Privacy Policy

Introduction

This policy and any other documents referred to in it set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Berties Direct is committed to protecting and respecting your privacy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.bertiesdirect.co.uk you are accepting and consenting to the practices described in this document.

Berties Direct Limited may change this policy from time to time by updating this page. You should check this page periodically to ensure you are happy with the current policy.

For the purpose of this document, “we” and “us” mean Berties Direct Limited (Company No. 2667752) of Unit 34 Wem Business Park, New Street, Wem, Shropshire, SY4 5JX. Under the relevant Data Protection Laws (including the EU General Data Protection Regulation), we are the data controller of the data you give to us.

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 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.

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 ‘Your rights as a data subject’ section below.

How we use your personal data

We collect and process the following data about you:

• When you shop with us in online, we process your payment card information.
• When you make an online purchase we collect and process transaction-based data which may include your payment card information, billing/delivery address, orders and receipts, email and telephone number. We may also collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, for the purposes of fraud screening.
• When you create an online account with us we collect and process the information you provide including (where provided by you) your name, gender, date of birth, billing/delivery address, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
• When you shop with us, we may collect and process details of your transaction history and shopping preferences including details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, brands you show interest in and, if applicable, web pages you visit.
• When you contact us by any means with queries, complaints etc., we may collect your personal data.
• When you choose to complete any surveys we send you, we may collect your personal data.
• When you comment on or review our products and services, we may collect your personal data.
• When you fill in any of our forms, we may collect your personal data.
• When you’ve given a third party permission to share with us the information they hold about you, we may collect your personal data.

How we collect personal data

We collect personal data from you by the following means:

• Information you give us. You may give us information about you by: entering into transactions, opening an account on our site www.bertiesdirect.co.uk (our site), filling in forms or providing information, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when:
• You purchase goods by phone or online;
• Register an online account on www.bertiesdirect.co.uk;
• Search for a product;
• Participate in discussion boards or other social media functions;
• Enter a competition, promotion or survey; and
• When you report a problem with our site.

The information you give us may include your name, address, e-mail address and phone number, debit or credit card information, personal description and photograph.

• If you choose to create an account, you will be able to manage your personal data online via www.bertiesdirect.co.uk. If you do not choose to do so, you will not be able to view or modify this information. If you wish to change any preferences and you have not created an account, please contact Customer Services.
• With regard to each of your visits to our website we may automatically collect the following information:
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
• We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) and may receive information about you from them.

Legal basis for processing your data

We may collect and process your personal data for a number of reasons and rely on the following legal bases:

1. Consent

Where we have collected data with your consent, we will process such data in accordance with the consents that you have provided. For example:

Where you have consented to receive direct marketing from us, we will use your personal data, preferences and details of your transactions to keep you informed about relevant products and services including tailored special offers, discounts, promotions, events and so on. We shall keep you informed in line with your marketing preferences. You are free to opt out from any such marketing communications.

Where you provide us with personal data for a specific purpose (such as complaints, claims, and online transactions) we will process such personal data for that specific purpose.

To display the most interesting content to you on our website, we may use data we hold about your favorite brands or 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.

2. Contractual Obligations

We may need your personal data to comply with our contractual obligations. For example, we will need to process personal data to deliver goods you have purchased online.

3. Legal Compliance

If required by law, we may need to collect and process your data. For example, we may need to process personal data to comply with our legal obligations to share data with law enforcement or to comply with an order from the court.

4. Legitimate Interest

We process your data for 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.

These legitimate interests include the following:

4.1. Direct Marketing and good customer Service

It is a legitimate interest of our business to contact our customers for the purposes of direct marketing.

Subject to their marketing choices, we send customers who have transacted with us personalised communications in relation to new products and ranges and offers by email and we do so on the basis of our legitimate interests.

We use the data we have to offer you promotions and products that are likely to be relevant to you.

You can, of course, decide not to receive any direct marketing from us by unsubscribing from our newsletters.

4.2. Process orders

We will need to collect and process data in order to process any orders online. 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.

We may share personal data with business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you. For example, your details will need to be passed to a third party to deliver product ordered online.

If you are looking to pay by debit or credit card by phone or online we will need to process your payment card data in order to complete the transaction. We process card payments in accordance with the Payment Card Industry Data Security Standards.

