To help us provide the best possible service, we capture personal information about you but we respect and protect your privacy and do all we can to honour the trust you place in us by being transparent about what personal information we collect and how we use it, vowing to handle your data fairly and lawfully at all times.
This notice is to inform you about how we collect and protect any personal information you provide to us and how you can control what personal information we collect from you and what we do with it. It sets out how we intend to use your information, who we will share it with and what rights you have about use of your information.
This notice applies to all our activities under the above brands and however you provide personal information to us, whether you visit us online at any of our websites or visit our stores or contact us via social media or whether you telephone, email, write to or text us.
Here we provide you with details about:
WHAT PERSONAL DATA DO WE COLLECT?
We may collect the following information about you:
- Your name, age/date of birth and gender;
- Your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- Purchases and orders made by you;
- Your social media handles;
- Your online browsing activities on any of our websites including what items you store in your shopping bag;
- Your password(s);
- Information about the device you use to browse our websites including the IP address and the device type;
- When you make a purchase or place an order with us, your payment card details;
- Your communication and marketing preferences;
- Your interests, preferences, feedback and competition and survey responses;
- Your location;
- Your correspondence and communications with us; and
- Other publicly available personal data, including any which you have shared via a public platform (such as Instagram, YouTube, Twitter or public Facebook page.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data are collected directly, for example when you set up an online account on our websites, or send an email to our Customer Services team. Other personal data are collected indirectly, for example, when you browse our websites or undertake online shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
We may anonymise and aggregate personal data for insight and research but this will not identify anyone.
Our websites are not intended for children and we do not knowingly collect data relating to children.
HOW WE USE YOUR DATA
Swico Limited (and trusted partners acting on our behalf) use your personal data:
- To provide goods and services to you;
- To make a tailored website available to you;
- To manage any account(s) you hold with us;
- To verify your identity;
- For crime and fraud prevention, detection and related purposes;
- To contact you electronically about promotional offers, events, products and services which we think may interest you;
- For analysis, insight and market research purposes to better understand your needs and ensure we are giving you what you like;
- To administer competitions and identify and contact competition winners;
- To enable us to manage customer service interactions with you; and
- Where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
Swico Limited use your personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on our latest offers and events.
We aim to update you about products and services of interest and relevance to you as an individual.
You have the right to opt out of receiving promotional communications at any time, by:
This may not stop service messages such as order updates.
3. Personalisation and Automated Decision Making
In order to improve your shopping experience with us, when you visit any of our websites, you may receive personalised banner advertisements whilst browsing websites of other companies. Any banner advertisements you see will relate to your browsing activity on our websites from your computer or other devices.
These advertisements are provided by us via external market leading specialist providers using ‘cookies’ placed on your computer or other devices. You can remove or disable cookies at any time, see here for further information.
We may collect data directly from you, as well as analysing your browsing and purchasing activity, both online and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to ensure that we contact you with information on products, services, events and offers that are relevant to you. To do so, we use software and other technology (automated decision-making including profiling).
We may do this to decide what marketing communications are suitable for you and this activity is based on our legitimate interests to develop and improve our products and services for you.
You have the right to opt out of any automated decision-making processes including profiling at any time by:
In order to provide more personalised services and experiences, we may also ask your permission to review third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation. Some of our services enable you to sign-in via a third party service, such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow us to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).
What are Cookies?
Some cookies collect information about browsing and purchasing behaviour when you access our websites via the same computer or device. This includes information about pages viewed, products purchased and your journey around a website. All data passed by cookies is anonymous and will never contain individual detail such as your name, address, telephone number or payment details. For more detailed information about how cookies work, please visit www.allaboutcookies.org
How Are Cookies Managed?
The cookies stored on your computer or other device when you access our websites are designed by:
- Swico Limited or on our behalf, and are necessary to enable you to make purchases on our websites;
- Third parties who participate with us in marketing programmes; and
- Third parties who publish web banner advertisements for us.
What Are Cookies Used For?
Cookies are used with our marketing partners to present you with appropriate offers and advertising as you browse other sites on the internet, based on your browsing activity while on our sites. Cookies also allow us to work alongside our web analytics partners to see how you like to use our website, which pages or special functions you prefer and help us to promote them and make them better. This helps us to continually improve the relevance of our promotional communications, your shopping experience and our products and services.
