The data controller is Purepay Retail Limited (referred to in this policy as “we” or “us”).
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why this privacy and cookies policy (“Policy”) has been developed, which:
sets out the types of personal data that we collect
explains how and why we collect and use your personal data
explains when and why we will share personal data within and with other organisations; and
explains the rights and choices you have when it comes to your personal data
This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:
shopping with us over the phone, or online or otherwise using any of the websites (“our Websites”) where this Policy is posted; or
being a member of a loyalty scheme where available
obtaining staff discount
This Policy also applies if you contact us or we contact you about our Services.
Some other parts of our Group of companies may need to collect and use personal data to provide you with their products and services and for certain other purposes. They have their own privacy policies that explain how they use your personal data.
Personal data we collect
This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.
When you register for our Services, you may provide us with:
Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title
Information relating to your membership of a loyalty scheme where available
Your account login details, such as your username and the password that you have chosen
When you shop with us online or browse our Websites, we may collect:
Information about your online purchases (for example, what you have bought, where and when you bought it and how you paid for it)
Information about your online browsing behaviour on our Websites and information about when you click on one of our adverts (including those shown on other organisations’ websites)
Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)
When you shop with us using the staff discount scheme, a loyalty scheme, vouchers or coupons, we may collect:
Transaction information, including the in-store and online purchases when you use a staff discount card or any loyalty scheme and how you use coupons and vouchers within Purepay Retail Limited.
When you contact us or we contact you or you take part in promotions, competitions, surveys or questionnaires about our Services, we may collect:
Personal data you provide about yourself anytime you contact us about our Services (for example, your name, email address and contact details), including by phone, email or post or when you speak with us through social media
Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
Your feedback and contributions to customer surveys, feedback sources and questionnaires
Other sources of personal data
We may also use personal data from other sources, such as specialist companies that supply information, online media channels, our Retail Partners and public registers. For example, this other personal data helps us to:
manage your Loyalty account (including the allocation of Loyalty points) where available;
review and improve the accuracy of the data we hold; and
improve and measure the effectiveness of our marketing communications, including online advertising.
How and why we use personal data
This section explains in detail how and why we use personal data.
Make our Services available to you
Manage the accounts you hold with us, including any Loyalty account where available and staff discount scheme
Process your orders and refunds
Why do we process your personal data in this way? We need to process your personal data so that we can manage your customer accounts, provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.
Manage and improve our day-to-day operations
Manage and improve our Websites
Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you
Why do we process your personal data in this way? We rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range, services and stores. This allows us to serve you better as a customer.
Detect and prevent fraud or other crime
Why do we process your personal data in this way? It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our Services.
Personalise your Purepay Retail Limited experience
Use your online browsing behaviour as well as your in-store and online purchases (including Loyalty transactions where available) to help us better understand you as a customer and provide you with personalised offers and services.
Why do we process your personal data in this way? Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer.
Provide you with relevant marketing communications (including by email, post or online advertising), relating to our products and services. As part of this, online advertising may be displayed on websites across Purepay Retail Limted and on other organisations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of Purepay Retail Limited.
Why do we process your personal data in this way? We want to ensure that we provide you with marketing communications, including online advertising, that are relevant to your interests. To achieve this we also measure your responses to marketing communications relating to products and services we offer, which also means we can offer you products and services that better meet your needs as a customer. You can change your marketing choices, both when you register with us, and at any time after that via your preference centre options.
You also have choices when it comes to online advertising. We set out below your choices when it comes to cookies, and how you can control your online behavioural advertising preferences.
Contact and interact with you
Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us
Why do we process your personal data in this way? We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications
Manage promotions and competitions you take part in, including those we run with our external agencies
Why do we process your personal data in this way? We need to process your personal data so that we can manage the promotions and competitions you choose to enter.
Invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by Purepay Retail Limited and by other organisations on our behalf
Why do we process your personal data in this way? We carry out market research to improve our Services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services or any Loyalty or rewards scheme.
To help us to better understand you as a customer and to be able to provide you with services and marketing communications, including online advertising, that are relevant to your interests we also combine personal data we collect when you make purchases in-store using Loyalty with personal data collected from our Websites and other sources.
Sharing personal data within Purepay Retail Limited
This section explains how and why we share personal data with other companies within Purepay Retail Limited.
We may share the personal data we collect with other companies in Purepay Retail Limited. For example, we share personal data within our Group for order fulfillment, fraud prevention and group reporting.
