Privacy Policy
This Privacy Policy was last updated on 15th October 2021 and is version 2.4.
Who is Responsible for Processing Your Personal Data
Oxendale & Co Ltd is the Data Controller. This is the legal entity responsible for how your personal data is collected, stored and processed. Oxendale & Co Ltd is a subsidiary company of JD Williams and Company Limited trading as N Brown.
Oxendale & Co Limited also operate Simply Be and Jacamo in Ireland to which this Privacy Policy relates.
Managing Your Personal Data
When you share your personal information with us, you have a right to expect that information to be treated with total confidentiality. Therefore, it is our responsibility to manage your personal data that you provide to us with care and in accordance with all data protection legislation and industry best practice.
Whether you have supplied your personal details online, by phone, by email or in a letter, we will never use them without a lawful reason to do so. We will use your personal data for the purposes for which they were initially requested and as fully explained in this Privacy Policy.
It is your responsibility to ensure that your personal data provided to us is accurate and up to date. You can update your personal contact details, including email address and phone number, by visiting My Account online or, if you need to update any other personal details, by ringing our contact centre on 01 8300600.
Using Your Personal Data for Direct Marketing Purposes
Based on your marketing preferences, we use your email and home address to send you details of our latest products, services and promotions. We also use marketing Profiling techniques to determine what product offers may be of interest to you whether that be by email, telemarketing, direct mail or social media. Occasionally, we may telephone you with special offers. For further information on how we use your personal data to keep you informed about our products, services and promotions and how you can change your marketing preferences, click the relevant sections below.
We hold your personal data for the purposes of direct marketing to you for a period of two years from the date of your last purchase unless you have an outstanding credit balance or have updated your marketing preferences in which case you will continue to receive marketing information unless you tell us otherwise. If you have only ever registered a cash account but never bought from us, we will stop marketing to you after a period of six months unless you ask to be contacted by updating your marketing preferences.
Obtaining Your Consent+
We will obtain your consent to send you details of our latest products and promotions via Email Marketing and Telemarketing in a number of ways We will obtain your consent when you register your details with us, open a credit account, make a purchase, request a catalogue from us or enter a competition You can change your email and telemarketing preferences at any time - see Changing Your Marketing Preferences.
Email Marketing +
We would like to keep you informed about our latest product offers, services and promotions using the email address you provide to us We will also use your date of birth to send you specific offers for your birthday To do this, we will ask you to opt-in to receive marketing emails when you first register an account with us, sign up to our email newsletters, enter a competition or prize draw You can opt out of email marketing at any time - see Changing Your Marketing Preferences.
Telemarketing+
We will ask your permission to ring you about our latest product offers and promotions when you make a purchase or open a credit account with us You can opt out of telemarketing at any time - see Changing Your Marketing Preferences.
Direct Mail +
We will use your name and address to send you personalised marketing mails in the post We have a legitimate business interest to send you information about our products and offers in the post as we know that many of our customers like to browse through catalogues or offers prior to placing an order with us However, should you wish to exercise your right to stop personalised postal marketing activity, you can do this at any time - see Changing Your Marketing Preferences.
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We will use your email address to send you online targeted marketing information about our product offers and promotions via social media platforms To do this, we will share your email address in a secure manner with social media organisations, such as Facebook, who will match our advertising requirements to your social media profile We have a legitimate business interest to send you product information via social media which we believe is of relevance to you; this is known as Interest-Based Advertising. However, should you wish to exercise your right to stop targeted social media marketing, you can do this at any time - see Changing Your Marketing Preferences.
Third Party Marketing+
We will not share your personal data with third party companies for the purpose of them marketing their products and services to you.
Changing Your Marketing Preferences+
You can change your marketing preferences for Email Marketing at any time by:
- Clicking unsubscribe in the body of the email sent to you;
- Going online to My Account; or
- Ringing the call centre on 01 8300600.
You can change your marketing preferences for Telemarketing at any time by:
- Going online to My Account; or
- Ringing the call centre on 01 8300600.
Please allow 48 hours for your changes to be processed for email and telephone marketing.
You can exercise your right to object to Direct Mail or Social Media at any time by:
- Going online to My Account; or
- Ringing the call centre on 01 8300600.
Please allow 48 hours for your changes to be processed for social media You may still receive direct marketing materials that are already processed before we received your request for up to 2 months.
