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Welcome to the Smiths-Briten’s privacy note. Smiths-Briten is a trading division of Bathroom Distribution Group UK Ltd. The privacy policy forms part of our website terms. Please take time to read our policy to understand how we treat your personal information.

Welcome to Smiths Briten’s privacy note.

Smiths Briten is a member of Bathroom Distribution Group UK Ltd (BDG)

Smiths Briten and BDG respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data whenever that information is provided to us. This includes when you, or your business, request information from us, contact us (or we contact you), apply to set up an account with us, purchase goods or services from us, use our website(s)/apps, connect with us via social media, link to or from our website(s)/apps, or any other engagement we have with you (regardless of where you are based). It also tells you about your privacy rights and how the law protects you.

This policy should be read in conjunction with our applicable terms and conditions of website use and our cookie policy.

Click here to view the Terms and Conditions of Use for Trade.

Click here to view the cookie policy

This privacy notice is provided with links so you can click through to the specific areas set out below. Alternatively,  download a pdf version here Smith-Briten-Privacy-Policy-Jan-2021-pdf

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. MONITORING

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how BDG collects and processes your personal data in our dealings with you, including in providing goods and services to you, and including any data you may provide through this our website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

CONTROLLER

BDG is the controller of your personal data and responsible for our website. BDG are part of Grafton Group Plc. Current members of the group can be found here www.graftonplc.com

Grafton Group has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 

The Data Protection Officer

Grafton Group plc
2 Wythall Green Way
Wythall
Birmingham
B47 6LW

01564 821600

DPO@graftonplc.com

You have the right to make a complaint at any time to the relevant supervisory authority. In the UK this is the Information Commissioner’s Office (ICO) (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority (ICO), so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This privacy notice was last updated Jan 2021.

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.

 

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

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

In the normal course, we will not collect Special Categories of Personal Data about you. Criminal offences may, however, appear on credit references or anti-fraud checks we may make.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, 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 or services). In this case, we may have to cancel a contract you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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, via this website, apps or on social media, or otherwise. This includes personal data you provide when you or your business

  1. subscribe to our newsletter and/or other publications;
  2. request a brochure or other promotional or marketing materials to be sent to you/your business;
  3. apply for, or operate, a credit or cash account with us;
  4. purchase goods [and/or services] at one of our stores;
  5. purchase goods [and/or services] via our website;
  6. attend a hospitality event;
  7. enter a competition, or respond to a promotion or survey;
  8. give us some feedback.

Automated technologies or interactions. As you interact with our website, we may 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. Please see our cookie policy for further details. 

Third parties and publicly available sources. We may receive personal data about you from various third parties and public sources including:

  1. Credit reference  agencies, Solicitors, Insurers/Brokers and fraud prevention organisations such as Graydon,  Silverback Law, QBE & TopService.  When     you or your business in which you are a partner or a director makes an application for a credit account with us, we will or may make searches  about you with credit reference agencies and fraud prevention organisations. [Searches are made against addresses provided, and so may also return  information relating to other household members.] The relevant agencies/organisations will keep a record of that search and will share information from their records with us and with other business assessing  applications for credit and to prevent fraud. We will record information  as to your/your business’ trading history with us and share this  information with credit reference agencies and fraud prevention organisations. Should it become necessary to review a credit account, a further check with credit reference agencies [fraud prevention organisations] and Insurers may be made, and a record kept by them of the  search.
  2. Debt  collection and debtor tracing organisations such as Creative Credit  Services. Where your/your business’ debts are unpaid, we may share your  personal information with relevant debt collection and/or debtor tracing  agencies or Solicitors.
  3. Other businesses in the same or related sectors. As part of our credit referencing procedures we may make enquiries of other businesses in the same or related sectors as to your/your business’ trading history with them and  may share information as to your/your business’ trading history with us.
  4. Technical Data from analytics providers such as Google based outside the EU
  5. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay based inside the EU.
  6. Identity and Contact Data from publicly availably sources such as Companies House and  the Electoral Register based inside the EU.
  7. Contract and  Planning Applications data from publicly available sources including local authorities, ABI, Bravo Solutions, In-Tend, CCS, Housing Net,      Contract.Net, Forsee, based inside the EU. 

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:

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message;

You have the right to withdraw consent at any time by emailing marketing@smithsbriten.co.uk with your account number.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of 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.

When we refer to legitimate interests, we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

We do not currently undertake automated decision making using your personal data.

