We are committed to complying with the Data Protection Act 1998 and the EU General Data Protection Regulation 2018 for the purposes of data protection and privacy.
We are registered as a data controller under the terms of the Data Protection Act 1998 and the EU General Data Protection Regulation with the UK Information Commissioner's Office. Details of our registration may be found at https://ico.org.uk/ESDWebPages/Entry/Z5035514.
Legal basis for collection of data
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
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.
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.
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 Beards to law enforcement.
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 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 may 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.
When do we collect your personal data?
- When you visit our website and use your account to buy products and services, or redeem vouchers from Beards on the phone, in a shop or online.
- When you create an account with us.
- When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask one of our staff members to email you information about a product or service.
- When you enter prize draws or competitions.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. If your comment or review includes information about the staff member who provided that service, it may be passed on to them if requested.
- When you fill in any forms. For example, if an accident happens in store, a staff member may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
- When our finance suppliers and partners – such as Novuna Personal Finance– share information with us about the product you have purchased.
- We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law.
- When you use our shops which usually have CCTV systems operated for the security of both customers and staff. These systems may record your image and audio during your visit.
What sort of personal data do we collect?
- If you have an online account with us: your name, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
- Details of your interactions with us through in store or online.
- 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.
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your shopping preferences.
- For example, which of our shops you prefer to visit and where you redeem your vouchers.
- Details of your visits to our website and which site you came from to ours.
- Payment card information.
- Your comments and product reviews.
- Your image and audio may be recorded on CCTV when you visit a store.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Learn more about this.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
How and why do we use your personal data?
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.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
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.
For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. 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.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website. We’ll do all of this as part of our legitimate interest. 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.
- To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our stores which record images and audio for security. We do this on the basis of our legitimate business interests.
- We record telephone calls to our stores for training and monitoring purposes.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
- With your consent, 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. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. 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 are having
- To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across Beards, third parties and data from publicly available lists. We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you.
- To process your booking/appointment requests (for example, with a jewellery designer). Sometimes, we’ll need to share your details with a third party who is providing a service. We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
- Help inform business decisions for example which 3rd Party websites we partner with to ensure our advertising reaches our customers
Across Beards, 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 Beards 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.
How do we protect your personal data?
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 website 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.
How long will we keep your personal data?
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:
When you place an order, we’ll keep the personal data you give us indefinitely so we can comply with our legal and contractual obligations.
If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
Who do we share your personal data with?
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:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
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 website.
- Data insight companies to ensure your details are up to date and accurate.
How we use your personal data:
When you purchase a product using interest-free credit option, we might receive a copy of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you. You are free to opt out of receiving marketing communications from us at any time.
How our providers use your personal data
When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies.
Here are those individual privacy policies (all links open in a new window; please note we can't be responsible for the content of external websites):
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
For further information please contact us.
To help personalise your journey through Beards website we currently use the following companies, who will process your personal data as part of their contracts with us:
Where your personal data may be processed
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.
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 Beards 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 us.
What are your rights over your personal data?
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
- Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
- That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You can contact us to request to exercise these rights at any time.
If we choose not to action your request, we will explain the reasons for our refusal.
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.
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
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.
How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Inform a member of staff in-store, by email or over the telephone.
- Click the ‘unsubscribe’ link in any e-newsletter communication that we send you. We will then stop any further emails.
- Write to Beards, Sandringham House, 70 The Promenade, Cheltenham, Gloucestershire, GL50 1NA.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Contacting the Regulator
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
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.
If you live outside the UK
For all non-UK customers
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 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 that haven’t been covered, please contact us and we will be pleased to help you:
Email us at: firstname.lastname@example.org
Or write to us at Beards, Sandringham House, 70 The Promenade, Cheltenham, Gloucestershire, GL50 1NA
This Policy was last updated on 29/10/2019