1. What personal data do we collect?
The personal data we collect from you directly can include your name, email address, mobile/landline telephone number, date of birth, address, your purchasing activity, your payment information, and information you give us when you contact our customer services team, when you engage with our social media platform (for example by tagging us in a post on Instagram) or when you sign up for Smart Tissues support site.
If you are using a mobile device and shopping with us online or browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information.
We may, where we have a lawful basis for doing so, also collect personal data about you from third parties who provide us with additional publicly available information about you.
2. When do we collect your personal data?
- When you purchase products and services from us online, or over the phone.
- When you log into our WiFi.
- When you join our Smart Tissues website.
- When you contact us or we contact you to take part in surveys, competitions or promotions.
- When you contact our customer support team online or over the phone.
- When you engage with us on social media (by mentioning/tagging us or by contacting us directly).
3. How do we use your personal data and what are our legal justifications for doing so?
To make our products and services available to you
We use your personal data to provide you with the information, products and services that you request or purchase from us (i.e. to complete certain tasks, processes or orders on our website, take payment online (where applicable) and deliver your products or services), and to communicate with you regarding those products and services that you purchase from us and respond to your questions and comments.
We may also use your personal data to measure how satisfied our customers are and provide customer service (including troubleshooting in connection with purchases or your requests for services or when you ask us questions on social media);
We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data when you make an order for products and services. Alternatively, in some cases, we rely on our legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For administrative and internal business purposes
We may use your personal data for our internal business purposes, such as enhancing our site, improving our services and products and identifying usage trends. We may also use your data to monitor the use of our website and ensure that our website is presented in the most effective and relevant manner for you and your device and setting default options for you.
It is in our legitimate interests as a business to use your personal data in this way. For example, we want to ensure our website is customer friendly and works properly and that our products and services are efficient and of high quality. We also want to make it easy for you to interact with us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
For security and legal reasons
We use your personal data to:
- ensure the personal and financial information you provide us is accurate.
- conduct fraud checks or prevent other illegal activity.
- protect our rights or property (or those of others), and
- fulfil our legal and compliance-related obligations.
In some cases, we will use your personal data because it’s necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
In relation to your smart-tissues.com customer account.
We use your personal data to personalize your experience with us:
- provide you with marketing material via post and email if you have given us your consent to this.
- process your registration details, account activity and purchase history to analyze how you shop and what you shop for. This may include information on products you have viewed, historical transactions and products you have added to your online basket. This allows us to provide a browsing experience which is relevant to you.
- in some instances, we will send specific offers to our members based on their in store spend or on a special occasion, or depending on geographical market.
- measure the effectiveness of our marketing campaigns and our advertising.
We rely on your consent to send postal and email marketing messages to you as Smart Tissues customer based on the consent we acquired from you when you signed up, as amended by you from time to time.
In other cases (for example, measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business to communicate with our customers in an engaging and efficient way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To personalize your shopping experience and improve our operations
We use your personal data to:
- allow you to create a profile on our website which enables you to purchase our products and services online without having to fill in your personal data every time you shop online with us.
- provide you with marketing material via email.
- analyze how you shop and what you shop for. This may include information on products you have viewed, historical transactions and products you have added to your online basket. This allows us to provide a browsing experience which is relevant to you.
It is in our legitimate interests as a business to use your data in this way and we do this in order to enhance your shopping experience with us. This allows us to help you find the products and services which you may be looking for and avoids you having to browse through products or services which are not relevant to you.
When we send you marketing material via email, we will rely on our legitimate interests as a business, always ensuring that your rights are protected.
4. Who do we share your personal data with?
We will never sell any of your personal data to a third party. However, in order for us to provide our services to you, we share your personal data with our trusted third-party service providers or our group companies, as detailed below. Whenever we share your personal data, we put safeguards in place which require these organizations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.
To prevent crime and comply with laws
We share your financial information with third parties to ensure that your payment is safe and that your details are not being used fraudulently. This data sharing enables us to conduct fraud analysis which ensures that genuine and accurate payment details are provided to us for any purchase.
There may be other scenarios where we are subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime or fulfil a legal requirement.
Other professional services
We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.
We work with carefully selected third parties, such as our customer database hosting provider, marketing agencies and advertising partners who assist us in providing you with a positive customer experience. We work with these third parties to place relevant content and advertisements for you on our website, other websites and online media channels and apps. In order to do this, we use pixels and cookies. You can see our cookies policy.
5. Your rights
You have a number of rights relating to your personal information and what happens to it. You are entitled to:
- have your data processed in a fair, lawful and transparent way.
- access personal data we hold about you.
- require us to correct any mistakes in your personal data.
- require us to delete personal data concerning you in certain situations where there is no good reason for us to continue to process it.
- request that we transfer your personal data to you or another service provider in a simple, structured format.
- object at any time to processing of your personal data for direct marketing purposes.
- object to automated decision making which produces legal effects concerning you or similarly significantly affects you.
- object in certain other situations to our continued processing of your personal data, and
- otherwise restrict or temporarily stop our processing of your personal data in certain circumstances.
6. Changing your preferences
If you no longer wish to be contacted by us about our products or services, or for other marketing purposes, you can amend your preferences or unsubscribe by contacting us. Alternatively, follow the unsubscribe link provided in emails you receive from us.
We want to ensure that all the information we have about our customers is factually correct and up to date. If you find that the personal data we have about you is inaccurate or needs updating (for instance, you may have changed your name or address) then please contact us so that we can correct it. If you have created a profile on our website, you can change the details stored about you by logging into your account.
7. Security and retention of your personal data
Security of your personal data
We take the security of your personal data very seriously. We have implemented various strategies, controls, policies and measures to keep your data secure and keep these measures under close review. This means that your data is protected and only accessible by co-workers who need it to carry out their job responsibilities. We also ensure that there are strict physical controls in our buildings which restricts access to your personal data to keep it safe.
Retention of your personal data
We have procedures in place regarding our retention periods which we keep under review considering our reasons for processing your personal data and the legal basis for doing so.