Slouch – Customer Privacy Policy

Last updated April 2024

 

–   Introduction

–   Who we are and how to contact us

–   How we collect your personal information

–   The types of information we collect

–   Ensuring your personal information is only used where lawful

–   Why we collect your personal information and how we use it

–   The Privacy and Electronic Communications Regulations (PECR)

–   Sharing your information

–   Business Administration and Legal Compliance

–   How can I unsubscribe from marketing communications?

–   Our use of Cookies

–   Third party links and services

–   Joint Controllers

–   Children

–   How long do we keep your personal information for?

–   Confidentiality and security of your personal information

–   How to access your information and your other rights

–   Changes to this Privacy Policy

 

Introduction

Slouch is committed to protecting your personal information. It’s your information, and we respect that. Our Privacy Policy gives you detailed information on when and why we collect your personal information, how we use it and how we keep it secure. This Policy also sets out your right to request that we delete, update, transfer or provide you with access to your personal information. This Policy should be read alongside our Terms & Conditions. Please also note that this Privacy Policy only applies to personal information processed by us – not information processed from your interactions with third parties and not received by us.

 

Who we are and how to contact us

The Sites (Website), and our Services (e.g. Personal Shopping, Trade Accounts, Commercial Projects etc.) are operated by Senator International Limited.

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please e-mail our Data Protection Officer [email protected]

Senator International Limited (registered office Syke Side Drive, Altham Business Park, Accrington, Lancashire, BB5 5YE)  is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: Z7485695

 

How we collect your personal information

Generally, we collect your information when you decide to interact with us. This could include purchasing online, over the phone or in person or when you sign up to receive emails from us. We also process information about how customers use our website, so that we can offer the best possible experience.

 

We collect information in a number of ways, examples of which are listed below:

• When you register or use slouchonline.com (the “Website”)
• When you register in our showrooms
• When you contact Slouch by telephone or email
• When you sign up to receive marketing newsletters
• When you attend an event, or enter prize draws or competitions run by Slouch
• When completing any surveys that we send to you for research purposes (although you are under no obligation to complete these)
• When completing any forms for transactional or other purposes
• When you buy products, services and gift certificates from Slouch (ie: details of transactions you make from Slouch – whether in-store or via the Website.
• When you use or are a customer of any of our other Services or showroom offerings
• When you visit our website: we use cookies to help make the experience of using our website better and to personalise the service you receive from us – this means we will remember your previous visits and track the pages on our website that you visit. For more information please see our Cookie Policy below. When you visit slouchonline.com the Slouch web server automatically records your public internet protocol (‘IP’) address [where this is permitted by your web browser].
• From time to time, we may also get data about you from third parties you have agreed this with. This could include other parties that we have run partnerships, competitions and events with or that provide some of our Services. All external parties must have your consent before sharing any information with us.

 

The types of information we collect

We only collect the information that’s necessary to carry out our business, provide the particular service you’ve requested and to keep you up to date about all the latest exciting Slouch news.

 

Information we obtain directly from you

Here are some examples of information we collect about you when you interact with us:

 

• Title
• Name and Surname
• Email address
• Date of Birth
• Contact phone number(s)
• Purchase information (Including items and prices)
• Interactions with us e.g. contacting our Customer Care team, visitors logs
• Delivery address(s)
• Billing address
• Health and disability information
• Attendance at events
• Preferred store, categories and brands
• Appointment booking and information given during appointments
• Alterations and repair requests
• Content of correspondence / messages
• Automatically populated IP address
• Information from cookies – All cookies can be edited in the cookie preference pop up which displays on entering the website. These can be turned on and off, but necessary cookies may be required for the website to function correctly.
• When visiting our website, we may collect an automatically populated IP address. An IP address is a unique number which allows a computer, group of computers or another internet connected device (such as your mobile or tablet) to browse the internet. We may also record the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version.

 

For further information about Cookies and how Slouch uses them, please read our Cookie Policy below.

