Fineline Flooring Ltd – Privacy Notice

Contents

1. Introduction
2. Who are we?
3. Explaining the legal basis we rely on
4. When do we collect your personal data?
5. What sort of personal data do we collect?
6. How and why do we use your personal data?
7. Combining your data for personalised direct marketing
8. How we protect your personal data
9. How long will we keep your personal data?
10. Who do we share your personal data with?
11. Where your personal data may be processed
12. Web
13. What are your rights with regards to your personal data?
14. Your right to withdraw consent for the use of your personal data
15. Contacting the Regulator
16. Contacting Us
17. Introduction

At Fineline Flooring we are dedicated to safeguarding and preserving your privacy when visiting our site www.finelineflooring.co.uk/ or communicating with us. This Privacy Notice, together with our Terms and Conditions, provides an explanation as to what happens to any personal data that you provide to us, or that we may collect about you indirectly.

Any changes we make to our Privacy Notice 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 it. It was last updated on 3^{rd December 2018.}

When you are using the Fineline Flooring website, Fineline Flooring is the Data Controller.

2. Who are we?

Fineline Flooring Ltd (referred to in this Notice as “Fineline”, “we”, “our”, “us”) is registered in England at Unit 1C, Lodge Farm, Hook Road, North Warnborough, Hook, Hampshire, RG29 1HA (Registered number: 7164508).

3. Explaining the legal basis 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:

Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box 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.

Contractual obligations
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 and telephone details to deliver your purchase, and pass them to our delivery partner.
For example, if you use our recommended fitting service, we’ll collect your address and telephone details and pass them to the fitting team to enable them to complete the fitting service.

Legitimate interest
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 address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

4. When do we collect your personal data?

• When you visit our website and make an online purchase of products and services.
• When you create an account with us.
• When you purchase a product or service in store or by phone.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you ask one of our colleagues to email you information about a product or service.
• When you enter prize draws or competitions.
• When you order a product sample on the website.
• When you book any kind of appointment for a Home Flooring Surveyor or use our recommended fitting service.
• 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 the colleague 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 colleague may collect your personal data.
• When you’ve given a third party permission to share with us the information they hold about you.
• When Finance providers – share information with us about the product you have purchased. We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.

5. What sort of personal data do we collect?

• If you have a web account with us: your name, billing/delivery address, orders and receipts, email, mobile phone number and landline telephone number. For your security, we’ll also keep an encrypted record of your login password.
• Details and recordings of your interactions with us by telephone, in addition to details of your interactions, in store or online. This includes email, mobile number and landline telephone number.

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, and wish list choices, brands you show interest in, web pages you visit and how and when you contact us.

• Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
• Details of your shopping preferences.

For example, whether you prefer to shop online, over the telephone or in store.

• Details of your visits to our website and which site you came from to ours.

Information gathered by the use of cookies in your web browser. Learn more about how we use cookies in section 12. Of this policy.

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.

• Your comments and service and product reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection, IP address and browser, as well as the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

6. 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 most complete 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.

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 on promotion, we can’t do that if you’ve withdrawn your general consent to hear from us.

We will only use your information for the purpose or purposes it was collected for (or else for closely related purposes).

The information that we collect and store relating to you is primarily used for administrative purposes (like internal record keeping) and to enable us to provide our services to you and to verify your identity.

In addition, we may use the information for the following purposes:

• To process any orders that you make by using our website. 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.

• To respond to your queries, refund requests and complaints. Handling the information you sent 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.

For example, by checking your password when you login and using automated monitoring of IP addresses for fraud prevention.

• 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 fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim 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 or 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 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 display the most interesting content to you on our website, we’ll use data we hold about your favourite products and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device.

For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

• 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.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.

• 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 from across the Group, third parties and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ 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.

• To process your booking/appointment requests for a Home Flooring Surveyor. Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or a fitter visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.

7. Combining your data for personalised direct marketing

• We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Group. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Experian.
• Please be advised that we occasionally provide our Advertisers with aggregate statistical information about our website visitors, however this does not reveal information about identifiable individuals.

