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Privacy Policy

This Privacy Policy sets out how we collect and use your personal information and what your individual data protection and privacy rights are.

This Privacy Policy was last updated on 1st May 2018 and is version 2.1.

Who is Responsible for Processing Your Personal Data

JD Williams & Company Ltd trading as N Brown is the Data Controller. This is the legal entity responsible for how your personal data is collected, stored and processed.

JD Williams & Company Ltd trading as N Brown operates a number of different brands to which this privacy policy relates. These brands are JD Williams, Simply Be, Jacamo, High & Mighty, Fashion World, Julipa, Ambrose Wilson, Marisota and Premier Man.

Managing Your Personal Data

When you share your personal information with us, you have a right to expect that information to be treated with total confidentiality. Therefore, it is our responsibility to manage your personal data that you provide to us with care and in accordance with all data protection legislation and industry best practice.

Whether you have supplied your personal details online, by phone, by email or in a letter, we will never use them without a lawful reason to do so. We will use your personal data for the purposes for which they were initially requested and as fully explained in this Privacy Policy.

It is your responsibility to ensure that your personal data provided to us is accurate and up to date. You can update your personal contact details, including email address and phone number, by visiting My Account online or, if you need to update any other personal details, by ringing our contact centre on 0345 071 9018.

Using Your Personal Data for Direct Marketing Purposes

Based on your marketing preferences, we use your email and home address to send you details of our latest products and promotions. We also use marketing Profiling techniques to determine what product offers may be of interest to you whether that be by email, telemarketing, direct mail or social media. For further information on how we use your personal data to keep you informed about our products and promotions and how you can change your marketing preferences, click the relevant sections below.

We hold your personal data for the purposes of direct marketing to you for a period of two years from the date of your last purchase unless you have an outstanding credit balance or have updated your marketing preferences in which case you will continue to receive marketing information unless you tell us otherwise. If you have only ever registered a cash account but never bought from us, we will stop marketing to you after a period of six months unless you ask to be contacted by updating your marketing preferences.

Obtaining Your Consent+

We will obtain your consent to send you details of our latest products and promotions via Email Marketing and Telemarketing in a number of ways.  We will obtain your consent when you register your details with us, open a credit account, make a purchase, sign up to our email newsletters, request a catalogue from us, enter a competition or when we send you electronic receipts via email in store.  You can change your email and telemarketing preferences at any time - see Changing Your Marketing Preferences.

Email Marketing +

We would like to keep you informed about our latest product offers and promotions using the email address you provide to us.  We will also use your date of birth to send you specific offers for your birthday.  To do this, we will ask you to opt-in to receive marketing emails when you first register an account with us , sign up for our newsletter, enter a competition or prize draw or agree for us to use your email address for marketing purposes when we send you electronic receipts in store.  You can opt out of email marketing at any time - see Changing Your Marketing Preferences.

Telemarketing+

We will ask your permission to ring you about our latest product offers and promotions when you make a purchase or open a credit account with us.  You can opt out of telemarketing at any time - see Changing Your Marketing Preferences.

If you have subscribed to the Telephone Preference Service, we will not contact you by phone unless you have explicitly opted in to receiving telemarketing calls from us.

Direct Mail +

We will use your name and address to send you personalised marketing mails in the post.  We have a legitimate business interest to send you information about our products and offers in the post as we know that many of our customers like to browse through catalogues or offers prior to placing an order with us.  However, should you wish to exercise your right to stop personalised postal marketing activity, you can do this at any time - see Changing Your Marketing Preferences.

Social Media+

We will use your email address to send you online targeted marketing information about our product offers and promotions via social media platforms.  To do this, we will share your email address in a secure manner with social media organisations, such as Facebook, who will match our advertising requirements to your social media profile.  We have a legitimate business interest to send you product information via social media which we believe is of relevance to you; this is known as Interest-Based Advertising. However, should you wish to exercise your right to stop targeted social media marketing, you can do this at any time - see Changing Your Marketing Preferences.

Third Party Marketing+

We will not share your personal data with third party companies for the purpose of them marketing their products and services to you.

Changing Your Marketing Preferences+

You can change your marketing preferences for Email Marketing at any time by:

  • Clicking unsubscribe in the body of the email sent to you;
  • Going online to My Account; or
  • Ringing the call centre on 0345 071 9018.

You can change your marketing preferences for Telemarketing at any time by:

  • Going online to My Account; or
  • Ringing the call centre on 0345 071 9018.

Please allow 48 hours for your changes to be processed for email and telephone marketing.