 

Information we obtain independently from you:

• Your information may be shared with us by independent organisations, for example other organisations that Slouch has worked with or by Senator International Limited. These independent organisations will only do so when there is a lawful basis to do so. You should check their Privacy Policy when you provide your information to them, to understand fully how they will process and safeguard your data. These independent organisations may include:

 

• Third Party Organisations – We may combine information you have given to us with additional information made available from / shared with us by external sources. This will only be done where there is a lawful basis to do so.
• Information updates – From time to time we may screen our database against recognised data files, such as the National Change of Address file, to help us keep our database up to date.
• Social Media – Depending on your settings or the privacy policies for social media and messaging services like Facebook or GMAIL, you may give us permission to access information from those accounts or services. This may be during a ‘sign in with’ feature. All information shared with us must be agreed by you within your App/Accounts opt in preferences.
• Information available publicly – We may include information found in places such as Companies House and information that has been published in, for example, articles/ newspapers/ online to authenticate business or trade customers/ orders.

 

Ensuring your personal information is only used where lawful

In order for our use of your personal information to comply with applicable data protection law, that use by us needs to fall under at least one of the specific lawful reasons that are set out in applicable data protection law. Examples of these lawful reasons include our use of your personal information being necessary for the performance of a contract with you, or for compliance with a legal obligation.

 

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

 

Why we collect your personal information and how we use it

We use the information we have to contact you about any information regarding processing your orders, returns or queries. Allowing us to provide the services that you have requested. We may also use this to offer you a personalised experience and inform you about exclusive events or brand updates.

 

Examples of how we use your data are as follows:

To carry out our business and to provide a service or carry out a contract with you.

• Fulfilment of, and delivery of, products and services you have ordered. We may share your personal information with our delivery partners and third-party concessions.
• Respond to customer care enquiries raised in the showroom, online, social media or on the phone.
• Process payments. Slouch does not store any card/payment details or numbers. We use a third-party supplier to process all payments securely on our site. These third parties will be responsible for the handling of your personal data for these purposes and their privacy policies will set out how they do this. See here the list of providers/ suppliers we use.
• Contact you with important information relating to an enquiry or purchase, or use and administration of any of our Services, such as confirming your order, letting you know about returns and refunds and any information in relation to that Service. We may share your information with our communication partners for this purpose.
• Transactional emails, customer care surveys and product reviews. We use this information to help us maintain a good quality service and to help improve the quality of service in future and to monitor the quality of our products and services.

Where we have justifiable reason (legitimate interest):

• Analyse customer information with other interactions customers have with Slouch in order to continually improve the products and services we offer through our; website and directly in order to inform and improve our marketing strategy. See here the list of providers/ suppliers we use.
• For classifying our audience into groups or segments, using shopping habits information regarding your personal or professional interests, demographics, experiences with our products and contact preferences. These segments help us to understand our customers better and help us to inform and improve our marketing strategy. We do this using Customer Relationship Management systems. See here the list of providers/ suppliers we use.
• Measure and understand how our customers respond to our services online and offline and to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective. If you do not want this information to be captured you can remove cookie permissions on our site and within your online browser at any time.
• Detect and reduce fraud and credit risk.

 

Where we have your consent:

• Send you marketing updates via email about all the latest news, events and offers at Slouch. We require active opt ins to capture your marketing preferences and you can unsubscribe at any time by clicking the unsubscribe link in any email. We share your personal information with a third-party email marketing provider who assist us in delivering our email marketing campaigns to you. See here the list of providers/ suppliers we use.
• We will use any health and disability information provided to ensure that an order is relevant to your needs and that any special requirements relating to delivery and installation are acted upon.
• Use your details to show you advertising on Social Media platforms, such as Facebook and Instagram, or via other third-party advertising that may appear on other websites you use such as Google. Online advertising channels we may use are: digital display advertising, search engine marketing, paid social adverts, video on demand – these are all on third party sites or platforms. We tailor emails and online advertising to the things that we believe you are interested in, they may also be relevant to your locations and based of products you have shown interest in recently. See here the list of providers/ suppliers we use.

 

The Privacy and Electronic Communications Regulations (PECR)

Where we have collected your contact details in our showrooms in the process of a sale (or negotiations of a sale) of a product or service, Slouch may send you marketing updates via email. We will only send you marketing updates about Slouch products and services similar to those you have expressed interest in. You have the option not to opt in to these communications when we first collect your contact details and you will be able to unsubscribe in every subsequent communication from us or at any time by contacting us by phone or email.

 

How can I unsubscribe from marketing communications?   

If at any point you do not wish to hear from us there are a number of ways you can unsubscribe from our communications.

