PROTECTING YOUR PRIVACY
HETTICH JEWELLERS LIMITED
CONTENTS OF PRIVACY NOTICE
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- Combining your data for personalised direct marketing
- How we protect your personal data
- Children’s privacy
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Contacting the Regulator
- If you live outside the UK
- Contacting Hettich Jewellers
- Rolex Section
This policy (together with any privacy notice displayed on https://www.hettich.co.uk/ ("our site") or otherwise notified to you) sets out the basis on which we will process any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection (Jersey) Law 2018 ("DPL") the data controller is Hettich Jewellers Limited of 1 King Street, Saint Helier, Jersey, JE2 4WF. We will, in processing your data, comply with the DPL and the General Data Protection Regulation (2016/679) ("GDPR").
This Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe. We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Hettich Jewellers Limited (which we’ll refer to as ‘Hettich Jewellers’) uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent In specific situations, we can collect and process your data with your consent.
For example, when you sign up to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
We may use precise location information subject to your consent. To withdraw your consent to such use, you can contact us at email@example.com, or you may be able to disable the sharing of location information in your browser or mobile application settings. Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, for us to conduct a home visit for any need we’ll collect your address details to deliver your purchase.
Or for example, when you use our online services we will use your personal information to respond to your requests and provide you with such services.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Hettich Jewellers to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We will also use your address details to send you direct marketing information by post, sending you invitations or telling you about products and services that we think might interest you.
Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this privacy statement and use personal information for our marketing purposes.
We may use CCTV recordings to ensure the safety and security of our employees, customers and property.
3. When do we collect your personal data?
- When you visit our shops or website, and use your account to buy products and services.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you have an account created with us.
- When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you ask one of our colleagues to email you information about a product or service.
- When you enter prize draws or competitions.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- When you fill in any forms. For example, if an accident happens in store, a colleague may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
- When you use our shops, which usually have CCTV, systems operated for the security of both customers and Partners. These systems may record your image during your visit.
4. What sort of personal data do we collect?
If you have a web account with us: your name, gender, date of birth, billing/delivery address, memorable dates, orders and receipts, preferences, email and telephone number. For your security, we will also keep an encrypted record of your login password.
For the avoidance of doubt, we do not store any payment card details
- Details of your interactions with us in store, or online. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, brands you show interest in, and how and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's license). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your visits to our website including, but not limited to, traffic data, location data, and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Personal details which help us to recommend items of interest.
- For example, you might tell us your favourite item of fine jewellery, which we’ll use to guide our suggested items.
- We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit our shop.
- To deliver the best possible web experience, we collect anonymous technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
We may collect information about your computer, including where available your operating system and browser type for system administration. This is statistical data about our users' actions and patterns, and does not identify any individual.
Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
Please note that this website also contains link buttons and content from various social media networks, so that you can easily share content from our website with your social media networks. If you use these features, these social media sites may store cookies on your device/computer. Information on the cookies used can be found in the information given on these sites. Equally, we may also receive information about you from these social media platforms, including but not limited to, when you interact with us on those platforms or access our social media content. Please note that the information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.
5. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you invites to events, products and services that are most likely to interest you.
The DLP allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when an item comes into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our website, or in store. If we do not collect your personal data during checkout, we will not be able to process your order and comply with our 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, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent 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 throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To send you email notifications when you place a product in your basket and you abandon browsing before completing your checkout. We do this based on our legitimate interest.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We will also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We will do all of this as part of our legitimate interest.
- For example, by checking your password when you login to identify possible fraudulent log-ins from unexpected locations.
- To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our stores which record images for security. We do this on the basis of our legitimate business interests.
- 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.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities and want to ensure the safety and security of our employees, customers and property.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, and telephone about relevant products and services including invitations to events, competitions and so on. Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services, service reminders and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our website, we will use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive notifications and/or for our website to place cookies or similar technology on your device. For example, we might display a list of items you have recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To administer any of our prize draws or competitions, which you enter, based on your consent given at the time of entering.
- To send you communications required as part of our legitimate business interests to inform you of products becoming available for collection.
