Privacy Policy

 Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here but we want you to be fully informed about your rights, and how the smartmovez  Partnership uses your data.

For example, we will explain things such as our credit checking procedure and how we combine data across the smartmovez  Partnership to build a picture of you. 

We hope the following sections will answer any questions you have but if not, please do get in touch with us. 

We’ll likely need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.

When you are using the smartmovez  websites, smartmovez  Plc is the data controller.

Smartmovez  is a UK based company and therefore, when visiting our website, personal data that we may collect through cookies or online forms will leave the EU for the UK.

Explaining the legal bases we rely on

The law on data protection sets out several different reasons for which a company may collect and process your data, including: 

Consent

In specific situations, we can collect and process your data with your consent.

When collecting your data, we’ll always make clear to you which data is necessary for connection with a particular service.

Contractual obligations

In certain circumstances, we need your data to comply with our contractual obligations.

Legal compliance

If the law requires us to, we may need to collect and process your data.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

When do we collect your data?

Ø  When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the Partnership on the phone, in a shop or online.

Ø  When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).

Ø  When you create an account with us.

Ø  When you purchase a product or service in-store or by phone but don’t have (or don’t use) an account.

Ø  When you engage with us on social media.

Ø  When you download or install one of our apps.

Ø  When you join a Partnership loyalty programme (e.g. my smartmovez or myWaitrose).

Ø  When you purchase Foreign Currency from us we'll collect personal information, such as your name, address and proof of identity.

Ø  When you sign up to my smartmovez  you will be given access to an area called Kitchen Drawer. This will collect and store all of your receipts, guarantees and warranties for you when you purchase smartmovez

Ø  When you contact us by any means with queries, complaints etc.

Ø  When you ask one of our Partners to email you information about a product or service.

Ø  When you enter prize draws or competitions.

Ø  When you book any kind of appointment with us or book to attend an event, for example, a class at Waitrose Cookery School.

Ø  When you choose to complete any surveys we send you.

Ø  When you comment on or review our products and services. Any individual may access personal data related to them, including opinions. So if your

Ø  comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.

Ø  When you fill in any forms. For example, if an accident happens in-store, a Partner may collect your data.

Ø  When you’ve given a third-party permission to share with us the information they hold about you.

Ø  When our smartmovez  Finance suppliers and partners – e.g. HSBC or RSA – share information with us about the product you have purchased.

Ø  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.

Ø  When you use our car parks and shops which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.

What sort of personal data do we collect?

If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.

Details of your interactions with us through contact centres, in-store, online or by using one of our apps.

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.

Details of your visits to our websites or apps, 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 and similar technologies.

Personal details help us to recommend items of interest.

We’ll only ask for and use your 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.

Payment card information.

Ø  Your comments and product reviews.

Ø  Your image may be recorded on CCTV when you visit a shop or car park.

Ø  Your car number plate may be recorded at some of our car parks to manage parking restrictions.

Ø  To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.

Ø  Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How and why do we use your 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 data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your data and why:

To process any orders that you make by using our websites, apps or in-store. If we don’t collect your data during checkout, we won’t be able to process your order and comply with our legal obligations.

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 based on 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 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 Partners from crime, we operate CCTV systems in our stores and car parks which record images for security. We do this based on our legitimate business interests. 

To process payments and to prevent fraudulent transactions. We do this based on 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 to prevent or detect unlawful acts. We aim to protect the individuals we interact with from criminal activities. 

With your consent, we will use your data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK.

 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 about updates, offers, services and products. We’ll do this based on 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 data for these purposes, we would be unable to comply with our legal obligations.

To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so based on your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.

 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 based on our legitimate business interests.

To comply with our contractual or legal obligations to share data with law enforcement.

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.

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 Partnership, 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 based on our legitimate business interest.

For my smartmovez members, to decide which information to show you, with the help of computer algorithms. We do so based on your consent when you become my smartmovez  member. If you don’t want to continue receiving my smartmovez offers, you’ll be unable to continue your smartmovez membership.

To process your booking/appointment requests (such as with a personal stylist).

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 data, we’d be unable to fulfil your request.

For myWaitrose cardholders: to provide you with tailored offers, printed with your till receipt at the end of a shopping trip. These are based on an analysis of previous purchases using your myWaitrose card, including the items you’ve just bought. We do this based on our legitimate interest to show you relevant offers. Of course, you’re free to choose whether to take advantage of them.

To ensure that all of your purchases are correctly assigned to you we track your payment card token id, this is an id given to your debit or credit card by the banking industry we do this whether you have logged into your account or check out as a guest. We do this for several reasons and based on our legitimate interest for example:

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 data gathered across the Partnership as described above, for example, your shopping history at both smartmovez  and Waitrose. 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 Land Registry mentioned above.

How we protect your 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. 

We secure access to all transactional areas of our websites and apps using ‘HTTPS technology.

Access to your data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. 

How long will we keep your data?

Whenever we collect or process your 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.

Who do we share your data with?

 We sometimes share your data with trusted third parties.

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.

Sharing your data with third parties for their purposes:

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

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

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 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 consider the privacy of our customers.

We may, from time to time, expand, reduce or sell the Partnership and this may involve the transfer of divisions or the whole business to new owners. If this happens, your data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

 For further information please contact our Data Protection Officer.