• You can click on the “unsubscribe” link in any communication that we send to you via email which will then automatically unsubscribe you from that type of communication. Each “unsubscribe” link only relates to that specific type of communication (e.g. general marketing communications, specific marketing communications (such as Events) or Survey Communications. This means that unsubscribing from general marketing communications will not automatically unsubscribe you from specific marketing or our survey communications (or vice versa). Please also note that you may continue to receive communications which are already on their way to you for a short period of time while your relevant unsubscribe request is being processed.

 

Alternatively, you may contact our customer service team by email at [email protected]

 

Sharing your information

We will never sell or disclose your information to make money.  We use other third party suppliers to help us deliver our goods and services and sometimes they may need access to your information to do this.  We carefully choose these suppliers, only share with them the information about you that they need to do the work we have them to do, and we make sure they keep your information secure and only use it in accordance with our instructions.

• We use third party platforms to manage and deliver customer relationship management (CRM); email marketing campaigns; online advertising; customer analytics; events; booking of appointments; fulfilment of orders; delivery; returns; refunds; IT services; payment providers. In providing the services, your personal information will, where applicable, be used by the service provider on our behalf. See here the list of providers/ suppliers we use.

 

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal information. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal information and their compliance with our data security standards and international transfer restrictions.

 

Business Administration and Legal Compliance

In certain circumstances, we share and/or are obliged to share your personal information for business administration and legal compliance purposes with third parties outside Senator International Limited.

We may use your personal information in connection with a business transition (such as a merger, acquisition by another company, or a sale of all of or portion of our assets), to enforce our legal rights and/or to protect the rights of third parties and it is in our legitimate interest to do so.  It may be necessary to share your personal information with external professional advisors such as lawyers and accountants, or insurers or Auditors.

We may use your personal information for legal compliance purposes and to enforce our legal rights. In such instances it will be necessary to share your personal information with external parties such as administrative authorities (HMRC), the Financial Conduct Authority, police and public prosecutors or to comply with a court order.

 

Our use of cookies and similar technologies   

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. These cookies are used by the ecommerce engine to identify the customer’s current order and shopping cart. For anti-forgery token (prevent CSRF attack). It guarantees that the user that posted the form is the same user that received the form in their browser and to Indicate the user has accepted the cookie notice.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title/ Name	Purpose	More information
_RequestVerificationToken         cookieconsent_status     vendr-(guid) vendr-(guid)-cfo	This is an anti-forgery token (prevent CSRF attack). It guarantees that the user that posted the form is the same user that received the form in their browser.   Indicates the user has accepted the cookie notice   These 2 cookies are used by the ecommerce engine to identify the customer’s current order and shopping cart. The (guid) aka, global unique identifier, will change when a user creates a new order. vendr-(guid) will always be present, and vendr-(guid)-cfo will be present when an order is completed but will removed after the session ends.	Expires at the end of the session       expires 1 year     Expires after 1 year or if the server data is removed.

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies. See here the list of providers/ suppliers we use.

To deactivate the use of third-party advertising cookies, you may edit your user preferences using the pop up that appears on entering the website – slouchonline.com. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire after 1 year or if the server data is removed.

 

Third Party Links and services   

Our website and emails contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.

• Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
• We encourage you to become familiar with the privacy practices of every website you visit, or third-party service provider that you deal with, and to contact them if you have any questions about their respective privacy policies and practices.
• This Privacy Policy applies solely to personal information collected by us through our Sites or Services (or Third-Party providers performing our Services on our behalf) and does not apply to these third-party websites and third-party service providers.

 

Children

Customers need to be over 16 years old to create an account with us and to sign up to receive our newsletter. We do not knowingly collect Personal Data from children under the age of sixteen (16). If you are under the age of sixteen (16), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Sites and Services without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the Services, please email our Data Protection Officer at [email protected] and we will endeavor to delete that information from our databases.

 

How long do we keep your personal information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available upon request. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We do not sell your personal information for any purpose.

 

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

 

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are contractually obliged to respect the confidentiality of the personal information of all users of our Services.

 

How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

• Your right of access

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to correct information

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it corrected. If we’ve shared your personal information with others, we’ll let them know about the changes where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to delete information

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict information

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are: Relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or Processing your personal information for direct marketing.

• Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, or the performance of, a contract between you and us.

• Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

 

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

 

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required, to comply with changes in applicable law or regulatory requirements. We highly advise that you review this Privacy Policy periodically as a minimum to remain informed of how we use your personal information and to keep yourself informed.