The main purposes for which cookies are used are:
- 1: For technical purposes essential to the effective operation of our websites, particularly in relation to online transactions and site navigation.
- 2: For us to market to you, particularly web banner advertisements and targeted updates.
- 3: To enable us to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc.
- 4: To enable us to meet our contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.
What Cookies Do We Use?
There are two types of cookie that may be used during your visit to our site:
Session cookies are deleted after each visit to our site. For example, when you are browsing our site, it will remember you for the duration of your visit, but the cookie will be removed from your computer as soon as you close down your internet browser. Session cookies allow you to add an item to the basket and then move through the checkout. Disallowing these cookies via your web browser will mean you are unable to place an order on the site.
Persistent cookies remember you for a set period of time allowing wishlist products and/or previously viewed products to be displayed the next time you visit our site and whether you logged into or out of your account while browsing.
Swico Limited work with several partners who serve advertisements or present online offers on our behalf. Most of these marketing partners use both session and persistent cookies. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. All data collected by third party cookies is anonymous and will never contain your name, address, telephone number, email address or payment details.
Turning Off And Deleting Cookies
Most web browsers will provide the option to turn off, or disallow cookies. How you do this depends on the web browser you're using. Instructions for disallowing cookies can usually be found in the browser's 'Help' menu. Note that in common with most other transactional websites, if you only disable third party cookies, you will not be prevented from making purchases on our websites but refusing the cookies we have used via your web browser will mean that you are unable to make a transactional purchase on our website. You may also find that the functionality of many other websites and services will be affected. Cookies can be deleted using your web browser. However, unless they are disallowed they will be re-applied the next time you visit a website.
If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
For Microsoft Internet Explorer:
For Google Chrome:
For Mozilla Firefox:
SHARING DATA WITH THIRD PARTIES
We will never sell or rent your personal information to other organisations for marketing purposes.
We will not disclose your personal information to any third party, except for those referred to below.
We may share your data with:
- Other companies within our group;
- Purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organisation or otherwise;
- Our legal and other professional advisers, including our auditors;
- Credit reference agencies where necessary for card payments;
- Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
- To comply with our legal obligations and/or the administration of justice;
- To exercise our legal rights (for example in court cases);
- For the prevention, detection, investigation of crime or prosecution of offenders; and
- For the protection of our employees and customers.
- Our service providers and suppliers.
In order to make certain services available to you, we have partnered with certain trusted third parties including IT, mailing, payment services, delivery and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.
|Type of External Service Provider||Reason for Sharing Your Information|
LEGAL BASIS FOR USING DATA
We are required to set out the legal basis for our ‘processing’ of your personal data.
We collect and use customers’ personal data:
- 1: As necessary to perform our contract with you
- For the purposes of complying with our duties and exercising our rights under contracts for the sale of goods or services to customers; or
- 2: As necessary for the pursuit of our legitimate interests including:
- Selling and supplying goods and services to our customers;
- Promoting, marketing and advertising our products and services;
- Sending promotional communications which are relevant and tailored to individual customers (including administering loyalty schemes);
- To administer competitions and promotions and identify and contact competition winners;
- Understanding our customers’ behaviour, activities, preferences, and needs;
- Improving existing products and services and developing new products and services;
- Protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- Good governance, accounting and managing and our operations and complying with our legal obligations;
- Preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
- Handling customer contacts, queries, complaints or disputes;
- Managing insurance claims by customers;
- Protecting our company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
- Handling any legal claims or regulatory enforcement actions taken against us; and
- Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders or
- 3: As necessary for complying with our legal obligations including:
- Where you exercise your rights under data protection laws;
- For compliance with legal and regulatory requirements; or
- To establish or defend our legal rights; or
- 4: Based on your consent
You have the right to withdraw consent at any time. Where consent is the only legal basis for processing your personal data, we will cease to process your personal data for that purpose after consent is withdrawn.
HOW WE PROTECT YOUR DATA
Swico Limited is committed to keeping your personal data safe and secure.
