Privacy Policy

1. Introduction
1.1. This privacy policy (“Privacy Policy”) is part of the (“Terms of Use & Sale”) for the use of the website at https://jeroboams.co.uk/ (“Website”) operated by Jeroboams Shops Limited, (“we”, “us”, “our”) and the supply of goods and services by us to customers (“you”, “your”). Capitalised terms have the meanings in the Terms of Use & Sale, unless they are defined in this policy. Our details are stated in Clause 1 of the Terms of Use & Sale.

1.2. We decide the purposes and means of processing of personal data that is collected about you when you deal with us. We are committed to protecting and respecting your privacy and we have legal obligations to do so as the ‘controller’ of your personal data under the Data Protection Act 1998/2018 (the “Act”).

1.3. This Privacy Policy and the Terms of Use & Sale explains what types of personal data is collected, the purposes for which it is collected and processed, the legal basis for that and the organisations or types of organisations, if any, to which we may provide your personal data. It is necessary for you to agree to the Terms of Use & Sale, including the Privacy Policy, and for us to collect, process, share and store the personal data as described in order for us to be able to transact and communicate with you, and interact with you via the Website.

1.4. The Website may from time to time contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies and any relevant service terms and conditions before you submit any personal data to those websites. We are not responsible for the content of any other websites or services.

2. What personal data do we collect?

2.1 We may collect, store and use the personal data described in the table in Annex A to this Privacy Policy, and process it for the purposes and on the legal basis specified in that table. We rely on the following lawful bases for processing, where specified in the table in Annex A:
(a) Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

(b) Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

(c) Legitimate Interest means the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us through https://jeroboams.co.uk/about-us/contact-us/.

(d) Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us through https://jeroboams.co.uk/about-us/contact-us/.

2.2 Personal data will be stored in accordance with Clause 5 of this Privacy Policy.
2.3 We aim to keep your personal information up-to-date, so you must promptly tell us by contacting us through https://jeroboams.co.uk/about-us/contact-us/ if you change your name, residential address or contact details.

3. When may we disclose your personal data?

3.1 We will not disclose your personal data to any third party, except as explained in the table in Annex A to this Privacy Policy.

3.2 If some or all of our business is bought by a third party, personal data held by us will be transferred and may be disclosed to the prospective seller or buyer of such business under the same conditions as this Privacy Policy. This is necessary for the purposes of the legitimate interests pursued by us and the third party, and would not be overridden by your interests or fundamental rights and freedoms which require protection of personal data.

4. How we use your personal data

4.1 We will only collect, process, use, store and share your personal data where the Act allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where we need to perform an obligation under a contract with you, such as the Terms of Use & Sale, or take steps at your request before agreeing a contract with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights that require the protection of personal data do not override those interests
• Where we need to comply with a legal or regulatory obligation
• Where you have consented before the processing

4.2 You can find out more about the types of lawful basis that we will rely on to process your personal data in the table in Annex A to this Privacy Policy.

5. Where and for how long we store your personal data

5.1 All information you provide to us is stored on our secure servers, located in the United Kingdom.

5.2 We use all reasonable endeavours to ensure that appropriate technical and organisational measures are in place to protect your personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage.

5.3 Your personal data will be stored for as long as you use the Website and for such time afterwards as required by law or six years from when you stop using the Website (which is the legal limitation period).

5.4 Please note that using the internet or mobile networks is not completely secure, so we cannot guarantee the security of your data transmitted between your device(s) and the Website. Any such transmission is at your own risk.

6. Your rights

6.1 Under the Act, you have a number of rights. The first right is to receive confirmation as to whether or not any of your personal data is being processed and certain other information, as we have set out in this Privacy Policy.

6.2 The table in Annex B at the end of this Privacy Policy explains the following rights which the Act gives you in relation to your personal data, and any exceptions to those rights:

(a) Right of access
(b) Right to rectification
(c) Right to erasure
(d) Right to request the restriction of processing concerning you
(e) Right to data portability
(f) Right to object to processing
(g) Right to ask us not to process your personal data for direct marketing purposes
(h) Right not to be subject to automated individual decision-making, including profiling.

6.3 Please note that you may exercise these rights (subject to any applicable exceptions) by contacting us through https://jeroboams.co.uk/about-us/contact-us/.

7. Marketing and advertising

7.1 We seek to give you choices about what marketing and advertising you see on the Website. We will give you a choice to opt-in to receiving marketing and advertising specifically tailored for you. If you do not opt-in, we may still send you generalised marketing and advertising messages.

7.2 We use personal data you have provided to us, and responses to our survey questions, for our loyalty programme and to work out if certain advertising and marketing will be of interest to you. We may use an automated process to create a profile for you.

7.3 You can ask us to stop profiling you and sending you any targeted marketing or advertising messages on the Website at any time by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us contacting us through https://jeroboams.co.uk/about-us/contact-us/. Further information can be found in Table B.

8. Cookies

8.1 We use cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience. By visiting and using the Website, you agree to our use of cookies.
8.2 A cookie is a small file of letters and numbers that we store on your browser, computer, or device. Cookies send information back to the originating website on each subsequent visit, or to another website which recognises that cookie. We may use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure accounts, use interactive features and Website.
• Analytical/performance cookies. These allow us to recognise and count the number of visitors and users and see how they use the Website. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
8.3 Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. You should refer to their privacy policies or cookie policies for the relevant information about those cookies.

8.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. All browsers provide tools that allow you to control how you handle cookies: accept, reject or delete them. These settings are normally accessed via the ‘settings’, ‘preferences’ or ‘options’ menu of the browser you are using, but you could also look for a ‘help’ function or contact the browser provider. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.

9. Changes to our privacy policy
We may amend this Privacy Policy. Any changes we may make to our Privacy Policy in the future will be posted on this page.

10. Regulatory and Contact details
Our full company and registration details are set out in Clause 1 of the Terms of Use & Sale.
Questions, comments and requests regarding this Privacy Policy are welcomed through https://jeroboams.co.uk/about-us/contact-us/.
For more information about data protection and the protection of personal data, please visit the Information Commissioner’s website at www.ico.org.uk.

11. Complaints
You can complain to the Information Commissioner’s Office if you consider there has been a breach of the Act in connection with your personal data.

12. General
This Privacy Policy is governed by English law and either of us can bring legal proceedings in the courts of England and Wales in relation to any dispute arising out of or in connection with these Terms of Use & Sale, except that you may bring proceedings in Northern Ireland or Scotland if you are resident there.