Marshalls Commercial Privacy Policy

We are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our policies and practices regarding your personal data and how we will treat it.

This privacy policy is issued by and on behalf of the Marshalls group of companies. The Marshalls group of companies is made up of different legal entities, including Marshalls plc (registered number 05100353), Marshalls Group Limited (registered number 481574), Marshalls Mono Limited (registered number 509579) and CPM Group Limited (registered number 1005164), each of whose registered office is at Landscape House, Premier Way, Lowfields Business Park, Elland HX5 9HT. When we say “Marshalls”, “the Company”, "we", "us" or "our" in this policy, we are referring to the relevant company in the Marshalls group of companies responsible for processing your data.

If you have any questions at all about the way we handle your personal data as set out in this policy, please contact the Data Protection Executive (“DPE”) for Marshalls, S. Sibal, at the above address, or by email to dataprotection@marshalls.co.uk. Our DPE represents the Marshalls Group as a whole, and any enquiries about how personal data is used by any Group entity should be directed to the DPE.
 

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on our site www.marshalls.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, request product samples or technical information, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, details of your property, technical specifications, details of your business activities, contact details for your employees, agents or contractors.

Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; 

information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. Information we receive from other sources. Where you have provided information or visited another of our websites, we may share that information across all the websites that we operate and combine it with information collected on this site. We are also working closely with third parties (including, for example, business partners, register members, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form at the point of entering your data, or advise us in writing at the address and/or the email given in this Policy (see “Your rights”);
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer or other device.

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer or other device; 
• to allow you to participate in interactive features of our service, when you choose to do so;
  as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
   

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any other member of the Marshalls group, which means Marshalls plc and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site. 
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We will only pass this information to a credit reference agency when we specifically tell you this. 

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If the company in the Marshalls group that is holding your personal information or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers and/or individuals with whom it has dealings in the course of its business will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Marshalls, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

OUR LEGAL BASIS FOR USING YOUR INFORMATION

We only use your personal information where that is permitted by the laws that protect your privacy rights. We only use personal information where:

• we have your consent (if consent is needed), for example your consent to send you marketing emails;
• we need to use the information to comply with our legal obligations (for example, recording footage of your visit to our premises using our CCTV system);
• we need to use the information to perform a contract with you (for example, where you have ordered goods or services from us or our business partners or where you are supplying goods or services to us or to a business partner of ours); and/or
• it is fair to use the personal information either in our interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services, or to use non-privacy invasive technologies.

Where we have your consent, you have the right to withdraw it.

Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations.

We will not collect or use any personal information of this kind.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Marshalls Mono Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We may need to transfer your personal information to territories that are outside the EEA. We will only transfer your personal information outside the EEA where either:

• the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or
• we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal information is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your data.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will never retain your personal information for any longer than is necessary for the purposes we need to use it for. We have a Document Retention Policy that explains how long data is kept for. If you would like to see a copy of this, please contact the DPE via email (dataprotection@marshalls.co.uk). In general terms:

• Where we have been using your personal information to provide you services, we will retain this information for a period of 7 years after the date you last used the service through our website.
• We may hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings.

YOUR RIGHTS

You are entitled to exercise any of the following privacy rights:

• Right to object: You can object to our processing of your personal information.  Please contact us as noted below, providing details of your objection.
• Access to your personal information: You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge by contacting us as noted below.
• Right to withdraw consent: If you have given us your consent to use your personal information to send you marketing emails, you can withdraw your consent at any time or by clicking the "unsubscribe" link in any marketing email which you receive.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
• Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

Please make all requests to exercise your privacy rights in writing to the DPE (dataprotection@marshalls.co.uk).  We are required to verify your identity in order to process your request and may ask you to provide valid identification documents to allow us to do so.

We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection law.

OUR USE OF COOKIES

A cookie is a piece of text, which asks permission to be placed on your computer's hard drive. Once you agree, your browser adds that text in a small file. A cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. Denial of a traffic log cookie should not prevent you from using this site, although it may restrict the use of certain features.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us. We know that people have concerns about cookies, but we believe that the benefit we both gain from their proper use is worthwhile. You may set your web browser to notify you of cookie placement requests or decline cookies completely. You can delete the files that contain cookies - those files are stored as part of your Internet browser.

We use cookies in three ways:

• Essential Cookies: these are used to enable core website functionality and monitor performance. Without these, you will not be able to use the website fully. They do not contain your personal information.
• Functional Cookies: these are used for social media sharing and for all collection of data so that other companies can show adverts that may be relevant to you. The inclusion of functional cookies also enables Essential Cookies to function.
• Marketing Cookies: these allow us to monitor marketing campaigns and allow Google to personalise marketing content on third party websites. These will remain effective for a maximum of 30 days after you close your browser.

Our use of cookies enables us to improve our website in order to tailor it to customer needs. If you choose not to accept Functional and Marketing cookies, this should not prevent you from using this site; however it may restrict the use of certain features.
 

Cookie Type	Cookie Function	Cookies
Essential	Core website functionality and performance monitoring i.e. basket identification, payment processing etc	ASP.NET_SessionId, marshallsgroup-eu-cookie
Functional	Additional website functionality and Social Media sharing functions i.e Live Chat, Facebook 'Like', Google +1 etc	__utma, __utmb, __utmc, __utmd, __utmv, __utmx, __utmz, _ga, _gat, is_returning _gid, _dc_gtm
Marketing	Allows us to monitor effectiveness of marketing campaigns and personalise content on 3rd party websites

THIRD PARTY WEBSITES

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT AND COMPLAINTS

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Data Protection Executive at dpo@marshalls.co.uk.

You can make a complaint to us by emailing dpo@marshalls.co.uk or to the data protection supervisory authority, the Information Commissioner's Office in the UK, at https://ico.org.uk/.