Privacy Policy

Senator International Limited Privacy Policy

Last updated October 2020

–   Introduction

–   Who we are and how to contact us

–   How we collect your personal information

–   The types of information we collect

–   Ensuring your personal information is only used where lawful

–   Why we collect your personal information and how we use it

–   The Privacy and Electronic Communications Regulations (PECR)

–   Sharing your information

–   Business Administration and Legal Compliance

–   How can I unsubscribe from marketing communications?

–   How long do we keep your personal information for?

–   Confidentiality and security of your personal information

–   How to access your information and your other rights

–   Changes to this Privacy Policy

Introduction

Senator International Limited is committed to protecting your personal information. It’s your information, and we respect that. Our Privacy Policy gives you detailed information on when and why we collect your personal information, how we use it and how we keep it secure. This Policy also sets out your right to request that we delete, update, transfer or provide you with access to your personal information. This Policy should be read alongside our Terms & Conditions.

Who we are and how to contact us

We are Senator International Limited (company registered number 01323955), whose registered office is at Syke Side Drive, Altham Business Park, Accrington, Lancashire, BB5 5YE.

Senator International Limited is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: Z7485695.

How we collect your personal information

Generally, we collect your information when you decide to interact with us. This could include purchasing online, over the phone or in person or when you sign up to receive emails from us. We also process information about how customers use our website, so that we can offer the best possible experience.

We collect information in a number of ways, examples of which are listed below:

• When you register or use our website (www.thesenatorgroup.com);
• When you contact us by telephone or email;
• When you sign up to receive marketing newsletters;
• When completing any surveys that we send to you for research purposes (although you are under no obligation to complete these);
• When completing any forms for transactional or other purposes;
• When you buy products or services from us;
• When you use or are a customer of any of our other services or offerings;
• When you visit our website.

The types of information we collect

We only collect the information that’s necessary to carry out our business, provide the particular service you’ve requested and to keep you up to date about all the latest exciting Senator Group news.    

Information we obtain directly from you

Here are some examples of information we collect about you when you interact with us:

• Title
• Name and Surname
• Email address
• Date of Birth
• Contact phone number(s)
• Purchase information (Including items and prices)
• Interactions with us e.g. contacting our Customer Service, visitors logs
• Delivery address(s)
• Billing address
• Health and disability information
• Attendance at events
• Preferred store, categories and brands
• Appointment booking and information given during appointments
• Alterations and repair requests
• Content of correspondence / messages
• Information obtained through automated technologies or interactions.  If you interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns.

Information we obtain independently from you:

• Your information may be shared with us by independent organisations, for example other organisations that we have worked with. These independent organisations will only do so when there is a lawful basis to do so. You should check their Privacy Policy when you provide your information to them, to understand fully how they will process and safeguard your data. These independent organisations may include:

• Third Party Organisations – We may combine information you have given to us with additional information made available from / shared with us by external sources. This will only be done when we both have a lawful basis to do so.

• Information updates – From time to time we may screen our database against recognised data files, such as the National Change of Address file, to help us keep our database up to date.

Ensuring your personal information is only used where lawful

In order for our use of your personal information to comply with applicable data protection law, that use by us needs to fall under at least one of the specific lawful reasons that are set out in applicable data protection law.

We will only use personal information when the law allows us to. Most commonly, we will use personal information in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with users and customers.
• Where we need to comply with a legal obligation.
• 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.
• Where we have obtained your consent (for example to send third party direct marketing communications to you via email or text message). You have the right to withdraw consent to such marketing at any time.

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Why we collect your personal information and how we use it

At Senator International Limited, we like to get to know our customers – after all, this is how we find new ways to provide you with an amazing experience. We use information about you in a number of ways, including providing the services that you have requested, offering you a personalised experience and informing you about exclusive events or exciting brand news. We might also use the information we have to contact you about any information we might need to process your orders, returns or queries.    

Examples of how we use your data are as follows:

To carry out our business and to provide a service or carry out a contract with you.

• Fulfilment of, and delivery of, products and services you have ordered. We may share your personal information with our delivery partners and third-party concessions.
• Process payments. Senator International Limited does not store any payment card numbers once the transaction has been completed. We share your personal information with credit card companies and other payment providers and acquirers. These third parties will be responsible for the handling of your personal data for these purposes and their privacy policies will set out how they do this.
• Contact you with important information relating to an enquiry or purchase, or use and administration of any of our services, such as confirming your order, letting you know about returns and refunds and any information in relation to that service. We may share your information with our communication partners for this purpose.

