This privacy notice sets out how we collect, use and manage your personal data. Where we refer to “personal data” in this privacy notice, this means data which relates to you and which personally identifies you either directly or indirectly.
Data Controllers and Data Protection Officer
A data controller is an organisation that collects, uses and manages personal data and has responsibility for how the personal data is collected, used and managed.
A data protection officer is the person in an organisation who has responsibility for monitoring compliance with data protection law and for ensuring that personal data is protected within an organisation.
Shop Direct Home Shopping Limited provides your goods and is the data controller of personal data that you provide when you order goods. Shop Direct Home Shopping Limited is registered in England, number: 4663281. Registered Office: First Floor, Skyways House, Speke Road, Speke, Liverpool L70 1AB. Shop Direct Home Shopping Limited’s websites are www.very.co.uk and www.littlewoods.com.
Shop Direct Finance Company Limited provides credit, subject to status, and arranges other financial services products and is the data controller of personal data you provide when you request a credit account or other financial services products. Shop Direct Finance Company Limited is registered in England, number: 4660974 and is authorised and regulated by the Financial Conduct Authority. Registered Office: First Floor, Skyways House, Speke Road, Speke, Liverpool, L70 1AB.
In the context of this privacy notice, when we use the term 'we' it means Shop Direct Home Shopping Limited and Shop Direct Finance Company Limited. Where you have a relationship with Shop Direct Home Shopping Limited and Shop Direct Finance Company Limited, your personal data may be shared between these two data controllers.
The Data Protection Officer for Shop Direct Home Shopping Limited and Shop Direct Finance Company Limited can be contacted at DPO@theverygroup.com
How We Use Your Personal Data
We collect, use and manage your personal data to provide goods and services to you and to enter into and administer any credit accounts or financial services products you may have with us.
We will use your personal data in the following ways:
To provide goods and services and to manage your retail account including administering payments, returns and responding to queries.
To assess whether to offer you a credit facility and for ongoing administration of any credit facility. This includes accessing and sharing information with the Credit Reference Agencies.
To administer any financial services products that you have.
To administer any prize draw or competition you may enter.
To analyse your shopping preferences or how you interact with or use our websites.
For research and statistical purposes.
For marketing purposes including to send you special offers or discounts and to tell you about products and services from us or third parties. This may also include levels of profiling to ensure we market to you about relevant products and services. You control your preferences in respect of how your personal data is used for marketing and you can change these preferences when you log in to My Account.
To record and monitor outbound and inbound telephone conversations with you to ensure consistent service levels, to prevent or detect fraud, to resolve queries and complaints and for performance management and training purposes.
We will collect personal data directly from you when you purchase goods or services, apply for a credit account or other financial services products, or change any of your details (such as your name or address) via My Account. We require you to provide personal data in order to assess whether to enter into a contract with you or to perform our contract with you and if you do not provide the personal data we request, we will be unable to enter into or fulfil this contract. We may also collect personal data through cookies. For further information please see our cookies policy
We obtain data from third party sources such as credit reference agencies, fraud prevention agencies and publicly available information relating to you on the internet (for example on social media websites).
We may also obtain personal data from third party companies for the purposes of sending marketing communications to you. Such marketing communication may be sent by ourselves or by the third parties. These third parties must check you have given your permission for such contacts to take place.
Why We Need Your Personal Data
We need to process your personal data for a number of different reasons and these are our legal bases for processing. We also need to keep your personal data for as long as is necessary for us to operate our business and to comply with legal and regulatory obligations.
We rely on one or more of the following legal bases for processing personal data:
To perform our contract with you or to enter into a contract with you
We need to process your personal data to fulfil our contract with you or to assess whether to enter into a contract with you, whether this is in selling and delivering goods and services to you or providing credit facilities or other financial services products to you.
To fulfil our legitimate interests or the legitimate interests of a third party
When we process personal data to fulfil our legitimate interests we will use it in a way in which you would reasonably expect and which will have a minimal privacy impact. When we or third parties are relying on legitimate interests to process your data we will balance our interests against your interests and the privacy impact of the processing on you and we will process your personal data responsibly.
Examples of our legitimate interests are: direct marketing, fraud prevention, preventing and investigating crime, assessing affordability and credit worthiness, IT security and development by us and third parties of new products and services.
To comply with legal obligations to which our business is subject.
We have to comply with relevant law and regulation in order to provide retail and financial services products and we will need to process your personal data in order to comply with these legal obligations.
If we are relying on your consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.
We will keep your personal data for the purposes set out in this privacy notice and only for as long as any legal basis continues to apply. Below is a non exhaustive list of some of the reasons we need to retain your personal data:
Compliance with the requirements of the Financial Conduct Authority
Compliance with Anti Money Laundering Regulations
Reporting obligations to the Credit Reference Agencies
Ensuring we have relevant information in the event of any queries or complaints
Being able to identify if you have purchased a product which is subject to a product recall
Being able to service any product or service guarantee you have purchased
To assist with the establishment, exercise or defence of legal claims
The length of time we need to keep the personal data will vary depending on the nature of the personal data and the reason we are obliged to hold it. We will apply appropriate risk based measures to protect your personal data which may include pseudonymising or anonymising the personal data. If personal data is pseudonymised, this means it is de-identified so you are no longer identifiable, but we can re-identify you if we have a requirement to do so. If personal data is anonymised, it is de-identified, but can never be re-identified in the future.
You have certain rights in respect of your personal data and we have processes to enable you to exercise these rights.
Right of Access
This is known as a Subject Access Request. If you want to know if we are processing personal data relating to you and to have access to any such personal data contact DPO@theverygroup.com
If you have any queries about how we use your information or on data protection generally please call us, click here for details, or write us at the Data Protection Office, Park Lane, Netherton, Liverpool, L72 1LE