Privacy and Cookie Policy

WHO ARE WE?

We are Willow & Hall Ltd. Our Head Office address is 3 Oriel Court, 106 The Green, Twickenham, TW2 5AG. You can contact us by post at the above address or by telephone on 020 8939 3800. We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

WHEN YOU USE OUR WEBSITE

When you use our website to browse our products and services and view the information we make available, a number of cookies are used by us and by third parties to allow the website to function, to collect useful information about visitors and to help to make your user experience better. Some of the cookies we use are strictly necessary for our website to function, and we don’t ask for your consent to place these on your computer.

WHAT ARE COOKIES ?

Cookies are very small text files stored on your computer when you visit certain web pages. Most websites you visit will use these text files in order to improve your user experience by enabling that website to 'remember' you, either for the duration of your visit (using a 'session cookie') or for repeat visits (using a 'persistent cookie').
Cookies do lots of different jobs but overall they are used to make the interaction between you and the website faster and easier. If a website doesn't use cookies, then for example, if you have an account and have logged in and move to another page it won't recognise you and it won't be able to keep you logged in.

OUR COOKIES POLICY

Our cookies can’t harm your computer and they don't store sensitive information such as your name. They are only used by us so we can improve your experience of our site. To make full use of the online shopping and personalised features on www.willowandhall.co.uk, your computer, tablet or mobile phone will need to accept cookies. By visiting our website we assume that you consent to the use of cookies as outlined above. However, if you'd prefer to restrict, block or delete cookies from www.willowandhall.co.uk you can use your browser to do this. Each browser is different, so check the 'Help' menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences.

MORE INFORMATION ON COOKIES

If you would like further information on cookies then the following websites might be of help:

- The Information Commissioner's Office (ICO)
- Aboutcookies.org
- Cookie Central

WHEN DO WE COLLECT PERSONAL DATA FROM YOU ?

- When you purchase a product or service
- When you order a fabric sample, product information card or digital download
- When you apply for a trade account with us
- When you sign up for our email newsletter
- When you engage with us on social media
- When you contact us by any means
- When you enter prize draws or competitions
- When you comment on or review our products and services
- When you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, patterns and the website that referred you to www.willowandhall.co.uk. We collect this personal data by using cookies, server logs and other similar technologies. Technical Data is collected from the following parties: analytics and search information providers. No personally identifiable information is obtained
- When you've given a third-party permission to share with us information they hold about you

PERSONAL DATA WE MAY COLLECT FROM YOU

Personal data 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

- Identity Data - including first name, last name, title
- Contact Data - including billing address, delivery address, email address, telephone numbers. We will also collect your social media username, if you interact with us through those channels
- Financial Data - including bank account and payment card details
- Transaction Data - including details about payments to and from you and other details of products you have purchased from us
- For our website we collect Technical Data including internet protocol (IP) address, 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 including purchases or orders made by you, your interests, preferences and feedback responses
- Usage Data including information about how you use our website. This includes information gathered by the use of cookies in your web browser
- Marketing and Communications Data includes your preferences in receiving marketing from us
- 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 function or 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

SPECIAL CATEGORIES OF PERSONAL DATA

We do not collect any Special Categories of Personal Data about you. Nor do we collect any information about criminal convictions and offences.

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 product or service you have with us, but we will notify you if this is the case at the time.

WHEN YOU PURCHASE A PRODUCT FROM US

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. This includes www.mention-me.com who provide and operate our referral marketing programme, processing customer email addresses and certain order data for the purposes of: Enrolling customers onto our refer-a-friend programme; monitoring the programme and safeguarding against gaming or fraudulent use of the programme; communicating with customers in connection with operation of the programme and delivery of rewards; and reporting on the performance of the programme

- Where we need to comply with a legal or regulatory obligation

- 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)

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

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide some services you asked for.

EXAMPLES OF HOW WE USE INFORMATION HELD ABOUT YOU INCLUDE:

- To process any orders that you make. If we don't collect your personal data during order processing, we won't be able to process and deliver your order and comply with 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 and guarantees
- To respond to your queries or after sales support. Handling the information you send 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. We do this on the basis of our contractual obligations to you, our legal obligations
- 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
- To listen to recorded telephone conversations for internal staff training
- To send you relevant communications by email or post in relation to updates, products and services. We'll do this on the basis of our legitimate business interest. You can choose opt out of hearing from us by email or post at any time
- To manage any of our competitions which you enter
- 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
- To comply with our contractual or legal obligations to share data with law enforcement
- To send you 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 understand who you are and your interests, and to inform our business decisions, we will combine data captured by Willow & Hall, third parties and data from publicly-available lists as we have described in the section 'Personal Data we collect from you

HOW WE USE YOUR DATA

We may have to share your personal data with selected third parties as outlined in "When you purchase from us".

EXAMPLES OF THE TYPES THIRD PARTIES WE WORK WITH ARE:

- Manufacturers or suppliers
- Companies who support our website
- Delivery couriers
- Google and Facebook to show you products that might interest you while you're browsing the internet. We'll also use your data to identify other internet users who share similar interests. This is based on your acceptance of cookies on our website.
- Insight and analytical companies to ensure your details are up to date and accurate
- We may also share certain limited information with companies who assist us with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our 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

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.

TO PROTECT YOUR PRIVACY, WE WILL:

- Only provide the information necessary to perform their specific services
- Only use their data for the exact purpose we specify in our contract with them
- Work closely with them to ensure your privacy is respected and protected at all times

STORING YOUR DATA

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
- The applicable legal requirements. For example, if your order included a product guarantee, the associated personal data will be kept until the end of the guarantee period

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for such as of satisfying any legal, accounting, or reporting requirements.

At the end of that retention period, your data will either be deleted completely or anonymised.

YOUR RIGHTS AS A DATA SUBJECT

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

To submit a request regarding your personal data by email, post or telephone, please use the contact information provided above in the "Who Are We" section of this policy.

YOUR RIGHT TO COMPLAIN

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Information Commissioners Office via their website at www.ico.org.uk/concerns or write to them at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

SECURITY

We realise how important it is to securely store any information that you provide and continually seek to ensure it is maintained to the highest levels of security. We take technical, physical, and organisational precautions and have procedures to keep your data secure including the use of high-level SSL encryption technology - the most advanced security software currently available for online transactions ensuring the details you provide us are protected to the highest of standards. You can tell that our page is secure as 'https' will replace the 'http' at the front of www.willowandhall.co.uk in your browser address window as soon as you begin to checkout.

UPDATES TO THIS PRIVACY POLICY

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven't previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.

We will update the version number and date of this document each time it is changed.

Cookies and Privacy Policy 22/05/2021