Privacy policy

We, Alexander Rose Ltd., understand that you care about your personal data and how it is used, and we want you to trust that we use your personal data lawfully. This privacy notice will help you understand what personal data we collect, why we collect it and what we do with it.

Please take a moment to familiarise yourself with our privacy practices and if you have any questions, send us an email or submit a request through the “Contact Us” form on our website or by using the information set out in paragraph 11 of this privacy notice.

1. Important information and Who are we?

This privacy notice gives you information about how Alexander Rose Ltd. collects and uses your personal data, through your use of this website, including any data you may provide when you register with us, sign up to our newsletter, purchase a product or service, and / or take part in a competition, or when you contact us, whether as a customer or supplier and whether through this website or not.

Alexander Rose Ltd. is a limited company incorporated in England and Wales under company number 02892358. Our registered office address is Alexander House, 59 Victoria Road, Burgess Hill, West Sussex, RH15 9LE.

We will be the controller for purposes of the UK General Data Protection Regulation and Data Protection Act 2018 when you use this website or purchase a product or service from us. We are registered with the Information Commissioner’s Office under certificate number ZA026189.

If you have any questions about this privacy notice, including any requests to exercise your legal rights (paragraph 9) please contact us using the information set out in the contact details section (paragraph 11).

This website is not intended for children and we do not knowingly collect data relating to children.

What personal data is being collected?

Personal data means any information about an individual from which that person can be identified.

We may collect, store, use, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier title, date of birth and gender.
• Contact Data includes billing address, home address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating systems and platforms, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We collect personal data directly from you or in some cases from a third party. It is collected using the following methods:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, text, social media or otherwise. This includes personal data you provide when you:

• Order our products;
• contact us via our website enquiry form;
• subscribe to our newsletter or special offers;
• request marketing to be sent to you;
• provide your information to us in person at a trade show;
• enter a competition, promotion or survey; or
• give us feedback or contact us in any other manner.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data is collected from the following parties:

• Analytics providers such as Google, Shopify, Meta and Microsoft, which may be based outside of the UK;
• Advertising networks such as Meta, Google, and Microsoft;

Contact, Financial and Transaction Data is collected from providers of technical payment and delivery services such as Stripe Inc, based outside the UK; and

Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. How will we use your personal data?

What are our legal bases for processing for the personal data?

 

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Contractual obligations  

In order for us to fulfil our contractual obligations to you we will need to use your personal data. For example, to deliver furniture to your address.

Legal or regulatory obligation 

We must comply with a number of statutory provisions when providing our services, which necessitate the processing of personal data. For example, we are required to comply with statutory and regulatory obligations relating to business such as HMRC and fraud/crime prevention.

Legitimate Interests 

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). For example, we may send you information of a new product or offer.

Consent  

We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. For example, you may provide consent to receive marketing updates or our newsletter.

You may withdraw consent at any time by contacting us to update your preferences, using the contact details in paragraph 11.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate:

 

Purpose/Use	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To set up an account for you on our website	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms, privacy notice or other important information about the products you are purchasing; and   (b) Dealing with your requests, complaints, providing you with an order status update and responding to your queries.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To enable you to partake in a competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e)Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)]
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business), provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products/services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business)

 

 

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We do not share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us with the contact details in paragraph 10.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product warranty registration, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookies Policy.

5. Who will data be shared with?

We may share your personal data with third-parties in order to carry out your requests, respond to your inquiries, fulfil your orders, or make various other features, services available to you through our websites. We share your personal data with specific third-party service providers that perform functions on our behalf, such as:

• APC Direct, a company based in the UK which provides delivery services;
• Tomsetts Distribution, a company based in the UK which provides delivery services;
• DX Delivery, a company based in the UK which provides delivery services;
• Worldpay, LLC, a company based in the United States which provides payment services;
• Stripe, a company based in the United States which provides payment services;
• Access Dimensions. a company based in the UK which provides IT services; and
• Fine Marketing Consulting Ltd, a web and marketing agency based in the UK.

We may also share your personal data where necessary to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers of data

In the course of the provision of our services we may transfer data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that one of the following safeguards are in place:

• Your data is being transferred to a country that has been deemed by the UK to provide an adequate level of protection for personal data; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

If you require further details of these safeguards please contact us using the details at paragraph 11.

7. Data Security and Confidentiality

Protecting the confidentiality and integrity of your personal data is a responsibility that we take seriously. We use appropriate technical and organisational measures to keep personal data secure against unauthorised or unlawful processing, and against accidental loss, destruction or damage. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

For example:

• Our employees have received training in data protection and how to handle your personal data;
• Where hard copies are created, these are securely stored;
• According to each department’s process and procedure, your personal data will be periodically reviewed and securely deleted if required; and
• Internal systems and networks are regularly tested.

8. Data retention

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes for which it is collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided (for example the warranty on some items of furniture is 10 years);
• any statutory, legal regulatory, tax, accounting or other obligations (for example 6 years +1 for HMRC);
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the potential risk of harm from unauthorised use or disclosure of your personal data;
• the amount and sensitivity of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

9. Your legal rights as a data subject

You have a number of legal rights under data protection laws in relation to your personal data:

• Right of access – you have the right to access your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
• Right of rectification – you have a right to request the correction of personal data that we hold about you. This enables you to have any inaccurate or incomplete data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object to processing – where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Right of portability – you have the right to have the personal data we hold about you transferred to a third party, or to you. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to object

• You have the right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing in paragraph 4’ for details of how to object to receiving direct marketing communications).
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the details in paragraph 11.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details set out in paragraph 11 below.

To a report a concern to the ICO, use one of the following:

online at https://ico.org.uk/concerns/ 
call 0303 123 1113 
write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

11. Contact details

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Privacy Officer using the email address customerservices@alexander-rose.co.uk.

12. Changes to the privacy NOTICE

We keep our privacy notice under regular review. This version was last updated on 3 June 2024. Historic versions can be obtained by contacting us.

13. Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Alexander Rose Ltd.
3 June 2024