Where your data may be processed

The Partnership is a UK based company and so we will transfer your data to the UK, which is outside of the EU. We may also need to share your data with third parties and suppliers outside the European Economic Area (EEA)

Protecting your data outside the UK

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.

Any transfer of your data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

What are your rights over your data?

An overview of your different rights

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.

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

The deletion of the data we hold about you, in specific circumstances. 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 (e.g. the end of a warranty).

A computer file in a common format (e.g. CSV or similar) containing the personal data that you have previously provided to us and the right to have your information transferred to another entity where this is technically possible.

Restriction of the use of your data, in specific circumstances, generally whilst we are deciding on an objection you have made.

That we stop processing your data, in specific circumstances. For example, when you have withdrawn consent, or object for reasons related to your circumstances.

That we stop using your data for direct marketing (either through specific channels, or all channels).

That we stop any consent-based processing of your data after you withdraw that consent.

Review by a Partner 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 can contact us to request to exercise these rights at any time by completing an online form.

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

Your right to withdraw consent

Whenever you have given us your consent to use your data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your data based on our legitimate interest, you can ask us to stop for reasons connected to your situation.

We must then do so unless we believe we have a legitimate overriding reason to continue processing your data.

Direct marketing

You have the right to stop the use of your 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.

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.

How can you stop the use of your data for direct marketing?

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.

If you have an account, log in to your smartmovez  or account, visit the ‘My Account’ area and change your preferences.

In our apps, you can manage your preferences and opt-out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.

Write to Group Customer Insight - Data Team Partnership House, 1st Floor, Carlisle Place, London SW1P 1BX.

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

smartmovez  Finance 

How we use your data

When you purchase a product or service from smartmovez Finance, we might receive a copy of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you.

You are free to opt-out of receiving marketing communications from us at any time. Find out more about the use of your data for marketing in section 7.

How our providers use your data

 When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their separate privacy policies.

 Outside the UK

 This Privacy Notice shall be provided in English, French, Spanish, Portuguese, Malay and Chinese languages. Should there be any conflict in the meanings between the English and translated version, the English version shall prevail.

When placing an order with the Partnership, browsing our website, including for analytics and website usage research, and/or agreeing to receive direct marketing electronic communications as described in this Privacy Notice and our Cookies Notice, your data will be processed by us or on our behalf. Of course, you still have the right to ask us not to process your data in these ways, and if you do so, we will respect your wishes.

Sometimes we will need to transfer your data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we will transfer your data to the UK and may also transfer your data to third parties located in the UK to your country of residence.

We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your data other than for the services they provide and for which they need the personal data and to adequately protect the confidentiality and privacy of your data.

We will ensure that any third parties only process your data following their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside. We do not actively take steps to ensure that any overseas recipient of your data complies with the laws which apply in your country.

 If you have any questions, please contact our Data Protection Officer, and we will respond within your local timeframe response requirements. To complain about an alleged breach of this Privacy Notice or our privacy obligations at law, please provide us with as much detail as possible about your complaint. We will take any privacy complaint seriously and any complaint will be assessed to resolve any issue in a timely and efficient manner. 

Australia 

For this Privacy Notice, “personal data” means any information or an opinion about an identified individual, or a reasonably identifiable individual, whether or not the information or opinion is true, or opinion is recorded in a material form.

We are committed to keeping your personal information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the

operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

We store personal information on computer databases and will take reasonable commercial physical and electronic security measures to protect any records that we hold which contains your personal information.

If you are in Australia, you may submit a complaint to our Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive you may submit a complaint to the Office of the Australian Information Commissioner.

USA

For information about our cookies and website ‘track’ or ‘do not track’ practices please refer to our Cookies Notice.

Canada

If you submit a request to stop direct marketing communications from us, it will take no longer than 10 days. 

As your data may be transferred to third parties outside the country where you are located, local police or other enforcement, regulatory or Government bodies may have access to that data with or without the Partnership’s knowledge. The personal data we process may be accessed by persons within the Partnership, or our third-party service providers, who require such access to carry out the purposes indicated in this Privacy Notice, or such other purposes as may be permitted or required by the applicable law. Personal data we collect is maintained primarily in the UK.

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 information, you have the right to complain with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.

 Hong Kong

Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data (Privacy) Ordinance (the “PDPO”

Under the Personal Data (Privacy) Ordinance (the “PDPO”), individuals must be notified at the point of collection of the purposes for which the data was collected and thereafter the data can only be used for those purposes unless consent is obtained for a new purpose.

If you are in Hong Kong you may submit a complaint to our Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive you may submit a complaint to the Office of the Privacy Commissioner for Personal Data. 

Malaysia

Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data Protection Act 2010 (“PDPA”).

If you are in Malaysia you may submit any questions, comments or complaints to our Data Protection Officer who will come back to you within 21 days. 

South Korea

The transfer of data to enable the company to supply the goods or services a customer have requested can be deemed as a Delegation.

EU AND EEA Countries

If you are sending us your personal data directly you do so within the sphere of your household or personal activity. If you want to purchase a smartmovez  product for your business please contact our [B2B service]. This privacy notice will apply to how any data you provide to us is processed.

 Any questions?

We hope this Privacy Notice has helped set out the way we handle your 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 support@ smartmovez.co.uk Our representative in the EU is MCF Legal Technology Solutions Limited, based in the Republic of Ireland, which you can contact at support@smartmovez.co.uk