Samuel Windsor Privacy Policy Summary

This is the privacy policy of BVG Group Limited, trading as Samuel Windsor. This policy sets out our procedures regarding the collection and use of your personal information when we send you information in the post, when we contact you electronically and when you access our website www.samuel-windsor.co.uk. BVG Group Limited is a company registered in England & Wales whose company number is; 03393851 and our registered office is 3rd Floor Cumberland House, Cumberland Place, Southampton, England, SO15 2BG. The trading address of Samuel Windsor is Unit 1B, Brecon Enterprise Park, Brecon, Powys, LD3 8BT.

Samuel Windsor is registered as a data controller on the UK Data Protection Register. Our registration number is Z459600X.

Our privacy policy will explain in detail to you what happens to the personal information we collect about you when you visit our website, receive postal information, and order or enquire about our goods and services:

• What information we collect
• The legal basis for processing we use in relation to processing your personal data
• How we use your personal information and how long we keep it for
• Who we share your information with and on what basis
• How you can control our use of your personal information
• Your rights
• Who to contact if you want more information

This privacy policy comes into effect from 15^th May 2018. This policy applies to all the personal information we collect and process about you when we engage with you, either as a customer or an enquirer. If you would like to know more about this policy, please contact us. You can view the detailed privacy policy below by clicking on each of the sections.

When we collect your personal information

We collect personal information about you as soon as you access our website www.samuel-windsor.com using a smartphone or computer and also when you call our customer service team. The specific information we collect depends on whether you are a customer or a website visitor. If you buy a product from our website or catalogue, you become a customer of Samuel Windsor. The specific information we collect is detailed below in the What personal information we collect section of this document.

When does this privacy policy apply?

Our privacy policy relates to personal information gathered from your use of our website www.samuel-windsor.com or if you order from our catalogue by phone or by post, either as a customer or an enquirer. The policy extends to cover your personal information when it is moved from our website and stored for subsequent processing within our IT infrastructure in the UK and when we process information about you directly into our IT systems. Our privacy policy does not extend to external links on our website to other organisations outside of our control. Please ensure that you take time to review the privacy policies of external sites to www.samuel-windsor.com as their privacy policies may differ from ours.

What personal information we collect on our website

The personal information we collect from you when you access our website comes in two parts: the information you give us when you complete our website forms, and the information we automatically gather from the device you use to access our website.

Information you give Samuel Windsor: this includes the following data items (although you can visit and use our website without giving us this information, if you do not place a transaction or an enquiry during your web visit to us):

• Your first name or initial, and surname
• Your email address
• Your telephone number
• Your postal address
• Payment details: if you order products from our website, your payment details will be processed by our payment processors RealEx/GlobalIris and Paypal. Samuel Windsor does not store any of your payment details; we are given a transaction ID by our payment processor

Information from your device: when you access a website using a smartphone, TV (browser enabled), tablet, laptop or desktop computer, your device will exchange information with www.samuel-windsor.com to maximise the speed of the site and provide the optimum navigation for your device. Without this information, Samuel Windsor cannot ensure the optimum browsing experience and ease-of-use when buying products. To do this, our website picks up the following information:

• IP (Internet Protocol) address: your IP address indicates your location, unless you are using a VPN service
• Device: what type of device you are using (TV, smartphone, laptop, desktop)
• OS (Operation system): what operating system your device has (IOS, Android, Windows, Linux, MAC OS X)
• Browser & browser version: which web browser you are using (Internet Explorer/Edge, Opera, Chrome, Safari, Firefox)
• Domain: depending on your device and browser settings, we sometimes identify the web address of the domain you came from before landing on our website
• Clickstream data: this is a list of all the web pages that you visited, and the order you viewed them in, on each visit to www.samuel-windsor.com. We also record how much time you spend on each web page, and record any actions you make on each page. We also record what items you place in the web shopping basket, even if you do not purchase them
• Cookies: these are small text files that our website places on your device, so that our website can remember something about you at a later time and optimise the website for your visit. There are also some third-party cookies we place on your device. For more information on the specific cookies that we use and their function, please see our cookie policy

Preferences on our website: you can change how we stay in touch with you, and what we inform you about by accessing your preferences in the My Account section of this website. If you have not placed an order with us, please call our customer service team on 1844 258 0365. Calls are free but may cost more from a cell phone.

