Moncrief.co.uk (“our website”) is provided by Sterling Wholesale Limited, a licenced retailer of the Moncrief Brand ,(“we”, “our” or “us”). We hold an exclusive licence to distribute Moncrief products in the UK, Europe, Australia and the United States of America. We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for how and what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (“your personal data”) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”).
Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by trusted third parties to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we may collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
- Your name, address and contact information, including email address and telephone number.
- Any delivery addresses specified for your order.
- Your gender (if you choose to give this to us).
- Your billing information, transaction and payment card or other payment information you provide to us or via our third-party payment handler.
- Details of any information, feedback or other matters you give to us by phone, email, post or social media.
- Your account details, such as username and log in details.
- Your activities on and use of our website.
- Your purchase history and saved items.
- Information about how you use our website and technology systems.
- Your responses to surveys, competitions and promotions.
You must provide this personal data to use our website and the services on it unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case, we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, we you enter or send us information, such as when you register with us, purchase products, send us feedback or participate in surveys; and
- indirectly, such as your browsing activity while on our website. We will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below.
How and why we may use your personal data
Under data protection law, we can only use your personal information if we have a proper reason, e.g.:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when rely on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contact us.
| What we use your personal data for: | Our reasons: |
| Creating and managing your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
| Providing products to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us |
| Enforcing legal rights or defend or undertake legal proceedings | Depending on the circumstances:
|
| Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
|
| Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances:
|
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices | Depending on the circumstances:
|
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us understand our customer base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Updating and enhancing customer records | Depending on the circumstances:
|
| Marketing our services to existing and former customers | For our legitimate interests, ie to promote our business to existing and former customersSee ‘Marketing’ below for further information |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvencyIn such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances:
|
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contact us on the details below; or
- using the ‘unsubscribe’ link in or emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products in the future or if there are changes in the law, regulation or structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share your personal data with:
- third parties we use to help deliver our products to you, e.g. payment service provides, warehouses and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies, website hosts and website analytics providers; and
- our bank.
We or the third parties mentioned above occasionally share personal data with:
- our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
- other parties that may have or may acquire control or ownership of our business (and our or their professional advisors) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or the event of our insolvency. Usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. If you stop using your account we will delete or anonymise your account data after ten years.
Transferring your personal data out of the UK
Countries outside of the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as the ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here: A guide to international transfers | ICO;
- there are specific safeguards in place, together with enforceable rights and effectively legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK we do so on the basis on an adequacy regulation or (where this is not available) by legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event that we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any change to the destinations to which we send personal data or in the transfer mechanism we rely on to transfer personal data internationally will be notified to you in accordance with the sections on ‘Changes to this privacy policy’ below.
Cookies
A cookie is a small text file which is placed onto your device when you use our website. We use cookies on our website to help us recognise you and your device and store some information about your preferences or past actions.
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.
For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office – Cookies | ICO.
Your rights
You have the following rights, which you can exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object to use | The right to object:
|
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects youWe do not make any such decisions based on data collected by our website |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeYou may withdraw consents by contacting us. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us. You may also find it helpful to refer to the guidance from the UK’s Information Commission on your rights under the UK GDPR.
If you would like to exercise any of your rights, please email us using the details provided in this privacy policy. When contacting us, please:
- provide enough information to identify yourself and any additional identity information we may reasonably request from you; and
- let us know which right(s) you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.
You also have the right to lodge a compliant with the Information Commissioner. They may be contact using the details at https://ico.org.uk/make-a-complaint/ or by telephone: 0303 1231113.
Changes to this privacy policy
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you.
How to contact us
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Please contact us by email at [email protected]