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Privacy Policy

WE SECURELY STORE INFORMATION ABOUT YOU IN ORDER TO PROVIDE YOU WITH THE BEST POSSIBLE SERVICE.

To ensure that we can provide you with a positive experience we securely capture and store information about you.

We are W.D. Coe Limited, registered to 20-28 Norwich Road, Ipswich, Suffolk, IP1 2NH, United Kingdom and we are a ‘Data Controller’ registered with the UK Information Commissioner’s office with the registration number ZB316404. Our ‘Data Protection Officer’ is The DPO Centre LTD, 50 Liverpool Street, London, EC2M 7PY, United Kingdom and is contactable on hello@dpocentre.com.

We have provided this Privacy Policy to inform you of how we collect, protect and use your personal information. We only collect information about you that we will genuinely use to give you a better shopping experience and in accordance to the General Data Protection Regulation.

This privacy policy applies to whichever way you provide personal information to us, whether visiting in-store or at events, writing or emailing us, telephoning or texting or via social media.

If you would like to contact us regarding this Privacy Policy, our details are as follows:

Email: help@coes.co.uk

Post: W.D. Coe Ltd, 20-28 Norwich Road, Ipswich, Suffolk, IP1 2NH

Telephone: 01473 256061

VAT Registered Number: GB 102 1225 48

 

What Personal Data Do We Collect?

We may collect the following information:
  • Your name, title, gender, date of birth and other relevant personal demographic details.
  • Your contact details such as billing address, delivery address, email address and telephone (including mobile) numbers.
  • Your purchase and order information.
  • Your usage experience regarding our website, products and services.
  • Your marketing and communication preferences.
  • Your correspondences and communications with us.
  • Your job application information.
  • Your device and browser information including IP address.
  • Your transaction data including payment card details and details about payments to and from you.
  • Your user profile data including usernames, marketing preferences and order history.
  • Your image data such as CCTV images and photography during events where you have not objected to us using it.

This list is not definitive, however, comprises of the most common data types and you are under no statutory or contractual requirement or obligation to provide us with your personal information. However, to help provide you with customer service in an efficient and effective manner we collect the above data.

We do not knowingly collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.

We also do not collect information about criminal convictions or offences.


We obtain personal data from sources as follows:

  • Directly from you when you interact with us, for example when you:
  • - Create a Coes Option or Coes Subscription account

    - Buy our products in a store or online.

    - Sign up to our mailing lists.

    - Request information.

    - Write to us.

    - Phone our customer services team.

    - Enter a competition.

    - Take part in a survey.

    - Give us feedback or post comments or reviews.

    - Apply for a job or send a CV.

    - Attend external local events.

    - Indicate on a form that you would like to receive communication from us.

  • From customers, for instance:
  • - If they provide your details in relation to an order. Please note if you are providing another person’s details, ensure you have that person’s explicit consent to do so.

  • From automated technologies such as cookies and tags when you use our website – for more information, please see our cookies notice.

  • We only use data in a way that is necessary for the purpose for which it has been collected. We use your data:
    • To provide our products and services.
    • To verify your identity.
    • To assist you with customer service enquiries and requests.
    • To manage any accounts, you may have with us (financial, loyalty, customer or other).
    • To personalise your website or shopping experience.
    • To comply where necessary with a legal or regulatory obligation.
    • To provide you with personalised marketing communications.
    • To carry out billing and administration activities, including refunds and credits.
    • To review for analysis or research purposes so that we can provide a better customer experience.

    For the purposes of marketing communications, we use your personal data to provide you with information on products, services, promotions or events that we consider may be of interest to you. We only do this where we have been provided your active consent and shown interest in receiving these marketing communications. These communications may be via online, email, post, social media, review sites and advertisers.

    You can opt out of receiving these marketing communications by unsubscribing from our emails, by returning our journals or offer mailing to the address indicated, or by contacting us via the details provided towards the beginning of this Privacy Policy.


    Our website uses cookies to capture information. This includes information that helps us to recognise you as a unique visitor and to allow us to tailor the content of our site to match your preferred interests. More detailed information can be found on our Cookie Policy which offers full transparency about the cookies we use and allow you to make an informed choice about your acceptance of cookies on our site.

     

    To provide you with the best possible service, we do on occasion provide your personal data to trusted third parties. Where possible this data is anonymised. We may share your data with:
    • Other companies within the trading group, currently: Coes, Golding of Newmarket, Goddards.
    • Service providers such as logistics providers, technical and support partners and recruitment service providers.
    • Law enforcement, public or government agencies and officials, regulators including any other person or entity that has the appropriate legal authority to request personal data.
    • Any specific parties where we have your active consent to do so.
    • Third parties if we need to provide personal data to establish, exercise or defend our legal rights (including preventing fraud and reducing credit risk).
    • Payment gateway providers, such as PayPal and Sage Pay.

    We will never sell or rent your personal data to other organisations for any purpose.