What personal information we collect by post and by phone

Information you give Samuel Windsor: if you order via the catalogue order form or phone our call centre we collect the following information about you;

• Your first name or initial, and surname
• Your email address, to which we send out order despatch information
• Your telephone number
• Your postal address
• Payment details, if you order products from our website, your payment details will be processed by our payment processors Realex/GlobalIris and Paypal, Samuel Windsor does not store any of your payment details, we are given a transaction ID by our payment processor. If you attach a cheque to your order coupon, this is banked, no details of your bank account are stored by us

Preferences by catalogue and by phone: you can change how we stay in touch with you, and what we inform you about via the My Account section of our website (see above). If you do not want to do this, you can change your preferences on the order form in the catalogue or by phoning our customer service team on 1844 258 0365. Calls are free but may cost more from a cell phone.

Why we collect your personal information

There are two main purposes for gathering your personal information: for marketing activities and for transaction processing.

Transaction processing: when you purchase a product from our website or catalogue, you become a customer of Samuel Windsor, so we retain personal information on you whilst you remain an active customer of ours and also for a short time when you no longer order from us. When you make an enquiry about a product of ours, we also retain the personal information you give us in your enquiry for a limited period of time. Our Data Retention policy below explains how long we keep your personal information. In all cases for transaction processing, our legal basis for processing your personal data is contract.

Marketing activities: we have separated out each marketing activity that your personal data is used for below. Note that any customers or website visitors who don't want to receive marketing communications from us can use the contact us form to manage their preferences, or the My Account function on our website. Samuel Windsor will never send you a marketing message that doesn't have a method of opting out from our marketing communications contained within it.

• Catalogues: we will provide our customers with at least one full range catalogue each year. The legal basis for processing is legitimate interest
• Product offers: from time to time Samuel Windsor will send you discounted product offers via email , SMS or post. These offers are based on our knowledge of the products you have ordered or enquired about and your visits to our website, if you have visited it. The legal basis for processing is legitimate interest
• Surveys: We occasionally survey portions of our customer and website visitor database to find out more about your experience using Samuel Windsor and to find out how we can improve our service delivery to you. The legal basis for processing is legitimate interest
• Site optimisation: the device-level information we automatically gather about you allows us to optimise the speed and performance of the website for you. The legal basis for processing is legitimate interest
• Web analytics: we use cookies and the device-level personal information to build a profile of your use of the site, including any transactions that you make, so that we can personalise our marketing offers to you, and to customise your website visits. To find out more please see our Cookie Policy. The legal basis for processing is legitimate interest
• Anonymous web analytics: Samuel Windsor aggregates and anonymises all your activity on our website for traffic analysis, to help measure and improve the website performance. We also use this anonymised data to monitor the effectiveness of our advertising. Your personal data is anonymised in this process, so there is no requirement under GDPR for a legal basis for processing
• Business Insight: your personal data and any order history goes into our business insight platform. We use this application to gain detailed insight into how to improve our product and service offering to you, and to also create statistical models to predict your likely purchasing intentions in the future. You can request that your data is removed from this business insight process in the preference section of My Account or by contacting our customer service team on 1844 258 0365. Calls are free but may cost more from a cell phone. The legal basis for processing is legitimate interest, you can request that we remove your details from our business insight process

How we protect and where we store your personal information

The personal information we collect about you is stored within our secure UK IT Data Centre. No identifiable personal information is stored or shipped to non-UK/EU locations. Your personal information is stored in databases which are encrypted at rest, providing the highest level of security. All personal information is moved to and from our website www.samuel-windsor.com via an HTTPS connection, which means that the transfer of data is also encrypted. Access to your personal data held on databases managed by Samuel Windsor or its' authorised subcontractors, is granted only when there is a need to use the data, no permanent access exists.

Samuel Windsor is amending our IT policies to further protect your personal information by adopting 'Privacy by Design', an information management standard that seeks to anonymise personal data held in commercial databases to further protect that information. You can find out more about this anonymization process by following this link.

How long we keep your personal information

Samuel Windsor will only use your personal information for as long as you remain a customer, and for a short time after your last order. The maximum amount of time that Samuel Windsor will retain your personal information in a data archive, is seven years, except in the event of a legal dispute. This seven-year limit is based on the legal requirement to maintain details of transactions as described in the Companies Act 2006. We have listed below how long we store your personal information for, which depends on your relationship with Samuel Windsor.

If you made a purchase from us: we will keep the information you gave us and details of what you bought for up to seven years from the date of the last transaction with us. After that time your personal data will be anonymised, but we will keep your purchase and marketing history.

If you enquired about a product, but did not make a purchase: we will keep the information we have on you as an enquirer for up to three years. After that time your personal data will be anonymised, but we will keep your enquiry and marketing history.

