Pavestone 2023 E-Flip Brochure
Posted on 05-04-2023
Converting your conservatory into an extension
Privacy Policy
PRIVACY NOTICE – BROWNS BUILDERS MERCHANTS LIMITED
Introduction
Welcome to Browns Builders Merchants Limited’s privacy notice.
Browns Builders Merchants Limited respects your privacy and is committed to protecting your
personal data. This privacy notice will inform you as to how we look after your personal data and
tell you about your privacy rights and how the law protects you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
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. GLOSSARY
1. IMPORTANT INFORMATION AND WHO WE ARE Purpose of this privacy notice
This privacy notice aims to give you information on how Browns Builders Merchants Limited collects
and processes your personal data through your use of http://www.brownsbm.co.uk and any data you may
provide when you register as an account holder, purchase products from us, sign up for our
newsletters, submit enquiries or give us feedback.
Our website is not intended for children and we do not knowingly collect data
relating to children.
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
Browns Builders Merchants Limited is the controller and responsib rsonal data
(collectively referred to as "we", "us" or "our" in this privacy notice).
We have appointed a data protection co-ordinator 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 our data protection co-ordinator using the
details set out below.
Contact details
Our full details are:
Full name of legal entity: Browns Builders Merchants Limited, a private limited company with
registered number 02478452
Data protection co-ordinator: Neal Myers Email address: neal.myers@brownsbm.co.uk
Postal address: 123 Old Nottingham Road, Derby, Derbyshire, DE1 3QQ
We hope that we can resolve any query or concern you raise about our use of your information. We
would appreciate the chance to deal with your concerns in the first instance. However, 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).
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in March 2019 and historic versions can be obtained by
contacting us.
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 follows:
• Identity Data includes first name, maiden name, last name, gender and date of birth.
• Contact Data includes billing address, delivery address, email address and telephone
numbers.
• Financial Data includes bank account and payment card details, and
credit information.
• Transaction Data includes details about payments to and from you and other details of
products you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to access our website.
• Profile Data includes purchases or orders made by you, your interests, preferences,
feedback and survey responses.
• Usage Data includes information about how you use our website, products and
services.
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
If you are opening a credit account with us, we may require different kinds of personal data from
your directors and/or shareholders. This is so that we may perform reference checks on the owners
and people in charge of our customer. Click here to find out more about how we use your personal
data.
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.
We do not collect any 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, trade union membership, information about your health, and genetic
and biometric data). Nor do we collect any information about criminal convictions and offences.
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). In this case,
we may have to cancel an order you have placed 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 or otherwise. This includes
personal data you provide when you:
• Register as an account holder;
• Purchase products from us;
• Subscribe to our newsletters;
• Request marketing to be sent to you;
• Participate in our competitions or promotions; or
• 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. We may
also receive Technical Data about you if you visit other websites employing our cookies. Please
click here for further information.
• Third parties or publicly available sources. We may receive personal data about you
from various third parties and public sources as set out below:
• Identity, Contact and Financial Data from credit reference agencies such as Experian
based inside the UK and/or the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and
delivery services such as PayPal based outside of the UK and the EU;
• Identity and Contact Data from publicly availably sources such as Companies House and
the Electoral Register based inside the UK and/or 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:
• 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 (or those of a third party) and your
interests and fundamental rights do not override those interests; or
• Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your
personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than
in relation to:
• Carrying out credit searches before registering you as a credit account holder;
• Sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground
has been set out in the table below.
Purpose/Activity Type of data Lawful basis for
processing
including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To register to you as a new account holder
(a) Identity
(b) Contact
(c) Financial
(a) Performance of a contract with you
(b) Necessary to our legitimate interests (for accounts purposes and to ensure we
allocate a suitable credit limit to you)
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to
study how customers use our products/services)
To administer and protect our business and our website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to prevent fraud
and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand
the
(a) Identity
(b) Contact
Necessary for our legitimate interests (to study how customers use our
products/services, to
effectiveness of the advertising we serve to you
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers
for our products and services, to keep our website updated and relevant, to
develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of
interest to you
To facilitate the
procurement and organisation of supplies made by third parties to
process and deliver your order
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(a) Identity
(b) Contact
Necessary for our legitimate interests (to develop our
products/services and grow our business)
Performance of a contract with you
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. You can ask us to stop sending marketing messages at any time by
contacting us.
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, services 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 or services from us and, in each case, you have not opted out of receiving that
marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
Our newsletters are distributed using an External Third Party (as set out in the Glossary). When
you sign up to receive our newsletters we will require the following information:
• Your name and address;
• Your email address;
• Your telephone number; and
• The types of products you would like to hear about.
We will rely on your consent to provide you with the newsletters or updates you have requested and
retain your details on our subscriptions database.
Without your contact details, we will not be able to provide you with newsletters and updates.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time
by contacting us at any time.
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/service purchase, warranty registration, product/service
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 our website may
become inaccessible or not function properly. For more information about the cookies we use, please
see our cookies policy at http://www.brownsbm.co.uk.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with
the original purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above:
• External Third Parties (as set out in the Glossary); and
• Third parties to 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.
We require all third parties to respect the security of your personal data and to treat
it in accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the EEA so their processing of
your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree
of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
• We will only transfer your personal data to countries that have been deemed to provide
an adequate level of protection for personal data by the European Commission. For further details,
see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in Europe. For
further details, see European Commission: Model contracts for the transfer of personal data
to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part
of the Privacy Shield which requires them to provide similar protection to personal data shared
between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed, such as the
implementation of appropriate security measures to protect our IT infrastructure. In addition, we
limit access to your personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on our instructions and
they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as 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.
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 request erasure below for further
information.
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. Please click on the links below to find out more about these rights:
• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw 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. GLOSSARY LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most secure experience.
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). You can obtain
further information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before entering
into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
We employ other companies to perform functions on our behalf such as:
• Service providers acting as processors based inside and outside the EEA.
These services may include fulfilling orders for products, providing customer relationship
management, marketing assistance and supporting our website and IT functionality.
Our service providers include:
• Microsoft, for services such as Outlook; and
• Mailchimp, who we use to distribute our newsletters.
These service providers may be supplied with or have access to your personal data solely for the
purpose of providing these services to us on our behalf. Browns Builders Merchants Limited is the
data controller and will remain accountable for your personal data.
• Professional advisers acting as processors or joint controllers including
lawyers, bankers, auditors and insurers based inside the EEA who provide consultancy,
banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom who require reporting of processing activities in certain
circumstances.
YOUR LEGAL RIGHTS
You have the right to:
• Request access to your personal data (commonly known as 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 the personal data that we hold about you. 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 the
right to ask us to delete or remove your personal data 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 local
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 (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel it 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 in the following scenarios: (a) if you want us to
establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to
erase it; (c) 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 (d) you have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, 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 or services to you. We will advise you if this is the case at the time you withdraw your
consent.
Browns Builders Merchants Limited
VAT No. GB 780620828