- 1. Introduction
- 2. Purpose of this Privacy Notice and Changes to this Privacy Notice
- 3. Who We Are and the Personal Information that We Collect From You
- 4. How is your personal data collected?
- 5. How we use your personal data
- 6. Sharing Your Information
- 7. Transfers Outside of the UK and Europe
- 8. Data Security
- 9. Your Rights
- 10. How Long We Will Keep Your Information
- 11. Marketing
- 12. Opting-Out
- 13. Contact Information
Welcome to M&Co’s loyalty card privacy notice. M&Co 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 when you sign up and use your loyalty card and tell you about your privacy rights and how the law protects you.
Any questions relating to this policy and our privacy practices should be sent to our Data Protection Officer by emailing firstname.lastname@example.org.Back to top
2. Purpose of this Privacy Notice and Changes to this Privacy Notice
This privacy notice aims to give you information on how M&Co collects and processes your personal data through your use of the loyalty card. It includes information that you provide when you sign up for a loyalty card, fill in forms and use your loyalty card when purchasing items. o:p>
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.
The loyalty card is not intended for children and we do not knowingly collect data relating to children.Back to top
3. Who We Are and the Personal Information that We Collect From You
We are M&Co Trading Limited trading as M&Co (Company Number SC662082) (“we”, “our” and “us”). We are data controller of any personal data that you provide us.
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 the following kinds of personal data about you:
- - Identity Data: includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
- - Contact Data: includes [billing address, delivery address, email address and telephone numbers].
- - Financial Data: includes [bank account and payment card details].
- - Loyalty Card Data: includes [your loyalty card account details, number of points and points usage].
- - Transaction Data: includes [details about payments to and from you and other details of products and services you have purchased from us].
- - Profile Data: includes [your loyalty card number, purchases or orders made by you, your interests, preferences, feedback and survey responses].
- - Marketing and Communications Data: includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
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.Back to top
4. 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:
- - apply for our products or services;
- - create a loyalty card account in store or online;
- - subscribe to our service or publications;
- - request marketing to be sent to you;
- - enter a competition, promotion or survey; or
- - give us some feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties as set out below:
- - Data from advertising networks
- - Data from search information providers;
- - Contact, Financial and Transaction Data from providers of technical, payment and delivery services and
- - Identity and Contact Data from data brokers or aggregators
If you place an online order with us, to ensure that your credit, debit or charge card is not being used without your consent, we will validate name, address and other personal information supplied by you during the order process against appropriate third party databases. You acknowledge that such checks will be made. In performing these checks personal information provided by you may be disclosed to a registered Credit Reference Agency which may keep a record of that information. You can rest assured that this is done only to confirm your identity, that a credit check is not performed and that your credit rating will be unaffected. All information provided by you will be treated securely and strictly in accordance with applicable data protection legislation.Back to top
5. 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; and
- - Where we need to comply with a legal or regulatory obligation.
We usually do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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.
Generally, we need your information and use the information we collect about you:
- - to enable us to supply you with products and services that you have requested;
- - to help us with understanding more about how our Loyalty Card is used;
- - to be able to send you communications that may be of interest to you, either electronically or otherwise;
- - to prevent fraudulent activity;
6. Sharing Your Information
The information you provide to us will be treated by us as confidential and will be processed only by our employees within the UK/EEA. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, [including payment providers and marketing suppliers].
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.
We may disclose your information to third parties in the event that we sell or buy any business or assets during a re-structuring, in which case, we may disclose your personal data to the prospective seller or buyer of such business or assets and/or if M&Co or substantially all of its assets are acquired by a third party, in which case, personal data held by it about our customers will be one of the transferred assets.Back to top
7. Transfers Outside of the UK and Europe
Your information will only be stored by M&Co within the UK and EEA however suppliers we use may store data outwith 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:
1.1.1 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.
1.1.2 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.
1.1.3 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 the 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.Back to top
8. 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. 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.Back to top
9. Your Rights
You have the right at any time to:
- - Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it.
- - Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- - Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- - Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- - Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- - Request the transfer of your personal information to another party.
- - Withdraw your consent to the processing of your personal information at any time.
If you wish to exercise any of the rights set out above, please email email@example.com
You 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.Back to top
10. How Long We Will Keep Your Information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
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.Back to top
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Loyalty 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 products from us, registered for a loyalty card or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receiving that marketing.
We will also get your express opt-in consent before we share your personal data with another company.Back to top
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 purchase, product experience or enquiry.Back to top
13. Contact Information
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice.
If you have any questions or suggestions about this privacy notice, including any requests to exercise your legal rights or if would like to make a complaint, please contact the Data Protection Officer using the details set out below.
Postal address: M&Co Customer Services Team
5 Inchinnan Drive
Inchinnan, PA4 9AF
Email Address: firstname.lastname@example.orgBack to top