If you wrote to us: we will keep any correspondence with you for six years, although we do keep this information longer if your correspondence is a complaint.

Sharing your personal information with other organisations

Subcontractors: Samuel Windsor use carefully selected subcontractors to assist in the management and structure of business information for its own marketing purposes. The information these subcontractors process includes the personal information we gather about you and your transaction and web history with us. By 'marketing' we mean the specific purposes outlined in the Marketing Activities section of this document. Details on these subcontractors are as follows:

Esendex Ltd trading as Text Marketer, whose registered office is 20 Wollaton Street, Nottingham, NG1 5FW, United Kingdom, or the purposes of SMS marketing. Esendex Ltd is registered as a data controller Z5483210.

Red Eye International, whose registered office is Oak House, Crewe Hall Farm, Crewe, CW1 5UE, for the purposes of email marketing. Red Eye is registered as a data controller Z9006942.

Qbase Data Services, whose registered office is 31-33 Bold Street, Warrington, Cheshire, WA1 1HL, for the purposes of building a single customer view database, business insight platform and list rental marketing. Qbase is registered as a data controller, Z842993.

BVG Group companies: periodically Samuel Windsor will share its customer information with other BVG Group companies who have products and services that are relevant to the shoe and cloithing market. Those companies will then send you marketing information by your preferred method (SMS, post or email), on products that are directly related to your purchases with Samuel Windsor. You can opt out of these communications at any time, by changing your preferences using My Account or by calling our customer service team on 1844 258 0365. Calls are free but may cost more from a mobile phone.

Requesting a copy of your personal information

You can contact Samuel Windsor using the information below, to request a copy of the personal information we hold on you. If you request this information, you will need to provide proof of your identity. We will return the information to you electronically in a text file. You are legally entitled to request this information under the General Data Protection Regulation, there is no charge for this service.

To create an online request for a copy of your personal information, please visit our Subject Access Request portal at https://sar.samuel-windsor.com.

We will supply you the following information:

• Your contact details: which may include your email address, phone and mobile numbers, your previous address, your previous or second email address, your communications preferences and the date your contact details were last updated
• Your transaction history: if you have ordered from us, you will receive details of your order, including products purchased, date of purchase and the cost of the products
• Your marketing history: if we have marketed to you, we will send you details of the catalogues and emails we have sent you
• Email correspondence: we will search our email server to see if your email address is in any email message headers, if we find it, we will send you the email(s)

To request a copy of your personal information via post, please write to: Data Protection Officer, Samuel Windsor, Unit 1B, Brecon Enterprise Park, Brecon, Powys, LD3 8BT.

How to control your personal information on the Samuel Windsor website

If you do not want to receive communications from Samuel Windsor, you can change your preferences via our My Account function. You can also opt-out directly from emails and SMS messages that we may send you and you can use the opt-out section of the order form in our catalogues. Lastly, you can phone our customer service team on 1844 258 0365. Calls are free but may cost more from a mobile phone.

Your rights

This privacy statement reflects the rights that you have under the General Data Protection Regulation, which specifically charges Samuel Windsor with providing you access to your personal information, and to ensure that your data is used appropriately & securely with specific reference to the rights of you, the data subject. Those rights regarding your personal data are as follows:

• The right to access a copy of your personal information that we hold
• The right to object to our processing of your personal data, if doing so causes you distress
• The right to prevent Samuel Windsor processing your data for direct marketing purposes
• The right to object to decisions being taken using automated means that includes your personal data
• The right to have inaccurate personal data rectified, or destroyed
• The right to have your data erased from our IT infrastructure
• The right to data portability
• The right to be informed about the collection and use of your data

You can find out more about your rights regarding your personal data in the UK from the Office of the Information Commissioner www.ico.org.uk.

Definitions

In this section of our privacy policy we want to explain what some of the terms in the policy mean, for the avoidance of any doubt. If you cannot find the definition you require, or are still unsure about the meaning of any aspect of this privacy policy, please use the contact us form on our website to request more information.

Data Controller: under the General Data Protection Regulation (GDPR), organisations that collect, process and store your personal information are defined as Data Controllers, which makes Samuel Windsor the Data Controller for your personal data collected from our website.

Data Subject: GDPR classifies individuals as data subjects. So you, the customer or enquirer of Samuel Windsor are a data subject under GDPR if you purchase or enquire about our products.

Data Processor: a data processor is an organisation other than the data controller, who processes your personal data on behalf of the data controller. A good example of this is PayPal, who are one of the payment processing options for any products that you buy online. The data processors who handle your personal information gathered by our website have the same duty of care in handling your personal information.