Policies

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: info@thewoolroom.com

Address: Wool Room Limited, 33-35 Pilings Road, Oakham, Rutland, LE15 6QF

If you'd like to be removed from our catalogue mailing list,
we ask that you click this link and fill in the form. We will endeavour to
remove you from our outreach database within 30 business days.

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.

•        
provide your phone number to receive marketing
messages or basket reminders via SMS;

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. 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.



If you sign up to receive SMS marketing, we may share your phone number and relevant
browsing or purchase behaviour with our SMS platform provider (Klaviyo) to
deliver personalised messages. These providers act on our instructions and are
not permitted to use your data for any other purpose.

5. International Transfers

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

6. 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.

7. 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.

 

8. 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 and

charities. The participating retailers are active in the clothing, collectables,
food & wine, gardening, gadgets & entertainment, health & beauty,
household goods, home interiors and travel 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



 

·        
9. Your Legal Rights



Under certain circumstances, you have rights under data protection laws in relation
to  our 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.

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.

11. 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.

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



In addition to email, we may also send marketing communications by SMS, provided
you have given us your consent to do so. These messages may include exclusive
offers, personalised product recommendations, and abandoned cart reminders. You
can opt out of SMS marketing at any time by replying “STOP” to ,any message
received or by contacting us directly using the details set out in this policy.

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.



Our website uses cookies and similar technologies to monitor basket activity and
determine when to send SMS cart reminders, where you have consented to receive
these messages.

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.

Effective Date: June 5, 2020

The social media pages of Woolroom Ltd (the “Company”), include but may not be limited to Facebook, Twitter, Pinterest, Instagram, and YouTube (collectively "Social Media"). Social Media is used by the Company and its customers to communicate on topics related to our products and customer service. While the Company values an open exchange of ideas, it does maintain a few “rules of the road” to make sure that it is able to assist people with questions and issues related to its products quickly and efficiently. Social Media is delivered to you in accordance with Woolroom's Website Terms of Use (the “Terms”) and the terms of use of each of the Social Media operators.

Any information, pictures, creative works, ideas, testimonials, suggestions, concepts, methods, systems, designs, plans, techniques or other materials submitted that you send to us or post on or through Social Media ("Submitted Materials") shall be deemed not to be confidential or secret, and may be used by us in any manner consistent with the Terms and the terms of use of each of the Social Media operators.

By submitting or sending Submitted Materials to us or posting it on or through the Social Media, you represent and warrant that the Submitted Materials are original to you, that no other party has any rights thereto, and that any "moral rights" in Submitted Materials have been waived. We are not responsible for maintaining any Submitted Material that you provide to us, and we may delete or destroy any such Submitted Material at any time and for any reason and without advance notice to you.

By submitting or sending Submitted Materials to us or posting it on or through Social Media, you grant us and our subsidiaries and affiliates a royalty-free, unrestricted, worldwide, perpetual, irrevocable, non-exclusive and fully transferable, assignable and sublicensable right and license to use, copy, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform, display and incorporate in other works any Submitted Materials (in whole or part) in any form, media, or technology now known or later developed, including for promotional and/or commercial purposes. You agree that we may use, or permit others to use, without charge, your name, biography, picture and likeness with the content you submit and otherwise in materials promoting, marketing or advertising the Services, or Social Media, or our goods or services, in any media, without any compensation or advance notice to you.

We reserve the right, but do not have an obligation, to monitor and review all materials posted by you to Social Media. We are not responsible for the content of any materials posted by users. We reserve the right to edit, refuse to post, remove any content you post, or block any social media account, for any reason, at any time and without advance notice to you. Our reasons for removing or refusing to post content include, that such content is objectionable to us in our sole discretion, that it violates the Terms, or that it violates any applicable law, ordinance or regulation. We may also limit your access to all or certain portions of Social Media without notice to you for any reason.

By accessing and/or using Social Media, you agree not to do the following:

(a) use, copy, sell, post, display, print, publish, reproduce, distribute, transmit, modify, perform, broadcast, re-broadcast, translate, sell, adapt or otherwise create derivative works or improvements, whether or not patentable, of the Company, or any part thereof, except as expressly permitted by the Terms for your own personal, non-commercial, non-promotional use;

(b) use Social Media in a manner that: (i) violates any law, statute, ordinance, or regulation; (ii) violates, exploits, or harms, or attempts to violate, exploit, or harm, the legal rights (including the patent, trademark, copyright, privacy, or publicity rights) of any person or third party; (iii) promotes any illegal, commercial, advertising, or political activity, or advocates, promotes, or assists any unlawful, commercial, advertising, or political act; (iv) causes annoyance, inconvenience or needless anxiety or be likely to upset, embarrass, alarm or annoy any person or third party; (v) defames, abuses, threatens, stalks, harasses, intimidates, or harms any person or third party, or discloses personal information; (vi) tracks any person or third party without their explicit consent; or (vii) could give rise to any civil or criminal liability under any applicable local, state, national or international laws, statutes, ordinances, rules, regulations or ethical codes governing your jurisdiction, including confidentiality, data protection, and intellectual property laws;

(c) edit, remove, delete, alter, change or obscure any trademarks or any copyright, trademark, patent, or other intellectual property or proprietary rights notices, including any copy thereof;

(d) remove, disable, circumvent, or otherwise create or implement any workaround to any copy protection, rights management, or security features;

(e) impair or interfere with any other party’s use of Social Media.

The Company shall, in its discretion, cooperate with any law enforcement authorities or court order requesting or directing the Company to disclose the identity of anyone violating these restrictions.

The Company welcomes your questions or comments regarding this Social Media Policy. Please contact us at the following email: info@thewoolroom.com, or at the following address:

Woolroom Ltd

33-35 Pillings Road

Oakham

Rutland

United Kingdom

LE15 8PT