Privacy & Cookie Policy

How We Use Data

In General

We (and trusted service providers acting on our behalf) use your personal data :

- To provide goods to you;

- Where possible personalise your browsing experience when visiting our website;

- Manage your online account and/or klass reward card account you may hold with us;

- Verify your identity;

- For crime and fraud prevention, detection and related purposes;

- To contact you electronically about promotional offers and products (provided you consented to such communications being sent to you) that we believe are of interest to you. - To better understand your needs;

- To help us provide a better customer service when dealing with you;

- Where we have a legal right or duty to use or disclose your information (for example in relation to a legal dispute or in relation to an investigation by a public authority).

Klass VIP Card and Other Marketing

We use your personal data for electronic marketing purposes (with your consent) and may on occasion post mail to you on our latest offers or product ranges.

We communicate to you in this way in the belief based upon on prior interactions with you as a customer or visitor to our website that we are sending you information on products or offers that are of interest to you. You have the right to opt out of receiving promotional

communications at any time, by : 1. If you are member of our loyalty scheme and hold a Klass VIP Card when registering or re-registering at any time your details on our website at www.klass.co.uk/register and selecting the opt out option;

2. Using the “unsubscribe” link that is included in every marketing email we send you, you can also unsubscribe from any text messages by sending a text from your mobile to the “STOP” number displayed any marketing text message we have sent to you;

3. Contacting us via the any of the Contact Us methods set out in this Policy. If you have a Klass VIP Card, we may collect data directly from you, as well as analysing your browsing and purchasing history with us, both online and in store as well as your responses to marketing communications we have sent you. This data together with other data you have provided us with such as your date of birth and address, helps us to ensure that we are contacting you with relevant products and offers that are of interest to you. To better manage this and achieve more accurate result we use software and other technology that automates the processing of the data.

Sharing Data With Third Parties

Service Providers

So that certain services are available to you, we may need to share your personal data with some of our service providers. These include payment processing companies so we can process payments and refunds in respect of orders you make with us, IT companies who support our website and other business systems, operational companies such as delivery couriers, and marketing service providers who help us manage our electronic communications with you and recommend products that might interest you whilst browsing our website.

We ensure agreements are in place with such third parties to make sure we have their confirmation that appropriate data protection and security controls are in place and maintained when handling your personal data. Contractually these third parties are only permitted to handle the data to provide the service needed for us and to you and for no other purposes. If we stop using their services , any of your data held by them will either be deleted or rendered anonymous.

Other Third Parties

Other than with our service providers, we do not share your personal data with any third parties, except as set out below. We never sell or licence/rent our customer data to other organisations or individuals for marketing purposes.

We may share your data with : Credit reference agencies where necessary for card transactions; Governmental departments, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so :-

- By virtue of a legal requirement;

- To exercise our legal rights (for example in court cases); - For fraud and crime prevention, or the investigation or detection of a crime or to prosecute an offender;

- for your protection, the protection of customers or our employees.

How Long Do We Retain Your Data

We will not retain your data for longer than necessary for the purposes set out in this Policy. Whilst different periods of retention apply for different types of data, as a general rule we will not normally hold any personal data beyond 6 years after your last interaction with us.

What Sort Of Personal Data Do We Collect

- If you have an online account with us : your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. - Details of your purchases and returns with us either in store if you are a member of our loyalty scheme and have used your Klass reward card or online.

- Details of your interactions with us thought our customer support, in store or online. For example we collect notes from our conversations with you, details of complaints or comments you make, details of purchases, items viewed online or added to your basket, voucher redemptions, web pages you visit and how and when you open or click on emails we may send to you.

- Information gathered by the use of cookies in your web browser. You can learn more about how we use cookies.

- Payment card information Whilst we collect your card details so we can process the payment needed to complete your purchase, this is done via an encrypted connection that is shown by the padlock or secure symbol in the address bar as being recognised by your browser as being secure and we do not store your card information on our systems. We pass on your details via the encrypted connection to our payment provider’s secure and fully compliant environment who take care of securing all sensitive data using industry leading technology to safeguard your card against digital breaches so as to keep your card data completely secure at all times.

