Primo Tiles & Bathrooms Limited (PTB) (“Primo Tiles & Bathrooms Limited“) operates primotilesandbathrooms.co.uk and may operate other websites. It is Primo Tiles & Bathrooms Limited’s policy to respect your privacy regarding any information we may collect while operating our websites.
There are some changes in data protection law, so we wanted you to know that we’ve updated our Privacy Notice to comply with the GDPR (General Data Protection Regulation) laws.
Your trust is important to us, and we want to make sure you understand what these changes mean for you.
Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive our email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity.
In specific situations, we require your data to pursue our legitimate 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.
When do we collect your personal data?
When you visit any of our websites, and use your account to buy products and services, on the phone, in a shop or online.
When you make an online purchase and check out as a guest (we just collect transaction-based data).
When you create an account with us.
When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
When you engage with us on social media.
When you download help, advice or inspirations material from us (for example eBooks).
When you sign up, you will be given access to a My Account area on primotilesandbathrooms.co.uk. This will collect and store all of your order history, invoices and receipts for you when you make a purchase from Primo Tiles & Bathrooms Limited.
When you contact us by any means with queries, complaints, questions etc.
When you enter prize draws or competitions.
When you book any kind of appointment with us, for example a project consultation in store.
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 Partner 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 partner may collect your personal data.
When you’ve given a third party permission to share with us the information they hold about you.
We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.
When you use our car parks and stores which usually have CCTV systems operated for the security of both customers and employees. These systems may record your image during your visit.
What sort of personal data do we collect?
If you have an online account with us: your name, billing/delivery address, orders and invoices, 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 centre, in store or online. 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, voucher redemptions, web pages you visit and how and when you contact us.
Details of your visits to our websites, and which site you came from to ours.
Personal details which help us to recommend items of interest. For example, you might tell us your room colour preference which we’ll use to guide our suggested products. Or you might share information on your favourite interior trends which allows us to recommend appropriate products. 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.
Payment card information.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit our store or surrounding car park.
Your car number plate may be recorded at some of our car parks to manage parking restrictions.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
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 personal data?
We want to give you the best possible customer experience when shopping for tiles. 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 Trade 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.
If you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to recieve emails from us. Here’s how we’ll use your personal data and why:
To process any orders that you make by using our websites, over the phone or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, exchanges and/or guarantees. To respond to your queries, refund requests and/or 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. With your consent, we will use your personal 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.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites, we’ll use data we hold about your tile preferences or products. We do so on the basis of our website to placing 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 possibly 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 unsubscribing via a link or contacting us.
To build a better picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured, 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. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.
Combining your data for personalised 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 as described above, for example your shopping history and/or trends you’ve told us you like. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties. We do not share your personal data with any third parties for their marketing purposes.
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. We secure access to all transactional areas of our websites using ‘https’ SSL technology and every part of our root domain (primotilesandbathrooms.co.uk) is Norton SafeWeb Verified.
Access to your personal data is password-protected, and sensitive data such as payment card information is secured and tokenised to ensure it is protected via our secure payment gateways SagePay, PayPal, AmazonPay and Close Brothers Retail Finance.
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 you personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. Examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for 7 years so we can comply with our legal and contractual obligations.
Refunds or Exchanges
If your order included a refund, exchange or warranty period, the associated personal data will be kept until the end of the relevant period.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties. For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you. 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. Marketing companies who help us manage our electronic communications with you. 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. 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 our website we currently use the following companies, who will process your personal data as part of their contracts with us:
Google, Facebook, Instagram, Pinterest, YouTube, Affiliate Window, Yahoo, Bing, WordPress, Sussex Web Designs Limited, Lloyds Banking Cardnet Merchant Services, PayPal, AmazonPay, Android Pay & Apple Pay.
What are your rights over your personal 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 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.
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.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact our Data Protection Officer, Primo Tiles & Bathrooms Limited Ltd, Unit 3 Gallows Green Industrial Estate, Gallows Green Road, Dunmow, Essex, England, CM6 3QS, or email email@example.com. To ask for your information to be amended, please update your online account, or contact our Customer Services team. 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 personal 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 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.
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. 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 personal data for 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 area.
If you have an account, log in into your Primo Tiles & Bathrooms Limited account, visit the ‘My Account’ area and change your preferences.
Write to us, Data Protection Officer, Primo Tiles & Bathrooms Limited Ltd, Unit 3 Gallows Green Industrial Estate, Gallows Green Road, Dunmow, Essex, England, CM6 3QS or email firstname.lastname@example.org.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes. Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
Or write to us at Data Protection Officer, Primo Tiles & Bathrooms Limited Ltd, Unit 3 Gallows Green Industrial Estate, Gallows Green Road, Dunmow, Essex, England, CM6 3QS.
Updated 17th July 2018.
If you require further explanation please email our Compliance Team here.