This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how the H. S. Johnson uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across the H.S.Johnson to build a picture of you.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.
H. S. Johnson – which we’ll refer to as ‘the Partnership’ in this document. This Privacy Notice applies to international orders, but there are additional terms for certain countries which supplement this notice and take priority over any conflicting provisions.
For simplicity throughout this notice, ‘we’ and ‘us’ means the Partnership and its brands.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement .
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We will also send you direct marketing emails when you shop with us and do not choose to opt out - this is often called a 'soft opt in'
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
With your consent, or when you shop with us and do not choose to opt out from receiving our emails ('soft opt in') we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable in the UK.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us.
For example, which of our shops you prefer to visit and where you redeem your vouchers.
For example, you might tell us your size, which we’ll use to guide our suggested items. Or you might share information on your skin type which allows us to recommend appropriate brands and products.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.
Across the H. S. Johnson, we record your interactions with us e.g. looking at how often you might shop with us or how much you spend. We do this to create a profile on how you interact with the Partnership and, in turn, that can affect how we engage you. For example, if you shop with us regularly, then this can affect what offers and rewards you might receive from us. We rely on our legitimate interest to undertake this activity.
We do this to ensure we have a clear view of what you like and to ensure that you are rewarded appropriately, so that direct marketing or browsing on our websites is tailored to what your preferences. This also allows your receipts to be stored in your kitchen drawer on your online account, if you have one, even if you are shopping in our store. We may also use the information we collect via the consolidation of your spend to inform our business decisions. This is done either by anonymising your spend and analysing it as part of a “spend-trend”, statistical view, or working with our third party suppliers, such as Google.
When you purchase a product from us that is delivered by the manufacturer or supplier of said product, we will pass on your contact details so that they can deliver your purchased product. The same with regard to warranties provided by the manufacturer or supplier of the product you bought. For example, if you buy a washing machine from us we will pass your details to the supplier of the washing machine to ensure the delivery of the goods and to fulfil any supplier product guarantees. We do that to ensure that we fulfil our contractual obligations to you.
If the manufacturers or suppliers wish to pass your details to other third parties, or use it for other purposes, they must provide you with sufficient information about whom they share your personal data with, and for what purposes they intend to use it, and in some cases they may be required to ask for your consent to do so. If they do not provide you with that information or collect your consent, and you are worried that they may have shared your personal data with someone else, you are entitled to contact them directly for clarification.
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Partnership as described above, for example your shopping history with us. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
Orders
When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations. In the case of certain products, such as electrical and nursery items, we’ll keep the data for 10 years.
Warranties If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
We sometimes share your personal data with trusted third parties.
For example, delivery couriers,for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Direct marketing companies who help us manage our electronic communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
- Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
For example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.
To help personalise your journey through Partnership websites we currently use the following companies, who will process your personal data as part of their contracts with us:
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
International orders
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Partnership in the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
You have the right to request:
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration of an extended warranty.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
There are several ways you can stop direct marketing communications from us:
Write to H.S Johnson Registered office H.S.Johnson, 8 Anson Street, Rugeley, Staffordshire, WS15 2BB
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113. Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
For all non-UK customers
This Privacy Notice shall be provided in English, French, Spanish, Portuguese, Malay and Chinese languages. Should there be any conflict in the meanings between the English and translated version, the English version shall prevail. copies of foreign language versions are available from our Customer Services team.
By placing an order with the Partnership, browsing our website, including for analytics and website usage research, and/or agreeing to receive direct marketing electronic communications as described in this Privacy Notice and our Cookies Notice, you expressly consent to the processing of your personal data by us or on behalf of us. Of course, you still have the right to ask us not to process your data in these ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we may transfer your personal data to third parties located in the UK to your country of residence. You hereby expressly consent to such overseas use, transferring and disclosure of your personal data outside of your country of residence for such purposes.
We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your personal data other than for that part of the purposes as set out in this Privacy Notice and to adequately protect the confidentiality and privacy of your personal data.
We will ensure that any third parties only process your personal data in accordance with their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside. We do not actively take steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
If you have any questions, please contact our Data Protection Officer, and we will respond within your local timeframe response requirements. To complain about an alleged breach of this Privacy Notice or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.
Australia
For the purposes of this Privacy Notice, “personal data” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, or opinion is recorded in a material form.
We are committed to keeping your personal information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
If you are in Australia, you may submit a complaint to our Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive you may submit a complaint to the Office of the Australian Information Commissioner.
Canada
If you submit a request to stop direct marketing communications from us, it will take no longer than 10 days.
As your data may be transferred to third parties outside the country where you are located, local police or other enforcement, regulatory or Government bodies may have access to that data with or without the Partnership’s knowledge. The personal data we process may be accessed by persons within the Partnership, or our third party service providers, who require such access to carry out the purposes indicated in this Privacy Notice, or such other purposes as may be permitted or required by the applicable law. Personal data we collect is maintained primarily in the UK.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.
Malaysia
Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data Protection Act 2010 (“PDPA”).
If you are in Malaysia you may submit any questions, comments or complaints to our Data Protection Officer who will come back to you within 21 days.
South Korea
The transfer of data to enable the company to supply the goods or services a customer has requested can be deemed as a Delegation.
Singapore, Qatar
Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).
By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.