You can exercise your right to object to Direct Mail or Social Media at any time by:

  • Going online to My Account; or
  • Ringing the call centre on 0345 071 9018.

Please allow 48 hours for your changes to be processed for social media.  You may still receive direct marketing materials that are already processed before we received your request for up to 2 months.

Using Your Personal Data to Improve Your Online Shopping Experience

We want to make sure that we only contact you with online content that you will find relevant and interesting.  For this to work effectively, we collect information about your browsing activity using Cookies when you are using our websites.  These Cookies pass back to us your browsing information using your Internet Protocol ("IP") address as the identifier, which we combine with other anonymised, non-personalised and aggregated data, allowing us to determine what content and product information is most relevant to you when you are shopping online.

We have a legitimate business interest to use the aggregated and anonymised data obtained via Cookies and other data sources to help us provide you with relevant product marketing and improve your online shopping experience.

Profiling+

Profiling is a term used to describe a form of data processing where significant volumes of data made up of lots of different data types - such as browser history from Cookies, age, gender, size, transaction history, demographics and buying habits - are all used in an aggregated, anonymised and non-personalised form to evaluate and predict, based on statistical analysis, what you may or may not want to purchase from us by assigning you to a profile type.  We use this technique to understand what drives you to buy from us and the types of products you are most likely to be interested in whether that be by email, telemarketing, direct mail or social media.  This is sometimes referred to as Big Data and Data Science and is widely used by retailers to improve their customer offering and Interest-Based Advertising.

Interest Based Advertising+

The data that we collect and use when you browse or shop online, including where we use Cookies, uses your IP address as the unique identifier; however, it will not contain your name, home address or phone number. We may also use your email address to send you online targeted marketing information but we always use hashed email addresses to keep your data secure. The email addresses are scrambled before being utilised to ensure nobody else can gain access to your email address. This enables us to offer our customers the best possible online user experience and equally allows us to improve the relevancy of our advertising. This allows us to provide you with more of the content you want to see.

Using Your Personal Data to Open Your Personal Credit Account

When you apply for a credit account with us, we will use your personal data to make a decision as to whether or not we will accept your application and, if so, the amount of credit we will offer you.  Without this data, we are unable to perform the services under this contract i.e. to calculate the amount of credit offered and manage your credit account in accordance with the applicable guidelines and regulation.

You have a choice to opt out of providing us with your personal data for the purpose of making an automated decision at the point of application and select a cash account.  By opting out, we will not be able to provide you with a credit account.  However, you can still shop with us by opting for a cash account as an alternative and pay with credit or debit card for your purchases.

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit account.

Automated Decisioning and Profiling+

To make a decision with regards to your credit application, we use automated decision making. To do this we will make searches about you with Credit Reference Agencies. We use the data from Credit Reference Agencies, together with personal data you provided to us, transactional data (such as any previous trading or account history with us), public records (such as insolvency register) and other data which you have given permission to be used for this purpose to verify your identity and determine the level of credit we can offer you. This data is used to calculate a score which allows us to categorise customers according to risk.  We do this so that we can respond to your credit application promptly and to ensure our credit lending decisions are fair and responsible.  By proceeding with your application, you agree to the use of these automated processes and acknowledge that without it we are unable to proceed with your credit application.  However, you can still shop with us by opting for a cash account as an alternative and pay with credit or debit card for your purchases.

Where we are unable to make an immediate decision, we will refer your application to our Credit Underwriting Team who may request additional information from you.  Should you not wish to provide such information, we will not be able to make a decision with regards to your credit account application for you.  However, you can still shop with us by opting for a cash account as an alternative and pay with credit or debit card for your purchases. 

Credit Reference Agencies+

We will request information about you from Credit Reference Agencies ("CRAs") and we will also supply your personal data to CRAs.  The CRAs that we use are Experian, Call Credit, Equifax and Aire Labs Ltd.  For more information as to how CRAs use your personal data, please refer to the Credit Reference Agency Information Notice ("CRAIN") at:

These companies receive and share personal and financial data on you from all the companies that you are connected with financially as well as providing us with verification of your name, address, date of birth and gender details from the Electoral Register to prevent fraudulent applications.  The CRA record details of all credit searches and tell us the risk associated with providing credit and if there is any suspected fraudulent activity associated with you.

We will also share your personal data with CRAs and other companies for fraud prevention.  We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.  When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

We may make periodic searches of our records that we hold about you, CRAs and fraud prevention agencies to manage your account with us and to take decisions about credit, including whether to make credit available or to extend existing credit arrangements. These searches will not be available to other lenders for credit assessment purposes.