Using Your Personal Data to Improve Your Online Shopping Experience
We want to make sure that we only contact you with online content that you will find relevant and interesting For this to work effectively, we collect information about your browsing activity using Cookies when you are using our websites These Cookies pass back to us your browsing information using your Internet Protocol ("IP") address as the identifier, which we combine with other anonymised, non-personalised and aggregated data, allowing us to determine what content and product information is most relevant to you when you are shopping online.
We have a legitimate business interest to use the aggregated and anonymised data obtained via Cookies and other data sources to help us provide you with relevant product marketing and improve your online shopping experience.
Profiling+
Profiling is a term used to describe a form of data processing where significant volumes of data made up of lots of different data types - such as browser history from Cookies, age, gender, size, transaction history, demographics and buying habits - are all used in an aggregated, anonymised and non-personalised form to evaluate and predict, based on statistical analysis, what you may or may not want to purchase from us by assigning you to a profile type We use this technique to understand what drives you to buy from us and the types of products you are most likely to be interested in whether that be by email, telemarketing, direct mail or social media. This is sometimes referred to as Big Data and Data Science and is widely used by retailers to improve their customer offering and Interest-Based Advertising.
Interest Based Advertising+
The data that we collect and use when you browse or shop online, including where we use Cookies, uses your IP address as the unique identifier; however, it will not contain your name, home address or phone number. We may also use your email address to send you online targeted marketing information but we always use hashed email addresses to keep your data secure. The email addresses are scrambled before being utilised to ensure nobody else can gain access to your email address. This enables us to offer our customers the best possible online user experience and equally allows us to improve the relevancy of our advertising. This allows us to provide you with more of the content you want to see.
Using Your Personal Data to Open Your Personal Credit Account
If you choose to open a Personal Credit account with us (subject to status), we will use the information you provide to us in order to make a credit lending decision. This will include information about your household income. Without this data, we are unable to perform the services under this contract i.e. to calculate the amount of credit offered and manage your credit account in accordance with the applicable guidelines and regulation.
As part of our credit lending process, we will manually assess various data, including the information that you have provided to us, about you, your partner and household income information. We also use transactional data (such as previous trading or account history with us) and any other data which you have given permission to be used for this purpose.
When applying for a Personal Credit account with us we need to confirm your identity, to do this we use a third party partner and will share your contact details with them in order that they can contact you to obtain further information to check and verify your identity. Our partner will then share limited identity verification information with us so that we can proceed with your Personal Credit account application.
We do this to assess creditworthiness and product suitability, check and verify your identity, manage your account, trace and recover debts and prevent criminal or fraudulent activities, as well as to ensure that our credit lending decisions are fair and responsible.
Using Your Personal Data to Open Your Personal Cash Account
When you register to open a personal cash account, we will hold your personal data which you have provided to us When you make a subsequent card or cheque payment to purchase products from us, we will use your personal data and card information to process the order. This involves sending your personal data to our card payment and banking providers to ensure that you have sufficient funds to cover the value of the transaction Without this data, we are unable to fulfil your order.
We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal cash account.
Processing Card Payments+
We process all card payments in line with our obligations under the PCI-DSS regulations Whenever you provide your card details to us either online or over the phone, we will encrypt the payment details before sending to our card payment and banking provider If you pay over the phone, we will mask any card data that you provide so that this is not visible to our customer advisors as well as stopping card data from being recorded in our Call Recordings This is regularly monitored for quality assurance as part of our PCI-DSS obligations.
Any card details provided by customers via paper order forms will be immediately, and securely, destroyed once processed.
Using Your Personal Data for Fraud Prevention
We carry out fraud checks on new credit applications and credit orders In order to do this, we use data sourced from other external agencies that are involved in fraud detection. If we identify fraud, we will pass data relating to the fraudulent activity such as name, address and email address to these agencies to help protect individuals and other businesses from the threat of fraud in the future.
We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit or cash account.
Based on the Criminal Justice Act 2010 (Anti-Money Laundering Directive 4), we are required to ask the question about Politically Exposed Persons when offering a credit account to individuals.
A politically exposed person/ or connection to a politically exposed person can put a customer into a higher-risk category, however, it does not incriminate any individuals or entities.
