offers that we send to you and improve our products, services and customer shopping experience;
- To store and manage your information in order for us to provide the Customer Loyalty Scheme (Bonus Club);
- To keep our database up to date to ensure that we don't send marketing mailings to deceased customers and those who have moved address;
- To manage your orders, queries, complaints and fulfilment of orders;
- To update your information with your latest address details;
- To deliver communications through the post, by email and SMS;
- To print your information, such as your name and address, on communications we send to you through the post;
- To sort and group you together with other customers based on where you live. This is used when we are sending communications through the post to a lot of our customers at the same time. By grouping our customers together, we can send out your letters more quickly and efficiently;
- To contact you to ask for feedback on products, services and communications;
- To contact you by phone to invite you to events, such as fashion shows;
- To provide you with a telephone ordering service and query answering;
- To amend your Bonus Club details, marketing preferences and deal with lost and stolen customer card enquiries;
- To send promotional and service emails to you;
- To provide you with and manage our refer-a-friend programme, to monitor the programme and safeguard against gaming or fraudulent use and to communicate with you in connection with the operation of the programme and to deliver your rewards.
You should be aware that if we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal Information and /or user information, we may be required to do so even if you do not consent.
International transfer of your personal data
Please be aware some personal information (including cookies) may be processed and stored in a country outside the European Economic Area ("EEA"), which may be a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. In such instances, we will ensure that your personal information is treated securely and in accordance with this policy.
The countries outside of the EEA that we may transfer your personal information to include the USA where we use the following service providers: BounceX, MentionMe, Surveymonkey.
The USA is not a country that the European Commission has deemed to have adequate security in place. We have therefore incorporated the European Commission approved clauses into our agreements with BounceX, Mention Me and Survey Monkey to ensure the security of your personal data. A copy of the European Commission approved model clauses is available here.
What rights do you have?
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. Details on how to contact us to exercise any of these rights are below.
In some instances, we may be unable to carry out your request, in which case we will write to you to explain why.
|1. You have the right to request access to your personal data||You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.|
|2. You have the right to ask us to rectify your personal data||You have the right to request that we rectify your personal data if it is not accurate or not complete.|
|3. You have the right to ask us to erase your personal data||You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide products and services to you, where you withdraw your consent for us to process your personal data for marketing and market research purposes, or where you object to the way we process your personal data (see right 6 below).|
|4. You have the right to ask us to restrict or block the processing of your personal data||You have the right to ask us to restrict or block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don’t need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims.|
|5. You have the right to port your personal data||You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.|
|6. You have the right to object to our processing of your personal data||You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.|
|7. You have the right not to be subject to automated decisions||You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.|
|8. You have the right to withdraw your consent||You have the right to withdraw your consent where we are relying on it to use your personal data (for example, where we are sending marketing to you).|
You can exercise any of your rights above by writing to the Data Protection Lead, Bonmarché, Jubilee Way, Grange Moor, Wakefield, WF4 4SJ or email DPO@bonmarche.co.uk or call 0330 026 2728 and select option 3.
Alternatively, if you would like to change your personal details, you can contact us in the following ways:
- Email firstname.lastname@example.org;
- Call Customer Services on 0330 026 2728;
- Write to Bonmarché, Jubilee Way, Grange Moor, Wakefield, WF4 4SJ;
- Go into “My Account” and updating your communication preferences;
- Go into any UK Bonmarché Store.
If you are not satisfied with the way we have handled your information in the first instance, please contact our Data Protection Lead on DPO@bonmarche.co.uk or call 0330 026 2728 and select option 3.
You also have the right to lodge a complaint with the Information Commissioner's Office by calling the helpline on 0303 123 1113, writing to them at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or visiting www.ico.org.uk
Retaining and deleting personal data
Typically, we will keep your personal data for 6 years from the closure of your account with us or from your last purchase to enable us to deal with any issues or concerns you may have about how we handled your account, and also to allow us to bring or defend legal proceedings.
We will restrict processing of your data and anonymise certain personally identifiable information in the following circumstances;
- When you haven’t shopped with us in the last 3 years;
- When you haven’t shopped with us in the last 3 years and you joined Bonus Club more than 3 years ago;
- When you haven’t opened an email from us in the last 12 months.
In some circumstances, we may retain your personal data for longer periods but in an anonymised form. This means we would delete any information which identifies you personally. We may also retain personal data where such retention is necessary for compliance with a legal or regulatory obligation to which we are subject.