We, CRAs and fraud prevention agencies may also use the credit records for statistical analysis about credit, insurance and fraud generally.  This is not personal data but is aggregated for the purpose of trend analysis, managing debt and fraud prevention.

You have the right to access your personal records held by CRAs by contacting Experian, Call Credit and Equifax directly. 

Using Your Personal Data to Open Your Personal Cash Account

When you register to open a personal cash account, we will hold your personal data which you have provided to us.  When you make a subsequent card or cheque payment to purchase products from us, we will use your personal data and card information to process the order. This involves sending your personal data to our card payment and banking providers to ensure that you have sufficient funds to cover the value of the transaction.  Without this data, we are unable to fulfil your order.

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal cash account.

Processing Card Payments+

We process all card payments in line with our obligations under the PCI-DSS regulations.  Whenever you provide your card details to us either online or over the phone, we will encrypt the payment details before sending to our card payment and banking provider.  If you pay over the phone, we will mask any card data that you provide so that this is not visible to our customer advisors as well as stopping card data from being recorded in our Call Recordings.  This is regularly monitored for quality assurance as part of our PCI-DSS obligations.

Any card details provided by customers via paper order forms will be immediately, and securely, destroyed once processed.

Using Your Personal Data for Fraud Prevention

We carry out fraud checks on new credit applications and credit orders.  In order to do this, we use data sourced from Credit Reference Agencies and other external agencies that are involved in fraud detection. If we identify fraud, we will pass data relating to the fraudulent activity such as name, address and email address to these agencies to help protect individuals and other businesses from the threat of fraud in the future.

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit or cash account.

Using Your Personal Data to Operate Your Simply Be Loyalty Membership

We will use the information, including personal data, which you provide to us when you register for your Simply Be customer account to administer your Simply Be Perks loyalty membership.  Without this data, we are unable to administer your Simply Be Perks loyalty membership.  For more details on how we use your personal data, click on the heading below.

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your Simply Be Perks loyalty membership.

Operating Your Simply Be Perks Loyalty Membership+

We will use your personal data to operate your Simply Be Perks loyalty membership in the following manner:

  • Your personal data, such as name, postal address and email, will be transferred to our third party processors so they can process and distribute your rewards on our behalf.
  • Details of rewards that are available to you will be sent to the email address you provided.
  • Your rewards will be available when you log in to your Simply Be customer account online.
  • Data from your Simply Be customer account may be used for the purposes of analysis and so that we can provide rewards that are tailored to you.

It is important that the contact information on your Simply Be customer account is accurate and up to date at all times. If you need to amend any of your details, you can do this online via your Simply Be customer account or by calling us.

If you have opted out of receiving email marketing from Simply Be when registering your Simply Be customer account, or at any other time, you will not receive any email notifications about any new or existing rewards available to you.  You can still be a part of Simply Be Perks and view your rewards online. You can change your email preferences at any time if you wish to opt back in - see Email Marketing.

Using Your Personal Data to Operate Your Personal Account

We will use your personal data to administer and to operate your personal credit and cash account as set out below.  We will collect and use the contact details that you provide to us to communicate with you about your account and in relation to the products and services we provide to you. 

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit and cash account.

Delivering Your Goods+

We will use your personal contact details such as name, postal address, phone number and email address that you provide to us in respect of delivering products or services to you.  We will share this information with our suppliers who directly despatch orders to you or our delivery partners who may contact you to arrange a convenient delivery time and provide you with updates as to when they will arrive. 

Processing Returns and Refunds+

We use your customer account and contact details to verify any returns and refunds that we process either by card or via your credit account.  We process all card payments in line with our obligations under the PCI-DSS regulations and will encrypt the payment details before sending to our card payment and banking provider. 

Operating Your Credit Account+

We use your personal contact details such as name, postal address, phone number and email address to notify you about any updates, changes or issues with your personal credit account.  We use your personal contact data, payment history and credit information obtained from Credit Reference Agencies to determine whether and when to increase or reduce your credit limit.  We may also send you notifications via SMS to notify you if you have exceeded your credit limit or a payment is due. 

Making Payments to Your Credit Account+

You can set up a direct debit between us and your bank to make regular payments to your personal credit account with us. If you choose to pay this way, we will require a bank account number, sort code and the type of payment you wish to make e.g. full balance or fixed amount. We will use the personal data provided to verify that the account number and sort code combination are valid. We will also ask you for the bank account holder’s name which the bank will use to verify the direct debit payment request. It is your responsibility to ensure that you either have a sole authority or that you have the bank account holder’s permission to make payments from their bank account.