    Lawful processing

    To process personal data, we must have a lawful basis to do so. We always ensure that this is the case, and we set out our lawful basis below. However, please note that more than one may apply at any given time, for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with legitimate interests, where we will always carry out a legitimate assessment prior to the processing.

    We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.

    Please contact us if you would like more information, and on situations in which more than one lawful basis applies.

    Legitimate Interests

    We process your personal information for our legitimate business purposes, which include the following:

  • To conduct and manage our business.
  • To identify suspicious purchasing activity (for example, where a card has been used for high-volume and/or high-value purchases or where cardholder and delivery addresses differ) – however, we do not make automated decisions on the basis of such profiling.
  • To ensure our website and systems are secure (for example, by conducting security penetration tests on our website to ensure our security tools are effective).
  • To personalise your web experience – for example, by tailoring our products and offers to you.
  • To allow you to review a product you have purchased.
  • To analyse, improve and update our services for the benefit of our customers.
  • To deal with complaints.
  • Where you have made a purchase from us, to let you know about our products, services, promotions or events that we consider may be of interest to you (and which may be tailored to your interests as construed from your purchase history). We do this only where you have provided us with a preferred means of contact for this purpose. We carry out this processing on the legal basis that we have a legitimate interest in marketing our products and services, and only to the extent that we are permitted to do so by applicable direct marketing laws. You can opt out of receiving this information by unsubscribing from our emails, by returning our journals or offer mailings to the address indicated, or by contacting us as set out in Section 1 above.
  • Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered, and we will carry out a Legitimate Interest Assessment prior to the processing of your data.

    Compliance with laws

    We may process your personal data in order to comply with applicable laws (for example, if we are required to co-operate with an investigation pursuant to a court order).

    If you give us information on behalf of someone else, you confirm to us that you have their permission to do so and that they are aware of the contents of this privacy policy and do not have any objection to our processing their information in accordance with this policy.

    You are responsible for informing us of any changes in your details such as change of address. You have a right to ask us to correct any inaccuracies in the information we hold about you.

    You have a right to ask what information we hold about you. We may charge you a small fee for this (the statutory fee is currently £10). You may contact us at the address found towards the beginning of this Privacy Policy.

    If you are under 16 please do not provide us with any personal information unless you have the permission of your parent or guardian to do so.

    Please note that we're not responsible for the content of external websites.


    Coes have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorised Coes employees and third parties processing data on our behalf have access to your personal data.

    Coes employees who have access to your personal data are required to adhere to the Coes Privacy Notice and we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by Coes.

    The security measures we have in place include:

  • Regular reviews of information collection, storage and processing practices to protect against unauthorised access.
  • Restriction of access to personal information.
  • Monitoring of systems storing and processing information.
  • Use of secure technologies (e.g. SSL, encryption)
  • Scenario planning and crisis-management exercises to ensure we are ready to respond to cyber security attacks and data security incidents.
  • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
  • We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us. Any transmission is at your own risk. Therefore, we recommend that information such as bank details or passwords are not sent to us by email. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
  • Please contact us using the details in section 1 of this notice if you would like more information about this.

  • We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.


    Although we are based in England, we may transfer your personal information to a location (for example, to a secure server) outside the European Economic Area, if we consider it necessary or desirable for the purposes set out in this notice.

    In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission “adequacy decision” applies (this is a decision from the European Commission confirming that adequate safeguards are in place in that location for the protection of personal data), or will be carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, or by the adoption of EU-US Privacy Shield.


    We draw your attention to your following rights under data protection law:

  • Right to be informed about the collection and use of your personal data.
  • Right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information – you will be asked to provide proof of your identity and residential address, and we may ask you to provide further details to assist us in the provision of such information.
  • Right to have inaccurate personal data that we process about you rectified – we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved to a new house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us; please also update us in the event this information changes.
  • Right of erasure – in certain circumstances you have the right to have personal data that we process about you blocked, erased or destroyed.
  • The right to object to, or restrict: - the processing of personal data concerning you for direct marketing.
  • Decisions being taken by automated means which produce legal effects concerning you or that similarly significantly affect you.
  • In certain other situations, to our continued processing of your personal data
  • The right of portability of your data in certain circumstances.
  • We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    Please contact us using the details provided towards the beginning of this Privacy Policy if you would like to exercise any of these rights or know more about them.

    These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/.

    To form a contract with you, we will need some or all the personal data described above so that we can perform that contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the data, the contract could not be performed.

    If you sign up to our mailing list, you will have to provide certain personal data. Of course, you may decide to stop receiving our mailings at any time.

    We hope that you will be satisfied with the way in which we approach and use your personal data.

    Should you find it necessary, you have a right to raise a concern with the information regulator, the Information Commissioner’s Office: https://ico.org.uk/.

    However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details in section 1 above, so that we have an opportunity to resolve it.

    Last modified: 12 June 2023

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