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Who we are
As set out in our Loyalty Programme terms and conditions, the Loyalty Programme is operated by Frasers Group Financial Services Ltd., whose registered address is Unit A, Brook Park East, Meadow Lane, Shirebrook, NG20 8RY. Our company number is 13191369.
Data we may hold about you
When being registered for the Loyalty Programme, using our Loyalty Programme, registering to receive our marketing communications, or contacting us, the personal data which is provided to us, such as your name, email address and information about the status of your account and your spending patterns, will be collected and processed.
How we may use your personal data
We may use your personal data in the following ways:
- to register you for the Loyalty Programme, including to set you up with, maintain and update your Loyalty Programme account (e.g. such as a change of address or change in your marketing preferences);
- to provide, run and administer the Loyalty Programme;
- to tell you about the Loyalty Programme, or products and services that you ask us to send you information about, by email, post, mobile, telephone and/or through other digital means (depending on your stated preferences) including social media platforms, in accordance with 'Marketing and promotional communications' below;
- to keep in touch with you regarding your marketing preferences, in accordance with 'Marketing and promotional communications' below;
- to answer your questions, and deal with enquiries or complaints relating to the Loyalty Programme;
- to analyse and improve the Loyalty Programme;
- to measure, analyse and improve our advertising and marketing to customers;
- to monitor and analyse the use of your Loyalty Programme account to detect and prevent fraudulent transactions and/or any other criminal activity (we may pass your details to a third party to carry out these functions);
- where relevant, to meet legal, regulatory and compliance requirements;
- where relevant, for the establishment, exercise or defence of legal claims; and
- to keep our network safe and secure.
Legal basis for using your personal data
We will only use your personal data when applicable legislation allows us to. We rely on the following lawful bases to process your personal data:
- where you have given us consent to use it – you are able to remove your consent at any time, by contacting us in accordance with 'How to contact us or complain' below;
- where it is necessary for entering into, or to perform, any agreement we have entered into with you;
- where required by applicable legislation; or
- where it is necessary for our legitimate interests (or those of a third party) where these are not overridden by your rights and interests.
How long we keep your personal data
We will not keep your personal data for any purpose(s) for longer than is necessary and we will only retain the relevant personal data that is necessary in relation to the purpose.
We will retain the personal data provided for registering an account for the Loyalty Programme so long as that account remains in existence and for a short time after that to enable us to deal with any question or queries in relation to that account.
In the case of any contact you may have with our customer services department, we will retain those details for as long as is necessary to resolve your query and for a short period after the query is closed.
If we are legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, respond to any questions, complaints or claims made by you or on your behalf, prevent fraud and abuse, keep records required by law or enforce our terms and conditions, we may also retain some of your personal data for a limited period of time, even after you have closed your account.
We will retain your personal data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place.
How we might share your personal data
We may routinely share your personal data with other companies in the Frasers Group, which means the companies who are ultimately owned or controlled by Frasers Group plc,
We may also share your personal data with carefully selected third parties who assist us in providing you with the Loyalty Programme. This includes Tymit as the regulated lender, as well as the following types of third party:
- Our (and the Frasers Group's) professional advisers, including, without limitation, our insurers; and
- Our (and the Frasers Group's) suppliers, business partners and sub-contractors.
We will only share your personal data with third parties where it is necessary for them to provide us with the services we need.
In the event that we were to sell our business or assets, we may disclose your personal data to any prospective/actual purchaser and/or their advisers.
We may disclose and exchange information with law enforcement agencies, government authorities and regulatory bodies to comply with our legal and regulatory obligations.
We may also disclose your personal data where we are subject to a legal obligation to do so in connection with the prevention or detection of crime, for the purpose of establishing, exercising or defending our legal rights, or where we consider that we receive a valid request for disclosure. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Please note that third party websites/providers have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you provide or submit any personal data to these websites/providers.
Where your personal data is held
Information may be held at our offices and in our IT systems and those of the Frasers Group as well as by its and our professional advisers, service providers, suppliers, business partners and sub-contractors.
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘International transfers of your personal data’.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully.
We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Marketing and promotional communications
We may use your personal data to send you updates (by email, post, mobile, telephone and/or through other digital means (depending on your stated preferences) including social media platforms) about our products and services, including exclusive offers, promotions or new products and services.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the Group for their marketing purposes.
You have the right to opt out of receiving promotional communications at any time:
- Through the Frasers Plus app:
- Log into the app
- Tap the person icon at the bottom right of the screen
- Tap on Settings
- Slide On/Off to change marketing consent
- By contacting Frasers Plus customer services by web chat or email via the Frasers Plus app.
- By writing to us at the address set out in 'How to contact us or complain' below" and addressing it to the Frasers Plus Loyalty Programme.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
International transfers of your personal data
The personal data that we process may be transferred to, and stored outside the UK or European Economic Area ("EEA"). It may also be processed by staff operating outside the UK or EEA who work for us or for one of our suppliers or third party providers. Where we do so, the third country's data protection laws will have been approved as adequate by the European Commission, or other applicable safeguards are in place.
You have certain rights in relation to personal data we hold about you. Details of these rights are set out below. You can exercise these rights by contacting us in accordance with 'How to contact us or complain' below.
Right to Object to or Restrict Processing
In some circumstances, you have the right to object to our processing of your personal data – e.g. if we are processing your data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal data for direct marketing purposes (for more information, see 'Marketing and promotional communications' above). If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved.
Right to Withdraw Consent
Where you have consented to us using your personal data, you can withdraw that consent at any time.
Right of Erasure
In some circumstances you can ask us to erase your personal data – e.g. if you withdraw your consent, it is no longer necessary for us to use your personal data, you object to the use of your personal data and we don't have a good reason to continue to use it, or we haven't handled your personal data in accordance with our obligations.
Right of Access
You have the right, with some exceptions, to ask us to provide a copy of any personal data we hold about you.
Right of Correction or Completion
If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.
Right of Data Portability
You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
To exercise these rights, we need to be suitably satisfied of your identity and so may request you provide identification documents or confirm other details we may hold about you (such as a recent delivery reference or address).
How to contact us or complain
If you have any queries or concerns regarding how we use your personal data, please write to Data Protection, Unit A, Brook Park East, Meadow Lane, Shirebrook, NG20 8RY.
If you are not happy with our response, you can contact the Information Commissioner's Office: https://ico.org.uk. The ICO’s address is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, and its helpline number is 0303 123 1113.
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