- Your comments and reviews on our products and service.

How Do We Protect Your Data

We are committed to keeping your personal data safe and secure. Our security measures include :- - encryption of data

- only sharing data with organisations that we are satisfied similarly adhere to commitment towards keeping your personal data safe and secure

- security controls which protect all data we hold on our systems from external attack and unauthorised access

- training our employees However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. We will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this policy.

The Legal basis for us processing customer personal data

General

We collect and use personal customers’ personal data because :

-it is necessary in the pursuit of our legitimate interest (as set out below);

- the customer has consented to the processing of his or her personal data when providing their email address whilst subscribing to the newsletter so as to receive direct marketing communications from us;

-To comply with our contractual obligations in respect of a contract for the sale of goods to a customer; or

- To comply with our legal obligations. Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

Our Legitimate Interests

The normal legal basis for processing customer data, it that it is necessary for our legitimate interests, including : - Selling and supplying goods and services to our customers;

- Protecting customers, employees and other individuals and maintaining their safety, health and welfare;

- Promoting, marketing and advertising our products;

- Sending electronic marking communications to existing customers who have opted to receive such communications when providing their contact details to us;

- Sending other promotional communications which are relevant and personalised to individual customers (including managing the Klass rewards card scheme)

- Improving existing products, ranges and promotions;

- Understanding our customers’ behaviours, preferences, interests and needs;

- Complying with legal and regulatory obligations;

- Preventing, investigating and detecting crime, fraud and prosecuting offenders as well as assisting with law enforcement agencies;

- handing customer contacts, queries, reviews, complaints or disputes;

- protecting Eleganze Limited, its employees and customers, by taking appropriate legal action against third parties who have committed or appear to have committed criminal acts or are in breach or we suspect are in breach of legal obligations owed to us;

- handling legal claims or regulatory enforcement actions taken against or for us;

- fulfilling our duties to customers, employees, shareholders and other stakeholders.

Your Rights

You have the following rights :

- The right to request :

- Access to what personal data we hold about you at any time, free of charge in most case;

- The correction of your personal data when incorrect, out of date or incomplete;

- That we stop using your personal data for direct marking (either though specific channels or all channels).

- That we stop any consent based processing of your personal data after you withdraw that consent

- The deletion of the data we hold about you, in specific circumstances; 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 (such as the end of a returns period) You can contact us to request to exercise these rights at any time by writing to Data Access request, Eleganze Limited, Unit B Royle Pennine Trading Estate, Lynroyle Way, Rochdale Lancs OL11 3EX, or by email to info@klass.co.uk. To ask for your information to be amended, please update your online account, re-register your reward card online, or contact our customer services team. If we choose not to action your request we will explain to you the reasons for our refusal.

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 consent.

Where We Rely On Our Legitimate Interests

In cases where we are processing your personal data on the basis of legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must do so unless we believe we have a legitimate overriding reason to continue to processing your personal data.

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.

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 Policy. 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 so act.

How To Stop The Use Of Personal Data For Direct Marketing

There are a number of ways to stop direct marketing communications from us:

- Click the ‘unsubscribe’ link in any marketing email communications that we send to you. We will then stop any further marketing emails.

- If when subsequently registering your reward card or creating an online account you indicate you do not consent to being sent emails and/or text messages from us.

- Email your request to info@klass.co.uk including enough information so we can identify your email address or if your request only relates to text messages your mobile telephone number. An email request with a header that says “unsubscribe” is acceptable.

- Write to us with your request to Customer services, Eleganze Limited, Unit B, Royle Pennine Trading Estate, Lynroyle Way, Rochdale Lancs OL11 3EX

Please note you may continue to receive communications from us for a short period after making your request for this to stop while our systems are fully updated.

Any Questions ?

We trust that this policy has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that have not been address in this Policy then please contact us and we will be pleased to help you : - By email to datapolicy@klass.co.uk

- Or write to us at Data Policy, Eleganze Limited, Unit B, Royle Pennine Trading Estate, Lynroyle Way, Rochdale Lancs OL11 3EX

For information on Cookies please go to www.klass.co.uk/cookies

This Policy was last updated 17/05/2018