privacy Policy

Welcome to the Brentwood Coffee privacy notice.

Brentwood Coffee respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Glossary:

1. Important Information and Who we are

2. The date we collect about you

3. How is your personal data Collected

4. How we use your personal data

5. Disclosures of your Personal Data

6. International Transfers

7. Data Security

8. Data Retention

9. Your Legal Rights

10. Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Brentwood Coffee collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account, sign up to our catalogue and emails, purchase a product or service, take part in a competition or provide a review.

This website is not intended for children and we do not knowingly collect data relating to children via our website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Brentwood Coffee is made up of different legal entities, including Brentwood Coffee and its subsidiaries and associates. This privacy notice is issued on behalf of Brentwood Coffee so when we mention “Brentwood Coffee”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Brentwood Coffee responsible for processing your data. Brentwood Coffee is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Brentwood Coffee

Name or team responsible for data privacy: Data Privacy Manager

Email address: sales@brentwoodcoffee.ie

You have the right to make a complaint at any time to a data protection regulator in Europe, in particular in a country where you work or live or where you believe your legal rights have been infringed. The Data Protection Commissioner is the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the relevant regulator, so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This privacy policy was last updated in May 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Apply for our products or services;

Create an account on our website;

Subscribe to our service or publications;

Request marketing to be sent to you;

Interact with us on social media;

Enter a competition, promotion or survey; or

Give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below.

Technical Data from analytics providers such as Google based outside the EU, from advertising networks or from search information providers.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services

Identity, Contact and Customer Journey data from our Customer Service support service provider. For more information see our cookie policy.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

See the table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at privacy sales@brentwoodcoffee.ie or unsubscribing from our email list by following the link at the bottom of all marketing emails you receive.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note, that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at privacy sales@brentwoodcoffee.ie if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

1

Purpose/Activity:

To register you as a new customer

Type of Data:

(a) Identity / (b) Contact

Lawful basis for processing including basis of legitimate interest:

Performance of a contract with you

2

Purpose/Activity:

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Delivery

(d) Saving contact and financial details securely on your account to speed up subsequent transactions, so that when you place your next order, your billing address and payment details will be automatically populated.

Type of Data:

(a) Identity / (b) Contact / (c) Financial / (d) Transaction / (e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

3

Purpose/Activity:

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of Data:

(a) Identity / (b) Contact / (c) Profile / (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

4

Purpose/Activity:

To enable you to partake in a prize draw, competition or complete a survey

Type of Data:

(a) Identity / (b) Contact / (c) Profile / (d) Usage / (e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

5

Purpose/Activity:

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of Data:

(a) Identity / (b) Contact / (c) Technical

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

6

Purpose/Activity:

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of Data:

(a) Identity / (b) Contact / (c) Profile / (d) Usage / (e) Marketing and Communications / (f) Technical

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

7

Purpose/Activity:

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of Data:

(a) Technical / (b) Usage

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(b) Performance of a contract with you 

8

Purpose/Activity:

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of Data:

(a) Identity / (b) Contact / (c) Technical / (d) Transaction / (e) Usage / (f) Profile / (g) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to develop our products/services and grow our business)

9

Purpose/Activity:

To provide you with a copy of our annual toy Catalogue in circumstances where you have subscribed to our postal catalogue mailing list

Type of Data:

(a) Identity / (b) Contact

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interest (to develop our products/services and grow our business)

10

Purpose/Activity:

To provide customer support via our web forms (Contact Us and Chat) and telephone helpdesk

Type of Data:

(a) Identity / (b) Contact / (c) Technical / (d) Usage / (e) Profile / (f) Transaction

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to ensure that customer queries, issues and complaints can be dealt with quickly and effectively, to identify problems within our systems or website and to seek to resolve these for the benefit of other customers)

11

Purpose/Activity:

To identify and prevent fraudulent transactions.

Type of Data:

(a) Identity / (b) Contact / (c) Technical / (d) Transaction

Lawful basis for processing including basis of legitimate interest:

(a) Necessary to protect our legitimate business interests.

(b) This also helps to protect our customers from fraud.

MARKETING

Given how we operate our business, it may be necessary to use the information we have about you in our marketing. Any use of your information for marketing will be both in our legitimate interests and yours. You have a right to object at any time to this use of your information by contacting sales@brentwoodcoffee.ie

Where you have given us your consent or if you have previously purchased from us, we may use your information to contact you about products that you have purchased, to tell you about goods and services which we consider may interest you, our offers available from time to time, or to send you a copy of our annual catalogue. Our marketing communications may be provided to you by email, post or such other means as we choose.

In addition to the right to object mentioned above, you will also be provided with the opportunity to opt out of receiving these marketing communications both at the time that you provide your contact information to us and at any time afterwards by clicking on the relevant link provided in an email or SMS or by contacting us at any time by contacting sales@brentwoodcoffee.ie

If you tell us that you do not want to receive any further marketing information from us, we will not contact you further for the purpose of marketing. However, we will not necessarily remove your information from our database(s) if it is necessary to retain the information for other non-marketing purposes such as where we need your information for compliance with our legal obligations. Please note that after you opt out of receiving marketing communications from us, it may take a few days to update our records during which time you may continue to receive marketing communications.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Smyths Toys group of companies for marketing purposes.