Stating Yes to this question Will Not affect your application or our credit decision. The Central Bank of Ireland requires Simply Be Ireland to gather this information on every credit account. Please see www.centralbank.ie for further information
Using Your Personal Data to Operate Your Personal Account
We will use your personal data to administer and to operate your personal credit and cash account as set out below We will collect and use the contact details that you provide to us to communicate with you about your account and in relation to the products and services we provide to you
We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit and cash account.
Delivering Your Goods+
We will use your personal contact details such as name, postal address, phone number and email address that you provide to us in respect of delivering products or services to you We will share this information with our suppliers who directly despatch orders to you or our delivery partners who may contact you to arrange a convenient delivery time and provide you with updates as to when they will arrive
Processing Returns and Refunds+
We use your customer account and contact details to verify any returns and refunds that we process either by card or via your credit account We process all card payments in line with our obligations under the PCI-DSS regulations and will encrypt the payment details before sending to our card payment and banking provider
Operating Your Credit Account+
We use your personal contact details such as name, postal address, phone number and email address to notify you about any updates, changes or issues with your personal credit account. We use your personal contact data and payment history to determine whether and when to increase or reduce your credit limit.
Making Payments to Your Credit Account+
You can set up a direct debit between us and your bank to make regular payments to your personal credit account with us. If you choose to pay this way, we will require a bank account number, sort code and the type of payment you wish to make e.g. full balance or fixed amount. We will use the personal data provided to verify that the account number and sort code combination are valid. We will also ask you for the bank account holder’s name which the bank will use to verify the direct debit payment request. It is your responsibility to ensure that you either have a sole authority or that you have the bank account holder’s permission to make payments from their bank account.
Where you pay by cheque, we will also store the cheque details including account number and sort code which are required to deal with any queries raised to us by your bank.
Where you pay by credit or debit cards, we process all card payments in line with our obligations under the PCI-DSS regulations. Please see Processing Card Payments section for more detail.
Call Recordings+
We record all calls into our contact centre for quality assurance, regulatory compliance and training purposes We retain all call recordings for a period of 12 months.
Enquiries and Complaints+
If you have any complaints with regards to the operation of your personal cash or credit account, please contact our contact centre on 01 8300600 so we can deal with your complaint as quickly as possible We will need to access your personal data and account history to verify your identity for security reasons and deal with the details of your complaint Details of any complaints received will be logged and recorded so they can be dealt with accordingly.
General Service Communications+
We will use your personal data for all general service communications including sending your statements, processing orders, notifying you of orders received, updating you on deliveries, despatched or products out of stock We need to do this for the performance of the contract and terms and conditions that you have signed.
Using Your Personal Data to Improve Our Services
As a valued customer, we may use your personal data to contact you by phone, SMS, letter or email to ask you to participate in one of our product and/or service improvement programmes. We will share your personal contact details with our chosen third party partners and service providers who may carry out these programmes on our behalf. We have a legitimate business interest in contacting our customers in this way and will always treat your involvement in any product and/or service improvement programme, and associated personal data, in confidence.
Surveys+
From time to time, we will contact you to take part in a customer satisfaction survey to obtain feedback about our products and services. We will send you an SMS or email containing a short survey which we ask you to complete and send back to us. The information we collect is only used by us to improve our products and services and deal with any enquiries and complaints that you raise following this contact. We may use third party partners such as Medallia to communicate with you and collect this information on our behalf. We will share contact information such as your name, phone number and email for them to contact you to ask if you wish to participate in such surveys. We may also share other information that is relevant to the survey such as location, gender and whether you have a cash or credit account. We, or our third party partners, may sometimes follow up on surveys with you to get more information from you regarding specific complaints or feedback. You can choose not to participate in these surveys should you not wish for your personal data to be shared in this way by replying to SMS contact with STOP or by using the opt-out links in the emails we send you.
Research & Focus Groups+
From time to time, we employ different market research agencies, who act on our behalf, to contact our customers with the aim of getting a more detailed understanding of what our customers think about our products and services We will share your basic personal data - name, address, phone number and email - for them to contact you to ask if you wish to participate in our service improvement programme We may also share more personal data about your shopping habits, including the size and type of products that you have purchased if this is relevant to the market research Occasionally, we ask our research companies not to tell customers that they are contacting you on our behalf, for example for brand research purposes, as we do not want to influence your answers However, the market research company is obliged to disclose this information should you ask at the end of the survey If you do not wish to be contacted for market research purposes, you can ring the contact centre on 01 8300600.
