Privacy Policy

Updated May 2018

John Smedley Limited ("we" or "us") are committed to protecting and respecting your privacy.

This policy (together with our Terms and Conditions of Sale and Cookies Policy and any other documents referred to on our website) aims to give you information on how we collect and process your personal data through your use of www.johnsmedleyoutlet.com, including any data you may provide through this website when you purchase a product or service. Please also use the Glossary to understand the meaning of some of the terms used in this policy.

For the purpose of the General Data Protection Regulation 2016 (“GDPR”), the data controller is John Smedley Limited, company number 40000 of Lea Mills, Matlock, Derbyshire, DE4 5AG.

You are not required to provide the personal information that we request, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Information we may collect from you

Information collected directly from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where their identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

We do not collect any Special Categories of Personal Data about you (this includes details of your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including:

Direct interactions

You may give us your Identity, Contact and Financial Data before you are redirected to our partners Sagepay, Elavon or Paypal, by filling in forms, or by corresponding with us by post, phone, email or through our Contact Area. This includes personal data you provide when you:
• register to use our website;
• search for goods;
place an order on our website;
participate in discussion boards or other social media functions on our website (including on our blog);
enter a competition, promotion or survey; and
• when you report a problem with our website.

Information collected automatically

We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

At John Smedley we use this information to understand and analyse trends, to administer our website, to learn about user behaviour on our website, to improve our product and services, and to gather demographic information about our user base as a whole.

Information collected via Third Parties

We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
- Google
- Affiliate Window
- Ometria
• Identity and Contact Data from data brokers or aggregators such as:
- Who's On

Cookies


By visiting the John Smedley Outlet website (www.johnsmedleyoutlet.com) and using the available features, we understand that you are agreeing to the technology which is required to support such services. In addition we ask all our customers to accept our Privacy Policy before the contract of sale is formed at the checkout.

What are Cookies?

A cookie is a small file stored on your computer by a web site to give you a unique ID. Cookies help make it easier and faster for you to use our site at www.johnsmedley.com (“Website”) because it can remember if you've visited the Website, and they help us provide you with the information you need about your shopping activity or account details - when and where you need it.

A cookie generated by our Website [contains no information about you]. It contains only a numeric ID that, for example, allows you to retrieve your account details or shopping list.

In keeping with our Privacy Policy on customer information, we analyse data gathered via cookies only in aggregate, not at the individual customer level.

John Smedley uses cookies in order to create an enjoyable and easy online shopping experience for you. By using our Website, you are agreeing that we can house cookies on your device.

Types of Cookies we use

There are three types of cookie that may be used during your visit to our Website:
Session Cookies
These cookies are used to identify users between page loads. This allows our Website to remember certain settings, like which products a user has added to the basket. Session cookies are deleted when you close your browser. Without session cookies, the site would forget which items you placed in your shopping bag and you wouldn't be able to buy anything.

Persistent Cookies
Persistent cookies remember your preferences and behaviour and help us to personalise your shopping. So, if the last time you visited, you decided that you wanted to shop the UK site in English and see prices in £s, that's what we'll show you. Persistent cookies remain on your browser until they expire automatically after a set time period, unless you delete them yourself.

Third Party Cookies
John Smedley partners with third party companies for marketing and advertising purposes. These cookies allow us to make more informed decisions about what our customers want from us. Third party companies may employ a mixture of both session and persistent cookies. [Any information that they collect is anonymous.]

Third Parties we work with and why

Google Analytics™
use cookies which enable John Smedley to recognise your browser and collect data based on user activity on our Website. This includes information such as the number of visits to the Website, the quantity of orders placed and number of pages visited. This data helps us make improvements to our site in order to provide you with a better service. These cookies are used to collect analytical information about how visitors use the Website. All information is collected in an anonymous form.

Affiliate Window™
use cookies to anonymously record that a user has clicked on an affiliate link that referred the user to our Website. This information is collected in order to enable us to pay a commission to Affiliate Window and its affiliates for any sales they may drive on our site. Affiliate Window cookies remain active for a period of 30 days.

Who’s On™
use cookies to enable our live chat facility to operate and remember your previous chat history.

Facebook and Twitter

these cookies are required to enable our customers to share their shopping experiences through social media such as Facebook and Twitter etc. Please note that if you do choose to share through these social media providers that we don't control the setting of these cookies and we recommend that you check the provider's website for further information.

Can I delete or control my Cookies?