Sharing personal data with Retail Partners and Service Providers
This section explains how and why we share personal data with Retail Partners and Service Providers.
When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.
We work with a number of Retail Partners who –
sell products through our Services, for example Evri; or
offer products, services and/or discounts.
We only share personal data that enable our Retail Partners to provide their services. For example, when you place an order with Purepay Retail Limited, we will give the relevant Retail Partner, for example Yodel, your name and contact details so that they can deliver your items.
We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing and combining data, processing payments and delivering orders. We only share personal data that enable our Service Providers to provide their services.
Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products and services, on those online media channels on our behalf. For example, you may see an advert for our products and services as you use a particular social media site or watch television through your pay TV account.
Sharing personal data with other organisations
This section explains how and why we share personal data with other organisations.
We may share personal data with other organisations in the following circumstances:
if the law or a public authority says we must share the personal data;
if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);
to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us; or
to any other successors in title to our business.
How we protect personal data
We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.
We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. We only authorise access to employees who need it to carry out their job responsibilities.
We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you.
We will reveal only the last four digits of your credit card number when confirming an order.
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.
Marketing and market research
This section explains the choices you have when it comes to receiving marketing communications and taking part in market research.
We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.
We also like to hear your views to help us to improve our Services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.
Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop or mobile device.
Improve the way our Websites work
Cookies allow us to improve the way our Websites work so that we can personalise your experience and allow you to use many of their useful features.
Improve the performance of our Websites
Cookies can help us to understand how our Websites are being used, for example, by telling us if you get an error messages as you browse.
These Cookies collect data that is mostly aggregated and anonymous.
Deliver relevant online advertising
Cookies used for this purpose are often placed on our Websites by other organisations, and always with our permission. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.
To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example your use of in-store purchases.
Measuring the effectiveness of our marketing communications, including online advertising
Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.
Your choices when it comes to Cookies
You can withdraw the consent you give us to use third party, non-essential cookies at any time on this page by toggling the switch below to 'remove consent'. If you choose to disable some or all Cookies, you may not be able to make full use of our website. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in. You may not receive any cashback or third party promotion if we cannot confirm the purchase using order confirmation technology. You can give your consent again at anytime on this page too.
You can also use your browser settings to accept or reject new Cookies and to delete existing Cookies regardless of the consent you give us. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. Any settings you change in your browser will overwrite the settings you choose on this page.
Where we display personalised adverts on other organisations’ websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices website.
Third parties operating through our Websites and Mobile Apps
Our partners are listed below with information about the services they provide to us. This list is not exhaustive but it does include those partners with whom we have an established relationship and whose cookie technologies are most frequently deployed through our services.
Measurement & Personalisation
To analyse how our services are used, including to test different content versions. This data may also be used to enable us to personalise our services and the marketing of our services.
To personalise adverts shown to you via Purepay Retail Limited and on other websites based on your interactions with The Edinburgh Woollen Mill Ltd. For example, by using data about your transactions with TPurepay Retail Limited, what you have in your basket and the pages and products you look at.
To market to you via social media platforms and to enable social sharing and engagement on our websites. These companies may use your data for their own purposes, including to profile and target you with other advertising.
Your rights in connection with personal information
We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend them.
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a "data subject access request" or "SAR"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Complete the form below;
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact;
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, repetitive or vexatious. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data protection officer
The Board of Directors has made the decision that Purepay Retail Limited of Companies shall not appoint a Data Protection Officer. This decision will remain under regular review. However, the Group GDPR Steering Committee led by the Group Company Secretary shall oversee compliance with this privacy notice and other aspects of GDPR compliance and the Group Company Secretary shall report to Purepay Retail Limited Board on issues relating to GDPR compliance for the Group, while day to day responsibility is delegated from Purepay Retail Limited Board to the Group GDPR Steering Committee the ultimate responsibility for compliance with GDPR shall rest with the Group Board Purepay Retail Limited as the immediate parents of the trading companies.
If you have any questions about this privacy notice or how we handle your personal information, please contact the Group Company Secretary. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
For postal enquiries;
The Company Secretary
Purepay Retail Limited
5 Castle Street
If we do not satisfactorily deal with any concern or complaint you raise in relation to our use of your personal data then you have the right to seek advice from the ICO (Information Commissioner). You can access the free helpline on 0303 123 1113 or access live chat or make an online communication at