1.2 If you have any questions about how we use your personal data, please contact email@example.com.
2.3 Bestway Retail Limited is registered with company number Co No. 4103203 and is registered with the Information Commissioner’s Office, or ICO, under registration number ZA387140.
3.2 We may need to verify your identity in order to process your request and ask you to provide valid identification documents to allow us to do so.
Information you give us
4.1 We will collect your name and contact details, if you have submitted an enquiry via the Contact Us page on the Website or provided your email address in-store.
4.2 When you register with Bestway Retail’s Websites, including “The Club” (Bargain Booze only), or placing orders or making “Click & Collect” orders (Bargain Booze only) or the App (Bargain Booze only), we collect and use some or all of the following:
(a) full name;
(b) date of birth;
(c) address, e-mail address and contact details;
(d) your preferred store;
(e) credit or debit card details;
(g) an indication of what offers and products you are interested in;
(h) an indication of your hobbies and pastimes and family time.
4.3 We collect and use the following personal data about you when you become a supplier and fill in forms on the Website or hard copy application forms:
(a) full name;
(b) address and contact details; and
(c) you may also be required to give us information about your business, business partners, beneficial owners or directors in which case you must ensure that you have permission to do this.
Other Information we collect
4.4 We also collect and use the following personal data about you indirectly:
(a) if you are a supplier of Bestway, information obtained from any credit checks or other checks we are required to carry out for legal and regulatory purposes (see the section on ‘Anti Money Laundering/ Sanctions’ below for further information);
(b) in order to administer the Website and understand how the Website is used, we may collect technical information including your IP address, your login information, products you have viewed or searched, browser type, plug-ins you use, operating systems and platforms, URL, page response times, download errors, length of visits to certain pages, page interaction information, methods used to browse away from a page;
(c) information collected through the App (Bargain Booze only), such as your access to it and redemption of offers;
(d) purchases you make via a Website using “click and collect” (Bargain Booze only) or for orders placed online; and
(e) information collected using CCTV surveillance in our stores or other sites.
5.1 We use personal data held about you for the following purposes in line with our legitimate interests to administer the Website and the App (Bargain Booze only), to engage with users when they request our products and services, and provide us with products and services and to protect and exercise our rights as a business:
(a) to respond to your queries;
(b) to manage your participation in the Club (Bargain Booze only), which may include issuing emails, SMS messages and vouchers to advise you of promotions that take account of your personal preferences;
(c) to provide you with your goods and information about your goods and to provide you with information via the App (Bargain Booze only), email, or SMS about our promotions and offers, to make suggestions and recommendations to you about goods or services that may interest you (for further information, see the section on ‘Marketing’ below);
(d) to analyse your purchases and purchase behaviour so we can provide you with vouchers and notifications of promotions that are tailored to you;
(e) if fraud is suspected or identified then this will be recorded and details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. The information may also be used to prevent theft, fraud and money laundering for example, when checking details for customer registrations, credit applications or managing credit accounts; and
(f) in relation to CCTV, for the prevention of crime and for security purposes.
5.2 We will also use your personal data, for example, your name, address and contact details, to carry out our contractual obligations to provide you with products or services which you have ordered or purchased from us and to contact you in relation to such products and services;
6.1 Special protection is given to certain kinds of personal data that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership (‘special categories of personal data’) or about your criminal convictions or offences.
6.2 Where we collect any special categories of personal data, we will take appropriate steps to ensure that we have explicit consent or another legal basis to hold, use and retain the information.
7.1 We may share your personal data:
(a) with other members of the Bestway group – for example, for administration or reporting purposes, or for marketing purposes where you have indicated that you wish to receive marketing from other group companies;
(b) selected third parties for the performance of our contractual obligations with you such as Franchisees who may operate the business where you collect “click and collect” (Bargain Booze only) goods from; (c) sub-contractors we may use in technical and payment services;
(d) where you have agreed to receive marketing emails from us, we need to pass your personal data on to our service providers who help us with these marketing activities;
(e) analytics and search engine providers that assist us with improvement and optimisation of our site who may anonymise the information and send on to third parties for statistical purposes; and
(f) credit reference agencies and other background check providers.
7.2 Occasionally, we may share personal data with relevant third parties where:
(a) you have given us your consent to do so;
(c) it is fair and reasonable for us to do so in the circumstances.
8.1 We may need to transfer your information outside the UK to service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area (“EEA”), such as the USA.
8.2 We may need to transfer your personal data to territories that are outside the EEA. We will only transfer your personal data outside the EEA where either:
(a) the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal data, or
(b) we have put in place our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal data is kept safe by carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses. Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your data. 8.3 If you would like further information, please contact firstname.lastname@example.org.
9.1 If you are a customer, we will send you emails, SMS messages and messages via the App (Bargain Booze only) to communicate relevant news and information about promotional products unless you tell us that you do not wish to receive them.
9.2 You can unsubscribe at any time by clicking the “unsubscribe” link in any marketing email which you receive, by emailing us at email@example.com, writing to us at Bestway Retail Limited, Data Protection Office, Unit 1 Weston Road, Crewe CW1 6BP or, if you are registered to shop online you can manage your preferences on the manage my data tab or unsubscribe using any of the other methods above.
10.1 We will not retain your personal data for any longer than is necessary for our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements. If you have any questions about data retention than please email firstname.lastname@example.org.
10.2 Where we have been using your personal data to provide you with marketing, we will delete your personal data following your request to be removed from our marketing list.
You can make a complaint to us by contacting us via email@example.com or to the data protection supervisory authority – in the UK, this is the Information Commissioner’s Office, at https://ico.org.uk/.