You can, if you prefer, set up your internet browser to not accept cookies. You should still be able to use our site without having cookies enabled.
Further information about controlling or deleting cookies visit https://ico.org.uk/for-the-public/online/cookies/
If you have any queries concerning your personal information or any questions on our use of the information, please contact [email protected] or
Online Customer Care Team
John SmedleyOutlet
Lea Mills
Matlock
Derbyshire
DE4 5AG

Alternatively, you can telephone our customer care team on 0800 6523498 (international no. +44 (0)800 6523498 – English speaking support only).

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

How we use your personal information

We use your information in several different ways. The table below sets this out in detail, showing what we do, and why we do it.

Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of purpose

We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted by law.

Disclosure of your information

Service Providers

In order to make certain services available to you, we may need to share your personal data with members of our group and some of our service partners including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter with them in relation to processing or delivering your goods.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.

Other Third Parties

Aside from our service providers, John Smedley will not disclose your personal data to any third party, except as set out below and we will never sell or rent your data to other organisations for marketing purposes. We may, however, share your data with:
• Credit reference agencies, where necessary for card payments.
• Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers:
- where we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
- in order to enforce or apply our terms of website use or terms and conditions of sale and other agreements;
- to protect the rights, property, or safety of John Smedley, our customers, or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and processing payment through the Sage Pay/ PayPal system); or
- where we are required to do so to comply with our legal obligations, to exercise our legal rights (for example in court cases), for the prevention, detection, investigation of crime or prosecution of offenders; and for the protection of our employees and customers.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

How we protect your data

John Smedley is committed to keeping your personal data safe and secure.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

All information you provide to us is stored on our secure servers. John Smedley payment pages are held on Sage Pay™ secure servers, unless shopping through our Chinese store with payment pages being held on PayPal™ secure servers. Both Sage Pay™ and PayPal™ are popular and established internet payment gateways. Any payment transactions will be encrypted using SSL technology. Sage Pay™ and PayPal™ employ encryption and firewalling techniques to provide the maximum security against fraud and hackers. For more information about Sage Pay™ or PayPal™ products or systems, please visit www.sagepay.co.uk or www.paypal.co.uk.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You can help us to protect your personal information by adhering to the following security measures:
• Do not confirm your bank or credit card details in an email. We will not ask for such personal information in this way, so any email claiming to be from us that does so is likely to be fake. Please ignore it
• Keep your passwords private
• When creating a password, do not use words such as your name, date of birth or other personal data
• Change your password regularly
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 site; any transmission is at your own risk.

Data Retention

We will not retain your data for longer than necessary for the purposes set out in this policy unless a longer retention period is required or permitted by law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Links to other Websites

Our website may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks).

We have no control over how third party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third party websites and services or their privacy practices. Please read the privacy statements of any third party websites or services that you access from our websites or services.

Your rights

Under certain circumstances you have rights under data protection laws in relation to your personal data. In summary, those include rights to:
• be informed about your personal information is being used;
• access the personal information we hold about you;
• request that we transfer elements of your data to another service provider;
• request us to correct any mistakes in your information which we hold. You can help ensure that your contact information and communication preferences are accurate, complete, and up to date by logging in to your account at: https://www.johnsmedley.com/uk/customer/account/login/;
• request the erasure of personal information concerning you in certain situations;
• receive personal information concerning you which you have provided to us, in a structured format;
• stop any direct marketing; and
• object to processing of your data.
For further information on each of these rights, including the circumstances in which they apply, see the ICO’s guidance available at www.ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to exercise any of these rights, please contact [email protected].

Children

This website is not intended for children and we do not knowingly collect data relating to children.

Changes

We may make changes to our privacy policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. This version was last updated on 25 May 2018 and historic versions can be obtained by contacting us.

Contact

Our full details are:
Full name of legal entity: John Smedley Limited, a private limited company with company number 40000 of Lea Mills, Matlock, Derbyshire, DE4 5AG
Name or title of data privacy manager: Data Protection Lead
Email address: [email protected]
Telephone number: 01629 534 424
Postal address: Online Customer Care Team, John Smedley Limited, Lea Mills, Matlock, Derbyshire, DE4 5AG
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected], or:
Online Customer Care Team,
John Smedley Limited,
Lea Mills, Matlock
Derbyshire,
DE4 5AG
Alternatively, you can telephone our customer care team on 0800 6523498 (international no. +44 (0)800 6523498 – English speaking support only).

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

John Smedley Limited
VAT registered GB 125 6154 85