Where you pay by cheque, we will also store the cheque details including account number and sort code which are required to deal with any queries raised to us by your bank.

Where you pay by credit or debit cards, we process all card payments in line with our obligations under the PCI-DSS regulations. Please see Processing Card Payments section for more detail.

Electronic Statements & Other Documents via Email+

We will use the email address that you provide to us to communicate with you about your account and in relation to the products and services we provide to you.  Unless you have specifically requested otherwise, we will send your account statements and other account information and documentation to you electronically using your email address.

We will hold your statement data for 6 years, plus the current financial year, after the date of your last statement.

Call Recordings+

We record all calls into our contact centre for quality assurance, regulatory compliance and training purposes.  We retain all call recordings for a period of 12 months.

Enquiries and Complaints+

If you have any complaints with regards to the operation of your personal cash or credit account, please contact our contact centre on 0345 071 9018 so we can deal with your complaint as quickly as possible.  We will need to access your personal data and account history to verify your identity for security reasons and deal with the details of your complaint.  Details of any complaints received will be logged and recorded so they can be dealt with accordingly.

General Service Communications+

We will use your personal data for all general service communications including sending your statements, processing orders, notifying you of orders received, updating you on deliveries, despatched or products out of stock.  We need to do this for the performance of the contract and terms and conditions that you have signed.

Using Your Personal Data to Improve Our Services

As a valued customer, we may use your personal data to contact you by phone, SMS, letter or email to ask you to participate in one of our service improvement programmes.  We will share your personal contact details with our chosen third party partners and service providers who may carry out these service improvement programmes on our behalf.  We will always make you aware of how we will use the information that we gather from you at the time of contacting you for any specific service improvement programme.  We have a legitimate business interest in contacting our customers in this way and will always treat your involvement in any service improvement programme, and associated personal data, in confidence.

Should you not wish to participate in our service improvement programme, you can simply decline to participate at the point of contact or, should you wish never to be contacted for the purpose of market research, you can tell us at any time by ringing the contact centre on 0345 071 9018.

Product Reviews+

Whenever you make a purchase from us, we will send you an email asking you to provide a review of the product and tell us what you think.  If you choose to do so, you will be asked to enter your email address, your thoughts about the product and any relevant details which may include age range, height and size if relevant to the product you have purchased.  You will also be asked to agree to separate terms and conditions as we use a third party to process and analyse the data for us.  We will use your email address to confirm that we have received your product review.  We are really keen to hear what you think about our products and use the information to inform our product development programme.

Fizzback+

We use a tool called Fizzback to communicate with our customers to obtain feedback about our products and services.  We will send you an SMS or email containing a short survey which we ask you to complete and send back to us.  This information is only used by us to improve our product and service offering and deal with any Enquiries and Complaints that you raise via Fizzback.  Should you not wish to participate, you can choose not to respond.

Surveys+

From time to time, we will contact you to take part in a customer satisfaction survey.  We often use third party partners to collect this information on our behalf.  We will share your basic personal data - name, address, phone number and email - for them to contact you to ask if you wish to participate in such surveys. We, or our third party partners, may sometimes follow up on surveys with you to get more information from you regarding specific complaints or feedback.  You can choose not to participate in such surveys should you not wish for your personal data to be shared in this way by ringing the contact centre on 0345 071 9018.

Research & Focus Groups+

From time to time, we employ different market research agencies, who act on our behalf, to contact our customers with the aim of getting a more detailed understanding of what our customers think about our products and services.  We will share your basic personal data - name, address, phone number and email - for them to contact you to ask if you wish to participate in our service improvement programme.  We may also share more personal data about your shopping habits, including the size and type of products that you have purchased if this is relevant to the market research.  Occasionally, we ask our research companies not to tell customers that they are contacting you on our behalf, for example for brand research purposes, as we do not want to influence your answers.  However, the market research company is obliged to disclose this information should you ask at the end of the survey.  If you do not wish to be contacted for market research purposes, you can ring the contact centre on 0345 071 9018.

Social Media+

We actively use social media platforms as a way of connecting, and getting closer, to our customers to hear and understand what our customers think about us and our products and services.  Occasionally, we may contact you directly via those social media platforms if we would like to share your comments or pictures with other customers or publish them in our marketing materials.  We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.

Using Your Personal Data to Process Insurance Claims

In the event that you need to make a claim against us, whether that be a product issue or personal injury claim, we will use your personal data and any supporting evidence that you provide to us to process your claim, including sharing this with our chosen insurance companies.  From time to time where a claim is outside of our insurance policy, we may also need to engage with external lawyers and share your personal data with them.