We implement a variety of security measures to maintain the safety of your personal information. We use the latest in Secure Server Technology to ensure that all your personal and transactional information is protected to the highest standards. Users personal information is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. All sensitive information supplied by users is transmitted via Secure Socket Layer (SSL) technology. When you elect to store your card details, your full card number is not visible to us. It is masked and used only to complete the transaction.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features outlined above to try to prevent unauthorised access.
Our website may, from time to time, contain links to and from the websites of third parties. 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 or your use of those websites.
What is a cookie?
Cookies are small files of letters and numbers, which are downloaded to your computer or mobile or other electronic device when you access a website. Cookies recognise your device and help you to navigate through the website by allowing you to log in automatically or remembering settings you selected during earlier visits (among other functions). Cookies contain information that is transferred to your computer's hard drive.
Cookies and how they benefit You
Cookies help us to provide you with a good experience when you browse the Bonmarché website and allow you to make full use of the online shopping and personalised features.
- Make our website work as you'd expect
- Improve user experience (make our website better for you to use)
- Save you having to login every time you visit the site
- Remember your settings during and between visits
- Improve the speed/security of the site
- Make sure any advertising shown is relevant to you
- Remember the choices you make such as language or country settings
- Allow you to share pages with social networks like Facebook
- Continuously improve our website for you
- Make our marketing more efficient
- Collect any personally identifiable information (without your express permission); or
- Collect any sensitive information (without your express permission)
We use the following cookies:
1. Strictly Necessary Cookies (Essential Cookies)
These are cookies that are required for the operation of our website. They include, for example, cookies that:
- Make our shopping basket and checkout work
- Determine if you are logged in or not
- Enable you to log into secure areas of our site or make purchases
We do not require your consent to place these cookies. Nevertheless, you may be able to block these cookies yourself on your device/ browser, but restricting these cookies is likely to mean that our site will not work as you would expect and certain functionality may be inoperable.
2. Social Website Cookies
We use social media cookies so you can easily like or share our content on social media websites such as Facebook, Twitter, Pinterest, Instagram and YouTube using the sharing buttons on our site. These third-party providers are responsible for the cookies they set on our websites. The privacy implications vary from social media site to social media site and will be dependent on the privacy settings you have chosen on these websites. If you want further information please go to the website for the relevant third party. You will find additional information in the table below.
3. Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and searches (for example, your choice of language or region).
4. Site Improvement Cookies
We regularly test new designs or site features on our website. We do this by showing slightly different versions of our website to different people and anonymously monitoring how our site visitors respond to these different versions. Ultimately this helps us to offer you a better website.
5. Visitor Statistics Cookies
6. Advertising Cookies
Cookies are widely used in online advertising. These cookies record your visit to our website, the pages you have visited and the links you have followed. This information will be used by us and third parties to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose but only if you consent to such sharing.
You can learn more about online advertising at www.youronlinechoices.com You can opt-out of almost all advertising cookies at www.youronlinechoices.com/uk/your-ad-choices. It is worth noting that opting out of advertising cookies will not mean you won't see adverts, just that they won't be tailored to you any longer.
7. Remarketing Cookies
You may notice that sometimes after visiting a website you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves pay for these adverts.
The technology to do this is made possible by cookies and as such we may place a so-called remarketing cookie during your visit. We use these adverts to offer special offers etc to encourage you to come back to our website. Don't worry; we are unable to proactively reach out to you as the whole process is entirely anonymous. You can opt out of these cookies at any time as explained above and below.
8. Affiliate Cookies
We have a number of partners who promote our products and services. Cookies are required to allow us to reward these partners and these cookies are usually provided by specialist companies (known as affiliate networks).
9. Banner Advertising
This type of advertising is designed to provide you with a selection of products based on what you're viewing on our website, which are presented to you when you visit other selected websites. The adverts may highlight alternative styles and colours of the same products that you had previously viewed, as well as products from other categories deemed relevant to your browsing history. The technology behind these adverts is based on cookies.
Turning Cookies Off
You can choose not to allow cookies in your browser settings. How you do this will depend upon the browser you are using. More information on cookies, their use and how to accept or reject them can be found at www.allaboutcookies.org and the Information Commissioner's Office website at ico.org.uk/for-the-public/online/cookies/.
To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout.
As our cookies are largely aimed at improving the user experience on the website, you may find that if you block certain cookies you may experience deterioration in the service you receive.