Following a transaction, we may keep your details for a reasonable period afterwards in order to fulfil contractual obligations such as refunds.

4.3. Refunds and complaints

We have to process personal data in order to respond to your queries, refund requests and complaints.

We may also keep a record of your queries, refund requests and complaints for the following purposes:

• To inform our future communications with you;
• To review whether there are any patterns regarding the complaints we receive, for example, quality issues with any particular products;
• To be able to demonstrate how we dealt with your complaint; and
• To consider how we can improve our services based on your experience.
• In such circumstances we will process your personal data in accordance with our contractual and legal obligations with you and our legitimate interest to provide you with good customer service.

4.4. Security

We have a legitimate interest to protect our customers, our business, our employees, our online store and our premises from criminal and illegal activity such as fraud and theft. Therefore, we may process personal data as follows as part of our legitimate business interest:

• Using your personal data to maintain, update and safeguard your online account.
• Monitoring your browsing activity with us to identify and resolve any problems and protect the integrity of our website. This will include checking passwords and using automated monitoring of IP addresses to identify possible fraudulent log-ins.
• Processing payments and preventing fraudulent transactions.

If we discover any potential criminal activity we will use personal data (such as transaction monitoring etc.) to investigate the potential criminal activity and, where appropriate, pass the details of such potential criminal activity to the police and other relevant regulatory authorities. For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems with third parties such as law enforcement bodies and the relevant financial institutions.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body upon a valid request to do so. We assess such requests on a case-by-case basis whilst taking the privacy of our customers into consideration.

4.5. Updates on law and our policies

We may send you communications required by law or which are necessary to inform you about changes to our business and/or issues regarding our products. For example, we may contact you by email, regarding 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. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

Sharing and disclosure of your data

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Berties Direct Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms &Conditions and other agreements; or to protect the rights, property, or safety of Berties Direct Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• In order to support, operate, maintain our website, to assist your user experience of the website and for fraud management we currently use the following IT companies who may process your personal data pursuant to contracts with Berties Direct:
• WorldPay (UK) Limited
• Sagepay Europe Limited
• Elavon Financial Services DAC
• PayPal (Europe) Sarl et Cie, SCA
• We also use delivery couriers to deliver orders. Currently we use the following delivery couriers:
• A. J. Maiden & Son Limited
• T.W.C. Parcel Collection Services Limited
• Ningbo Distribution
• We also work with:
• Direct marketing companies who help us manage our electronic communications with you;
• Marketing Companies that provide services that will improve the products and services we offer you.
• We work closely with the third parties with which we share your data to ensure the that the third parties: Have adequate security measures and policies in place;
• Will respect and protect your privacy;
• Only use your data when necessary to perform their specific services in place and will protect your privacy;
• Will delete your data or anonymise when we have stopped using their services.
• We do not share data with third parties for their own purposes.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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. We ask you not to share a password with anyone.

Input of personal data is at the user’s discretion. We have strict policies and procedures regarding the storage, processing and transmission of your personal data.

The Berties Direct Limited website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Berties Direct Limited uses cookies to help Berties Direct Limited identify and track visitors and their website access preferences. Berties Direct Limited website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Berties Direct Limited website.

Any information Berties Direct Limited holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

Retention Policy

Berties Direct Limited will process personal data during the duration of any contract and will continue to store the personal data for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted or anonymized.

Your rights as a data subject

At any point whilst Berties Direct Limited is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Berties Direct Limited refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Berties Direct Limited at your request can confirm what information it holds about you and how it is processed

You can request the following information:

• Identity and the contact details of the person or organisation (Berties Direct Limited) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Berties Direct Limited, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

Berties Direct Limited will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Berties Direct Limited is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to sales@bertiesdirect.co.uk or by phoning 01939 234232 or writing to us at the address further below.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by Berties Direct Limited, you have the right to complain to Berties Direct Limited’s Board of Directors. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The contact details are as follows:

Berties Direct Limited, attention of the Board of Directors
Unit 34
Wem Business Park
New Street
Wem
Shropshire
SY4 5JX.
Telephone 01939 234232 or email sales@bertiesdirect.co.uk

Data Protection Regulator

Information Commissioners Office
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Website: https://ico.org.uk

List of cookies we collect

The table below lists the cookies we collect and what information they store.