Sharing Your Personal Data with Third Party Processors & Partners

As part of delivering our products and services to you, we will share your personal data with carefully chosen Third Party Processors and Partners who carry out a number of services on our behalf.  Should you wish to obtain a list of our latest Third Party Processors and Partners, you can request this at any time by contacting our Data Governance team.

Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services.  If you have any concerns about any of our third party processors and partners, please contact our Data Governance team.

Processing Your Personal Data Outside of the EU

We will transfer your personal data outside the European Economic Area (the EEA) to prevent fraud, for credit searches and with our outsourced IT partners and contact centres. Please also see Sharing Your Personal Data with Third Party Processors & Partners.  In some cases, countries outside the EEA may not have such well-developed data protection laws as those in the EEA. However, we will put in place measures and safeguards that require your personal data to be kept secure, confidential and to be processed only and strictly in line with the terms of this Privacy Policy and any relevant data protection laws.

Acting as a Data Processor for Our Marketplace Partners

We will sometimes act as a data processor for other retail companies including, but not limited to, Amazon and eBay.  These companies pass your personal data - name, address, email address, telephone number and unique order number - to us for the sole purpose of fulfilling and managing your order on their behalf.  We may occasionally contact you in respect of your order using this data.  When placing an order with these companies, you will be agreeing to their terms and conditions and their privacy policy.  Please contact the relevant company should you have any questions, comments or complaints about how your data is used.

How to Contact Us

If you have any questions, comments or complaints about this Privacy Policy or our use of your personal data, please contact us at:

Data Governance Team

JD Williams and Company Limited trading as N Brown

Griffin House

40 Lever Street

Manchester M60 6ES

informationrequest@nbrown.co.uk

Tel: 0161 2382123

If you are at all dissatisfied with the information provided by the Data Governance Team, please address any complaints to the Data Protection Officer at the same address.

Your Personal Data Rights

Right of Access+

You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request.  You can do so by ringing, writing to or emailing the Data Governance team. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days.  However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time that we have validated your identity.

Please be aware that for security reasons we do not usually provide details of any bank details that we hold against your account(s).  Please speak to our Data Governance team should you need this additional information.

Right of Rectification+

If you believe we have made an error as to the personal data we hold about you, please speak to one of our customer service advisors on 0345 071 9018 who will be able to process the correction for you.  Alternatively, you can visit My Account to update your contact details online.  Should you wish to discuss this matter further, please contact the Data Governance team

Right of Erasure+

You have the right to request your personal data to be permanently deleted from our records and systems to avoid any further communication with you.  Your request will always be considered in light of the legal bases that we hold, store and process your personal data and the purpose that we collected your data.  Where the legal bases permits, we will carry out your instruction without undue delay.  Please note, however, that where we have a legal or contractual obligation to hold your personal data, we may not be able to carry out your request but we will explain this fully to you.  Please address any request to delete your data to the Data Governance team.

Right to Restrict Processing+

Should you believe that we are processing your personal data in a way that you did not understand or agree to and wish to restrict such processing, please speak to the Data Governance team who will be able to assist you.

Right to Object to Processing+

You have the right to object to certain types of processing of your personal data.  We will always make it clear at the outset of any new arrangement with you how we are going to process your personal data.  Should you wish to object to such processing, particularly concerning Automated Decisioning and Profiling, we will give you the option to opt out on application.  However, should you wish to discuss this matter further, please speak to the Data Governance team.   

Right to Portability+

In the event that you wish to move your personal data that we hold on you to another organisation in the form of an excel or csv format, please contact the Data Governance team who will be able to assist you.

Right to be Informed+

You have the right to be informed about the collection and use of your personal data. This is commonly known as a 'privacy statement' or 'privacy policy'. We will provide you with the information about how we collect and use your data in various means, such as by 'just in time' notice provided to you at the time of collecting your personal data and via this Privacy Policy.  Our Privacy Policy is regularly reviewed in line with our business processes.  Any changes to this Privacy Policy will be communicated via email and credit account statements to all active customers.  We will also advise customers of changes when ringing the call centre via a recorded message.  You can ask for a printed copy of our Privacy Policy by contacting the Data Governance team.

Right to Complain to the Information Commissioner's Office (ICO)+

You have a right to lodge a complaint with the Information Commissioner's Office (ICO) if you have a complaint with how you believe your personal data has been handled.  For more information, please visit https://ico.org.uk/concerns

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