 

 

Purpose/Activity

Type   of data

Lawful   basis for processing including basis of legitimate interest

To respond   to an enquiry from you.

(a)   Identity
  (b) Contact

Necessary   to take steps at your request prior to entering into a contract with you.

To   undertake credit-referencing and anti-fraud checks in connection with   applications for and the operation of a credit account with us.

(a)   Identity
  (b) Contact
  (c) Financial
  (d) Transaction

Necessary   to take steps at your request prior to entering into a contract with you.

Necessary   for our legitimate interests in protecting our business from insolvent   customers and fraud.

Necessary   for means of substantial public interest (preventing fraud).

To provide goods and/or services to you, and to collect and recover   money owned to us

(a) Identity
  (b) Contact
  (c) Financial
  (d) Transaction

Performance of a contract with you

Necessary   for our legitimate interests (to operate our business and 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 for feedback

(a) Identity
  (b) Contact
  (c) Profile
  (d) Marketing and Communications
  (e) Usage

Performance of a contract with you

Necessary   to comply with a legal obligation

Necessary   for our legitimate interests (to keep our records updated and to study how   customers use our services)

[Your   consent (email/SMS marketing)]

To administer and protect our business including our website   (including troubleshooting, data analysis, testing, system maintenance,   support, reporting and hosting of data)

(a) Identity
  (b) Contact
  (c) Technical

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)

Necessary   to comply with a legal obligation

To deliver relevant website content to you [and measure or understand   the effectiveness/usability of our website

(a) Identity
  (b) Contact
  (c) Profile
  (d) Usage
  (e) Technical

Necessary for our legitimate interests (to study how customers use our   services, to develop them, to grow our business and to inform our marketing   strategy)]

 

 

 

 

To use   data analytics to improve our website, services, marketing and customer   relationships

(a)  Technical
  (b) Usage

Necessary   for our legitimate interests (to define types of customers for our

services,   to keep our website updated and

relevant,   to develop our business and to inform our marketing strategy)

To deal   with issues, complaints or disputes arising out of our relationship with   you/your business, and to prevent or detect crime, including fraud

(a)   Identity
  (b) Financial
  (c) Technical
  (d) Profile
  (e) Usage

To   establish, exercise or defend legal claims

To use data analytics to improve our website, services, marketing and   customer relationships (a) Technical

To use data analytics to improve our website, services, marketing and   customer relationships (a) Technical

To use data analytics to improve our website, services, marketing and   customer relationships (a) Technical

 

MARKETING/PROMOTIONAL OFFERS

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

Where you have agreed to receive it, 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 goods, services and offers may be relevant for you.

We will only share your personal data for marketing purposes in accordance with your preferences/consent.

You can ask us to stop sending you marketing messages at any time by registering on the website and linking your trade account then checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by emailing marketing@smithsbriten.co.uk

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 our our cookie policy.

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 email dpo@graftonplc.com

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. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the categories of parties set out below for the purposes set out in the table in paragraph 4 above.

Other companies in the Grafton Group based within either the European Economic Area or the United Kingdom involved in providing goods and/or services to you, whether directly or providing underlying infrastructure services.

Third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Where these third parties are our processors, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors 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. Some of the third parties mentioned above, for example many professional advisers and HM Revenue and Customs, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data.

6. TRANSFERS OF YOUR PERSONAL DATA

We may transfer your Personal Data outside of the United Kingdom to certain other recipients (other Grafton Group companies and our third-party service providers) who process your Personal Data on our behalf.

Where such transfers of Personal Data occur, we look to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

Please Contact us  if you want further information on the specific mechanism used by us when transferring your personal data.

 

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. Processors we appoint 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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different types of your personal data are available in our retention policy which you can request from us by dpo@graftonplc.com

In some circumstances you can ask us to delete your data: click here for more information on how to Request erasure.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

If you wish to exercise any of the rights set out above, please email dpo@graftonplc.com

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.

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 enable us to deal with your request or to speed up our response.

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 we have received a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS

You have the right to:

10. MONITORING

We may monitor and/or record:

(a) telephone calls;

b) transactions [and activities at all points of contact];

(c) web, traffic and activities

These are to ensure that we carry out your instructions accurately, for training purposes and to improve our services, and to ensure security and prevent fraud.

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SmithsBriten, PO Box 2125, Bolton, BL6 4WN

Sales Tel: 0845 634 4321
Fax: 0800 917 7143
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E-Mail: sales@smithsbriten.co.uk

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