- 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. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
- To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you surveys and 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. Of course, you are free to opt out of receiving these requests from us at any time by contacting us either in the showroom, by letter or by email.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across Hettich Jewellers, and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest.
- To process your booking/appointment requests. Sometimes, we will need to share your details with a third party who is providing a service (such as delivery couriers visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we would be unable to fulfil your request.
6. Combining your data for personalised direct marketing
We want to bring you invitations to events, and product details that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Hettich Jewellers as described above.
Hettich uses, through its Website, the Google Ads Remarketing service to advertise on third party websites (including Google and Facebook) to previous visitors to our Website. Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google and Facebook. It connects activity on www.hettich.co.uk with the Google and Facebook advertising network.
Google Ads Remarketing and Facebook retargeting displays relevant advertisements to you based on pages of the website that you have viewed by placing a cookie on your computer. This cookie does not identify you or give us access to your computer. The cookie allows us to show you relevant advertisements across the Google and Facebook Advertising Networks based on your previous browsing of the website.
You can opt out of Google Ads Remarketing by visiting http://www.google.com/settings/ads
You can opt out of all third party cookie advertising by visiting http://www.networkadvertising.org/choices.
7. How we protect your personal data
We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
We deploy administrative, technical, and physical safeguards designed to comply with applicable legal requirements and safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by us.
However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.
The online services are controlled and operated by us from within Jersey. We may transfer information to countries outside of Jersey and your country of residence which may have data protection laws and regulations that differ from those in your country provided that we ensure that an adequate level of protection is in place.
8. Children’s privacy
The site is intended for visitors over the age of 18. We will not knowingly collect information from children under the age of 18. If you are under the age of 18, you may not use this website unless you have the consent of, and are supervised by, a parent or guardian.
The premises has CCTV recording in operation and therefore visitors under the age of 18 are only permitted to visit the premises with the consent and supervision of a parent or guardian.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us indefinitely (or unless requested otherwise by yourselves) so we can comply with our legal and contractual obligations, and provide a record if needed by customers for insurance purposes.
10. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties for legitimate purposes.
For example for fraud management, to handle complaints, or to help us personalise our offers to you. In these instances, we demand these organisations keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- Our payment processing companies who process payments on our behalf.
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Direct marketing companies who help us manage our electronic communications with you.
- Data insight companies to ensure your details are up to date and accurate.
- Sharing your data with third parties for their own purposes.
We will only do this in very specific circumstances, for example:
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 Hettich Jewellers Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Employees of Hettich Jewellers Limited may be given access to any information which we collect via our online services, but their use shall be limited to the performance of their duties and in line with the reason for processing. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to enable you to use the online services or to deal with requests which you submit to us.
To third-party service providers that perform services on our behalf, such as web-hosting companies, mailing vendors, analytics providers, event hosting services, and information technology providers.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or 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 may be asked to share data with our suppliers. We will only do so with your prior consent.
We may, from time to time, expand, reduce or sell Hettich Jewellers and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
11. Where your personal data may be processed
We keep and store your data in Jersey, Channel Islands, UK. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
An overview of your different rights.
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent. You have the right to request a copy of any information about you that Hettich Jewellers holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information or for amendments to the information, please contact the Chief Operating Officer, Hettich Jewellers Limited, 1 King Street, Saint Helier, Jersey, JE2 4WF or email firstname.lastname@example.org.
If we choose not to action your request we will explain to you the reasons for our refusal.
You can exercise your rights at any time by contacting us at email@example.com.
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 statements and that we do not accept any responsibility or liability for these policies. Please check these statements before you submit any personal data to these websites.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking your identity: To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. How can you stop the use of your personal data for direct marketing?
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Please write to the Chief Operating Officer, Hettich Jewellers Limited, 1 King Street, Saint Helier, Jersey, JE2 4WF or email firstname.lastname@example.org.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
14. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact the Jersey Information Commissioner at email@example.com.
15. If you live outside the UK
For all non-UK customers: By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the EEA and USA.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the EEA and USA.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
16. Contacting Hettich Jewellers
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to firstname.lastname@example.org.
17. Rolex Section