Our security measures include:
- Encryption of data;
- Regular cyber security assessments of all service providers who may handle your personal data;
- Regular planning to ensure we are ready to respond to cyber security attacks and data security incidents;
- Daily penetration testing of systems;
- Security controls which protect the our IT systems infrastructure and our premises from external attack and unauthorised access; and
- Internal policies setting out our data security rules for our personnel.
- Regular training for our employees.
WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from The Watch Shop Holdings Limited asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety
- Keep your account passwords private because anyone who knows your password may access your account or be compromised if your account is accessed without authority.
- When creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed by hackers such as dictionary words, your name, email address, or other personal data that can be easily obtained. Also, frequently change your password. You can do this accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.
- Avoid using the same password for different online accounts.
HOW LONG WE KEEP YOUR DATA
We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.
In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organisational purposes and we will not keep your data for longer than is necessary for the purposes for which we collect them.
Record Retention Periods
|Record||Type of Personal Data||Retention Period|
|Contracts with Suppliers||Names||10 years after expiry|
|Supplier details||Names, addresses, email addresses, telephone numbers||Permanently|
|Rental and hire purchase agreements||Names||10 years after expiry|
|Payment services agreements||Names||10 years after expiry|
|Cookies||Webtracking information including IP addresses||5 years|
|Contracts with Customers||Names, addresses, telephone numbers, transactional details||10 years from date of transaction|
|Contracts with Customers – bank transfers||Names, addresses, telephone numbers, Bank and Branch||14 days|
|Contracts with Customers – waiting lists||Names and products||Until purchase or as long as customer requires|
|Contracts with Customers – pre-owned watches||Names, addresses, age and product||3 years|
|Contracts with Customers||Email addresses||website emails: 7 years, customer care emails: 7 years, store support emails: 2 years|
|Customer complaints||Names, addresses, telephone numbers, email addresses||7 years|
|Interest Free Credit applications||Customer emails, names, addresses, dates of birth, marital status, employment details, financial details such as income and major outgoings, bank account details||14 days|
|Interest Bearing Credit applications||Customer emails, names, addresses, dates of birth, marital status, employment details, financial details such as income and major outgoings, bank account details||14 days|
|Promotional materials||Names and customer images||3 years|
|Customer listings for promotional communications||Names and addresses, email addresses||30 days|
|Marketing databases||Names and addresses, email addresses||15 years|
|Social Media communications||Names, addresses, email addresses, transactional data, hobbies, interests, payment references||Permanently|
|Product and service reviews by customers||Names, emails and products services purchased||Personal data: 12 months, review content: permanently|
|Records of administration of watch and jewellery insurance claims for Insurance Companies||Names, addresses, telephone numbers, email addresses, insurance policy number, item claimed for, call recordings, bank sort code details||Permanently|
|Call recordings||Telephone numbers, call recordings||28 days|
|Customer live chat forum||Voice recordings images and messaging||28 days|
You have the following rights:
- The right to be informed about our processing of your personal data which is the aim of this Notice;
- The right to request access to personal data that we hold about you at any time;
- The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
- The right to object to processing of your personal data and/or to withdraw any consent you have given us and to opt out of any marketing communications that we may send you.
- The right to prevent processing that is likely to cause damage or distress to you or anyone else;
- The certain rights in relation to automated decision-making processes including the right to object to profiling;
- The right to request that we erase or destroy your personal data in certain circumstances (the right to be forgotten) for example when the data are no longer necessary for the purpose for which we collected them;
- The right to have your personal data provided to you by us in a structured, commonly used and machine-readable format and the right to have that data transmitted to another data controller. This is known as the right to data portability.
If you wish to exercise any of the above rights, you can always:
- 1: Call our Customer Services Team on telephone 01428 656822, but we will ask you to put your request in writing.
- 2: Email us at either email@example.com or
- 3: Contact us by post to Customer Services, Swico Limited, Meadway, Haslemere, Surrey, GU27 1NN, United Kingdom.
You have the right to lodge a complaint with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow SK9 5AF, United Kingdom if you believe we have not handled your personal data in accordance with the law. Further information, including contact details, is available at https://ico.org.uk.
Last Updated: June 2020