8. How we protect your personal data

• We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
• All personal data collected by the Group is encrypted and stored on a secure server. The Group secure access to all transactional areas of our websites using latest EV SSL (Extended Validation Secure Sockets Layer) ‘https’ technology.
• All transactions are subject to real time cardholder authentication with the card issuing bank, using 3D Secure technology provided by Verified by Visa and MasterCard SecureCode. This password protected identity check prevents your credit / debit card details from fraud.
• Whilst we will take all reasonable steps to make sure that your data is treated securely and in agreement with this Privacy Notice, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is therefore entirely at your own risk.
• Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential.

9. How long will we keep your personal data?

Storing Your Information

The periods for which we keep your information depend on the purpose for which your information was collected and the use to which it is put. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements. For example:

• Data relating to product orders are kept for 7 years to comply with our legal and regulatory obligations.
• We will keep your contact information for 10 years after you have purchased our products or services in case you decide to use our services again.
• We will keep details of the address, room measurements and the products we have sold for those rooms indefinitely, without your name associated with it. This is to enable improved service to customers who may wish to purchase floorcoverings in the future at the same address.

10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, delivery couriers, fitters visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Operational companies such as delivery couriers, suppliers of materials who will deliver directly to you, contractors that will fit or install the materials at your address.
• Secure payment providers who support our payment processing operations.
• 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 in section 12. for details.
• Data insight companies to ensure your details are up to date and accurate.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

For example, if we run a joint event with a furniture store and you agree to receive direct communications from them.

• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
• To help personalise your journey through the Groups’ website we currently use a variety of companies, who will process your personal data as part of their contracts with us. These include:
  • Google, DoubleClick
  • Google Analytics
  • Google Tag Manager
  • GA Audiences
  • Trust Pilot
  • Facebook Custom Audience
  • Facebook Connect Magento
  • Qubit
  • Session Cam
  • Postcode Anywhere
  • Dotmailer
  • Twitter
  • Instagram
  • Google+
  • Pinterest
  • YouTube

11. Where your personal data may be processed

Transferring Your Information Outside of Europe

We may transfer data that we collect from you to locations outside of the European Economic Area (EEA) for processing and storing. Also, it may be processed by staff operating outside the EEA who work for us or for one of our suppliers. For example, such staff maybe engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. Where we transfer your information outside of the EEA we will ensure safeguards are in place to ensure it remains secure and adequately protected.

Third Party Websites

You might find links on our website to third party websites. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

12. Our Website and Cookies

Cookies are very small text files, which are stored on your computer when you visit certain web pages. We use cookies to keep track of what you have in your basket, and to remember you when you return to our website. It’s important to understand that cookies can’t harm your computer. We don’t store personally identifiable information such as credit card details in the cookies we create, but we do use encrypted information gathered from them to help improve your experience of the site. For example, they help us to identify and resolve errors and to determine relevant related products to show you when you’re browsing. To order products on FineLine Flooring, you need to have cookies enabled. If you don’t wish to enable cookies, you’ll still be able to browse the site and use it for research purposes. Most web browsers have cookies enabled, but see

Managing cookies for further help to turn them on or off should you need to. We’re giving you this information as part of our initiative to comply with recent legislation, and to make sure we’re honest and clear about your privacy when using our website. We’re working on a number of other privacy and cookie-related improvements to the website.

Cookie Policy

To make full use of the online shopping and personalised features on FineLine Flooring, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain personalised features of this website by using them. Our cookies don’t store sensitive information such as your name, address or payment details: they simply hold the ‘key’ that, once you’re signed in, is associated with this information. However, if you’d prefer to restrict, block or delete cookies from FineLine Flooring, or any other website, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

Google Analytics

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These cookies enable Google Analytics software. These cookies helps us measure and analyse visitor information such as browser usage and new visitor numbers. This information helps us to improve our website performance, personalise your shopping experience and make our marketing campaigns more relevant. The data stored by these cookies never shows personal details from which your individual identity can be established.

Qubit

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These cookies enable Qubit software. These cookies helps us measure and analyse visitor information such as browser usage and new visitor numbers. This information helps us to improve the website performance. personalise your shopping experience and make our marketing campaigns more relevant. The data stored by these cookies never shows personal details from which your individual identity can be established.