Where we have your consent:

• Send you marketing updates via email about all the latest news, events and offers at Senator International Limited. You can unsubscribe at any time by clicking the unsubscribe link in any email. We share your personal information with a variety of third-party email marketing providers who assist us in delivering our email marketing campaigns to you.

• We will use any health and disability information provided to ensure that an order is relevant to your needs and that any special requirements relating to delivery and installation are acted upon.

Where we have justifiable reason (legitimate interest):

• Respond to customer service enquiries raised in the showroom, online, social media or on the phone.
• Send a welcome, abandoned basket or wish list email via third party suppliers.
• Invite you to provide feedback about our products and services in the form of online, email, or in-store surveys. We use this information to help us improve the quality of service provided; to monitor the quality of our products and services and to assist with the selection of future product and service lines.
• Conduct postal marketing. We may share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.
• Analyse aggregated customer information with other interactions customers have in order to continually improve the products and services we offer.  We do this using third parties such as Google Analytics and Microsoft Dynamics.
• For classifying our audience into groups or segments, using shopping habits information regarding your personal or professional interests, demographics, experiences with our products and contact preferences. These segments help us to understand our customers better. We do this using Customer Relationship Management systems.
• Measure and understand how our customers respond to our website and to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective.
• Detect and reduce fraud and credit risk.   

The Privacy and Electronic Communications Regulations (PECR)

Where we have collected your contact details in our showrooms in the process of a sale (or negotiations of a sale) of a product or service, we may send you marketing updates via email. We will only send you marketing updates about our products and services.

You will be able to say no to receiving these emails when we first collect your contact details and you will be able to unsubscribe in every subsequent communication from us or at any time by contacting us.

Sharing your information

We use third party platforms to manage and deliver customer relationship management (CRM); email marketing campaigns; online advertising; customer analytics; events; booking of appointments; fulfilment of orders; delivery; returns; refunds; IT services; etc. In providing the services, your personal information will, where applicable, be used by the service provider on our behalf.

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal information. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal information and their compliance with our data security standards and international transfer restrictions.    

Business Administration and Legal Compliance

In certain circumstances, we share and/or are obliged to share your personal information for business administration and legal compliance purposes with third parties outside Senator International Limited.

We may use your personal information in connection with a business transition (such as a merger, acquisition by another company, or a sale of all of or portion of our assets), to enforce our legal rights and/or to protect the rights of third parties and it is in our legitimate interest to do so.  It may be necessary to share your personal information with external professional advisors such as lawyers and accountants, or insurers or financial institutions.

We may use your personal information for legal compliance purposes and to enforce our legal rights. In such instances it will be necessary to share your personal information with external parties such as administrative authorities (HMRC), the Financial Conduct Authority, police and public prosecutors or to comply with a court order. We may also use your personal information to undertake customer checks to know our customers and verify their identity. We will use your information to conduct online searches to assist us with meeting our legal requirements. We may also be required to share your information to report any suspicious and/or criminal activity including fraud, sanctions infringement and money laundering. It is our legal obligation to do so.

How can I unsubscribe from marketing communications?    

If at any point you do not wish to hear from us there are a number of ways you can unsubscribe.

• You can click on the “unsubscribe” link in any communication that we send to you by email which will automatically unsubscribe you from that type of communication. Each “unsubscribe” link only relates to that specific type of communication (e.g. general marketing communications, specific marketing or survey communications. This means that unsubscribing from general marketing communications will not automatically unsubscribe you from specific marketing or our survey communications (or vice versa). Please also note that you may continue to receive communications which are already on their way to you for a short period of time while your relevant unsubscribe request is being processed.

• Alternatively, you may contact our customer service team by calling 01282 725000 Monday to Friday: 9am-5pm or by contacting us by email at Sales@thesenatorgroup.com

How long do we keep your personal information for?

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available upon request. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We do not sell your personal information for any purpose.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access
• improper use or disclosure
• unauthorised modification
• unlawful destruction or accidental loss

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are contractually obliged to respect the confidentiality of the personal information of all users of our services.    

How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:    

• Your right of access

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to correct information

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it corrected. If we’ve shared your personal information with others, we’ll let them know about the changes where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to delete information

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict information

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are: Relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or Processing your personal information for direct marketing.

• Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

• Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required, to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.