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Introduction


Wool Room Limited (“we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.
 

1. Important Information and Who We Are

 

Purpose of this privacy policy


This privacy policy aims to give you information on how we collect and process personal data from people who visit our website at www.thewoolroom.com, including any data you may provide through this website when you purchase a product and from people who get in touch with us for any reason, including by phone or email. It will inform you how we use your personal data, the conditions under which we may disclose your personal data to others, how we keep your personal data secure and sets out your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
 

Controller


Wool Room Limited is the data controller and is responsible for your personal data. We gather and process your personal data in accordance with this privacy policy, and in compliance with the General Data Protection Regulation (“GDPR”) and other relevant data protection laws and regulations.
 

Contact details


If you have any questions about this privacy policy, our privacy practices or to exercise any of your legal rights, please contact us in the following ways:

Telephone: +44 01780 461217
Email: [email protected]
Address: Wool Room Limited, 33-35 Pilings Road, Oakham, Rutland,

Changes to the privacy policy and your duty to inform us of changes We keep our privacy policy under regular review. We may change this privacy policy from time to time by updating this page. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to review and/or update personal data we hold about you, please contact our data protection manager using the details above.
 

Third-party links


This privacy policy applies to this website only. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. You should read any policies and statements on every website you visit.
 

2. The Data We Collect About You


Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed.
The following table explains the types of personal data which we may collect, use, store and transfer. We will only use your personal data as the law allows us to. The categories of personal data which we use include:
• Identity and Contact Data such as names, titles and other identifiers together with address, email address and telephone numbers.
• Financial Data including information you may need to provide us with to make a payment. This may include credit/debit card information, and your bank account details.
• Technical Data including internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website and our products and services.
• Transaction Data including details about payments to and from you and other details of products you have purchased from us.
• Profile Data such as username and password details you use to log in to your account, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data including information about how you use our website, products and services.
• Marketing and Communications Data which includes preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 privacy policy.

We do not collect certain types of Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership). However, from time to time we may collect other data about you depending on why you have contacted us. For example, if you are enquiring about the Allergy Seal offered on some of our products, then we may ask for information in respect of your allergies or particular needs. If you contact us in your capacity as a representative of the organisation for which you work (rather than in a personal capacity) we may take your job title and role. We do not collect any information about criminal convictions.
 

If you fail to provide personal data


Where we need to collect personal data by law, under the terms of a contract we have with you or the organisation your represent, or for another lawful reason and you fail to provide that data when requested, it may restrict us from offering some or all of our services. It may also prevent us from properly dealing with a request or enquiry you have made, or we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.
 

3. How is Your Personal Data Collected?


Personal data is collected in a number of ways. We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
 

4. How We Use Your Personal Data


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: • Where we need to perform the contract we are about to enter into or have entered into with you. • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. • Necessary to comply with a legal obligation.
 

Purposes for which we will use your personal data


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 
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)
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, 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, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products, 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 that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products and grow our business)

Marketing


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
 

Promotional offers from us


We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing
 

Opting out


You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
 

Cookies


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Woolroom Cookie Policy here.
 

Change of purpose


We will only use your personal data for the purposes for which we collected 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 required or permitted by law.
 

5. Disclosure of Your Personal Data.


We may contact you via email to invite you to review any products you received from us in order to collect your feedback and improve our service and products. We use an external company, Trustpilot A/S (“Trustpilot”), to collect your feedback which means that we will share your name, email address and order number with Trustpilot for this purpose. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 

6. International Transfers


We do not transfer your personal data outside the European Economic Area (EEA).
 

7. Data Security


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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 

8. Data Retention

 

How long will you use my personal data for?


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other 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 you can ask us to delete your data: see “your legal rights” below for further information.

 

9. Data Sharing


We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. Retailers share information about their customers and what they buy. Epsilon Abacus processes this information as a processor on behalf of the retailers to help them understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending individuals suitable offers that should be of interest to them, based on what they like to buy. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here: https://www.epsilon.com/abacus/services-privacy-policy
 

10. Your Legal Rights


Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
• Request access to your personal data (a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it, to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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.br/>
 

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.
 

10. Lodging a Complaint


We will only process your personal data in compliance with this privacy policy and all relevant laws and regulations. If you have cause for concern or are unhappy in any way, however, you may lodge a complaint with us using the contact details set out above.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.