Cookies used by Fineline Flooring

frontend

This cookie stores any activity that the user has when interacting with items and the basket (i.e. adding an item or increasing its count) and with the check-out process (i.e. entering shipping address).

YouTube

We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit http://support.google.com/youtube/bin/answer.py?hl=en-GB&answer=171780

Sharing Tools

If you take the opportunity to ‘share’ finelineflooring.co.uk content with friends through social networks – such as Facebook and Twitter – you may be sent cookies from these websites. We don’t control the setting of these cookies, so please check the third-party websites for more information about their cookies and how to manage them.

Managing Cookies

If cookies aren’t enabled on your computer, it will mean that your shopping experience on our website will be limited to browsing and researching; you won’t be able to compare products, order samples, add products to your basket and buy them.

To enable cookies

If you’re not sure of the type and version of web browser you use to access the Internet:

• For PCs: click on ‘Help’ at the top of your browser window and select the ‘About’ option
• For Macs: with the browser window open, click on the Apple menu and select the ‘About’ option

3rd Party Cookies

Some cookies may be set by third parties when you visit this website. These third parties may be suppliers who partner with us to deliver our website, companies that participate with us in affiliate marketing programmes and other third parties. These cookies are controlled by the third parties, so please check the third-party websites for more information about these cookies and how to manage them. These third party cookies do not collect personal data from which the third party would be able to identify individual customers./p>

Some of our third party partners that may set cookies on this website include:

DoubleClick	Double Click uses cookies to help to make PPC advertising more effective. These help us to track clicks and conversions. This is part of Google’s conversion tag and more information on how the cookie operates and how you can manage these cookies is available here.
Facebook	Facebook use Cookies and similar technologies to show you ads on and off Facebook Services. Facebook work with advertising companies to help advertisers show people ads based on other websites or apps those people have visited, among other factors.
Google	To help Google partners manage their advertising and websites, Google offer many products, including AdSense, AdWords, Google Analytics, and a range of DoubleClick-branded services. When you visit a page that uses one of these products, either on one of Google’s sites or one of our partners’, various cookies can get used. Google may use cookies for a number of purposes, such as to stop you from seeing the same ad over and over again, to detect and stop click fraud, and to show ads that are likely to be more relevant (such as ads based on websites you have visited).
Twitter/X	To help Twitter deliver ads, measure their performance, and make them more relevant to you based on criteria like your activity on Twitter and visits to our ad partners’ websites.

12. What are your rights with regards to your personal data?

An overview of your different rights

You have the right to request:

• Access to the personal data we hold about you.
• The correction of your personal data when incorrect, out of date or incomplete.
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review by a colleague of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that the Group holds.

Please put your request to access your information in writing to the Data Protection Officer at the address given below. It is helpful if you explain what particular records you are seeking, but you do not have to say. You will need to provide two forms of identification (current passport (the page with your personal details); driving licence; birth certificate; utility bill from last 3 months; current vehicle registration document; bank statement from last 3 months; rent book from last 3 months) We don’t store this identification and it will be securely disposed of. It’s used solely to verify the requesters identity.

If you would like further information about your rights or wish to exercise them, please write to our Data Protection Officer sales@finelineflooring.co.uk If we are unable to fulfil your request for any reason, we will provide you with a reason as to why.

13. Your right to withdraw consent for the use of your personal data

n certain circumstances you can ask for the data we hold about you to be erased from our records or transferred to another organisation. Where certain conditions apply, you have a right to ask us to restrict the processing of your personal information. You also have the right to object to certain types of processing such as direct marketing, automated processing or profiling.

If you would like further information about your rights or wish to exercise them, please write to our Data Protection Officer sales@finelineflooring.co.uk If we are unable to fulfil your request for any reason, we will provide you with a reason as to why.

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.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. (see above) If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

If we choose not to action your request we will explain to you the reasons for our refusal.

14. Contacting the Regulator

If you are not happy with the way we have handled your data, and are unable to resolve the issue with us personally, you have the right to lodge a complaint with the:

Information Commissioner’s Office, the UK’s independent authority for privacy matters.

15. Contacting Us

We welcome any queries, comments or requests you may have regarding this Privacy Notice, please feel free to contact us.