Social Media+
We actively use social media platforms as a way of connecting, and getting closer, to our customers to hear and understand what our customers think about us and our products and services Occasionally, we may contact you directly via those social media platforms if we would like to share your comments or pictures with other customers or publish them in our marketing materials We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.
Using Your Personal Data to Process Insurance Claims
In the event that you need to make a claim against us, whether that be a product issue or personal injury claim, we will use your personal data and any supporting evidence that you provide to us to process your claim, including sharing this with our chosen insurance companies From time to time where a claim is outside of our insurance policy, we may also need to engage with external lawyers and share your personal data with them.
Sharing Your Personal Data with Third Party Processors & Partners
As part of delivering our products and services to you, we will share your personal data with carefully chosen Third Party Processors and Partners who carry out a number of services on our behalf Should you wish to obtain a list of our latest Third Party Processors and Partners, you can request this at any time by contacting our Data Governance team.
Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services If you have any concerns about any of our third party processors and partners, please contact our Data Governance team.
Processing Your Personal Data Outside of the EU
We will transfer your personal data outside the European Economic Area (the EEA) to prevent fraud and with our outsourced IT partners and contact centres. Please also see Sharing Your Personal Data with Third Party Processors & Partners. In some cases, countries outside the EEA may not have such well-developed data protection laws as those in the EEA. However, we will put in place measures and safeguards that require your personal data to be kept secure, confidential and to be processed only and strictly in line with the terms of this Privacy Policy and any relevant data protection laws.
How to Contact Us
If you have any questions, comments or complaints about this Privacy Policy or our use of your personal data, please contact us at:
Data Governance Team
Oxendale & Co Ltd
Woodford Business Park
Santry
Dublin 17
Tel: 01 8824290
Oxendale & Co Ltd is a subsidiary company of JD Williams and Company Limited trading as N Brown.
If you are at all dissatisfied with the information provided by the Data Governance Team, please address any complaints to the Data Protection Officer at the same address.
Your Personal Data Rights
Right of Access+
You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request You can do so by ringing, writing to or emailing the Data Governance team We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time that we have validated your identity.
Please be aware that for security reasons we do not usually provide details of any bank details that we hold against your account(s) Please speak to our Data Governance team should you need this additional information.
Right of Rectification+
If you believe we have made an error as to the personal data we hold about you, please speak to one of our customer service advisors on 01 8300600 who will be able to process the correction for you Alternatively, you can visit My Account to update your contact details online. Should you wish to discuss this matter further, please contact the Data Governance team
Right of Erasure+
You have the right to request your personal data to be permanently deleted from our records and systems to avoid any further communication with you Your request will always be considered in light of the legal bases that we hold, store and process your personal data and the purpose that we collected your data Where the legal bases permits, we will carry out your instruction without undue delay Please note, however, that where we have a legal or contractual obligation to hold your personal data, we may not be able to carry out your request but we will explain this fully to you Please address any request to delete your data to the Data Governance team.
Right to Restrict Processing+
Should you believe that we are processing your personal data in a way that you did not understand or agree to and wish to restrict such processing, please speak to the Data Governance team who will be able to assist you.
Right to Object to Processing+
You have the right to object to certain types of processing of your personal data. We will always make it clear at the outset of any new arrangement with you how we are going to process your personal data. However, should you wish to discuss this matter further, please speak to the Data Governance team
Right to Portability+
In the event that you wish to move your personal data that we hold on you to another organisation in the form of an excel or csv format, please contact the Data Governance team who will be able to assist you.
Right to be Informed+
You have the right to be informed about the collection and use of your personal data. This is commonly known as a 'privacy statement' or 'privacy policy'. We will provide you with the information about how we collect and use your data in various means, such as by 'just in time' notice provided to you at the time of collecting your personal data and via this Privacy Policy Our Privacy Policy is regularly reviewed in line with our business processes Any changes to this Privacy Policy will be communicated via email and credit account statements to all active customers We will also advise customers of changes when ringing the call centre via a recorded message You can ask for a printed copy of our Privacy Policy by contacting the Data Governance team.
Right to Complain to the Data Protection Commissioner (DPC)+
You have a right to lodge a complaint with the Data Protection Commissioner (DPC) if you have a complaint with how you believe your personal data has been handled. For more information, please visit https://dataprotection.ie