Introduction 

This Privacy Policy outlines in detail the types of personal data we may collect about you when you interact with usIt also explains how we’ll store and handle that data and keep it safe. 

Whilst there is a lot of information here, it is intended to keep you fully informed about your rights and how Elys uses your data. 

The following sections should hopefully answer any questions you have, but if not, please do get in touch with us. 

From time to time we may need to update this Privacy Notice. If we do make any significant changes we will notify, but this policy is available for you to review at any time. 

When you are using the Elys website, Morleys Department Stores Ltd is the data controller. 

Explaining the legal bases we rely on 

Data protection law outlines a number of different reasons for which a company may collect and process your personal data including the following: 

Consent 
In specific situations, we can collect and process your data with your consent. 

For example when you become a member of Rewards or subscribe to our newsletter. 

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service. 

Contractual obligations 
In certain circumstances, we need your personal data to comply with our contractual obligations. 

For example if you purchase an item from us requiring home delivery, we’ll collect your address details in order to deliver your item via the relevant courier. 

Legal compliance 
If the law requires us to, we may need to collect and process your data. 

For example we can pass on details of people involved in fraud or other criminal activity affecting Elys to law enforcement. 

Legitimate interest 
In some situations, we may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. 

For example, for Elys  Rewards members we will use your purchase history to send you or make available personalised offer. We also combine the purchase history of Rewards customers to identify trends and ensure we can keep up with demand or introduce new products/service. 

  

When do we collect your personal data? 

  • When you visit any of our websites, with your consent as a Rewards member 

  • When you join our Rewards loyalty 

  • When you purchase a product or service in store or by phone 

  • When you engage with us on social media 

  • Your receipts, guarantees and warranties for you when you make a purchase from Elys. When you contact us by any means with queries, complaints etc. 

  • When you ask one of our staff members to email you information about a product or service 

  • When you enter prize draws or competitions 

  • When you book any kind of appointment with us or book to attend an event, for example personal shopper 

  • When you choose to complete any surveys we send you 

  • When you comment on or review our products and services 

  • Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the staff member who provided that service, it may be passed on to them if requested 

  • When you fill in any forms. For example, if an accident happens in store, a staff member may collect your personal data 

  • When you’ve given a third-party permission to share with us the information they hold about you, for example a finance agreement with V12 Retail 

  • We may collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law 

  • When you visit our Store which usually have CCTV systems operated for the security of both customers and staff. These systems may record your image during your visit 

  

What sort of personal data do we collect? 

  • If you have Rewards or request newsletter information we will with your consent collect the following information: Name 
    Gender 
    Address 
    Email 
    Mobile number 
    Date of birth 

  • Financial information including credit card, debit card, and financial account numbers, payment card information, financial account information, transaction details, form of payment, payment confirmation and other payment details. 

  • Account information including your username, password, security questions, preferences and settings. 

  • Transaction information including the items you view, put in your cart, add to your wishlist, or purchase, return, exchange or cancel and your past transactions. 

  • Communications with us including the information you include in communications with us, for example, when sending a customer support inquiry. 

  • Device information including information about your device, browser, or network connection, your IP address, and other unique identifiers. 

  • Usage information including information regarding your interaction with the Services, including how and when you interact with or navigate the Services. 

  • Details of your shopping preferences 
    For example, products purchased and Reward points accrued and redeemed 

  • Details of your visits to our websites via Google Analytics 

  • Information gathered by the use of cookies in your web browser 
    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 to distinguish you from other users of our website. This enables us to deliver a good experience on the website and allow us to make improvements in the future. A cookie is a small piece of information sent to a web browser to a web server, enabling information from the browser to be collected by the server. To find out more about cookies, including what has been set and how to manage and delete them please www.allaboutcookies.org. 

We also use Google Analytics cookies on our website. This cookie is specifically used to collect information on how visitors use our site. We use this information to understand how visitors are using the site in order to make improvements to the user experience. This information is collected in an anonymous form, including the number of visitors to our website, where visitors have come from and the pages viewed. 

Most web browsers allow some control of most cookies through browser settings. Please see more on this or take a look at instructions on how to manage here www.allaboutcookies.org. It may be possible to set up your computer to reject cookies although, if implemented you may not be able to use certain features on our website. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gooptout.Third parties or publicly available sources. 

  • Personal details which help us to recommend items of interest 
    For example you may share with us information on your skin type enabling the recommendation of appropriate beauty brands and/or products 

  • We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us 

  • Payment card information 

  • Your customer service comments and product reviews 

  • Your image may be recorded on CCTV when you visit a shop or car park 

  • To deliver the best possible web experience, we collect technical information via Google Analytics about your internet connection and browser as well as telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered 

  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback 

We may collect personal information from the following sources: 

  • Directly from you including when you create an account, visit or use the Services, communicate with us, or otherwise provide us with your personal information; 

  • Automatically through the Services including from your device when you use our products or services or visit our websites, and through the use of cookies and similar technologies; 

  • From our service providers including when we engage them to enable certain technology and when they collect or process your personal information on our behalf; 

  • From our partners or other third parties.  

How and why do we use your personal data? 

We are always striving to give our customers the best possible shopping experience. One way for us to achieve this is be creating a rich picture of who you are by combining all the data we have about you. 

We then use this data to offer you promotions, offers, products and services that are most likely of interest to you. In the case of Rewards members, we will also offer you personalised, relevant and appropriate promotions and incentives. 

As a Rewards member you consent for us to communicate with you in this way. The data privacy law also allows this interaction as part of our legitimate interest in understanding our customers better in order to provide and deliver the very highest levels of service. 

If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. 

Please remember, that if you choose not to share your personal data with us, or refuse consent for certain communication methods we may not be able to provide some of the services and/or benefits you have asked for. 

For example if you’ve asked us to let you know when a product comes back into stock we can’t inform you if you have withdrawn your consent to hear from us. Also if you are a member of Rewards and refuse permission for us to contact you we will be unable to let you know about offers, promotions and events that are exclusively for Rewards members. 

Here’s how we’ll use your personal data and why: 

  • To process any orders that you make in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. 
    For example, your details may be need to be passed to a third party to supply or deliver the product or service you ordered. We will keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds or guarantees. 

  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 

  • To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. 

  • In order to identify possible fraudulent log-ins we continually monitor our website and automatically ban IP’s which attempt to log-in multiple times in succession. 

  • To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our store/car park which record images for security. We do this on the basis of our legitimate business interests. 

  • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud. 

  • If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities. 

  • With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. 

Of course, you are free to opt out of hearing from us by any of these channels at any time. 

  • To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest and/or your consent if you are a member of our Rewards scheme. 

You are free to opt out of hearing from us by post at any time. 

  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Policy, product recall notices and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations. 

  • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering. 

  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, to comply with our contractual or legal obligations to share data with law enforcement. Or when a court order is submitted to share data with law enforcement agencies or a court of law. 

  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. 

Of course, you are free to opt out of receiving these requests from us at any time. Please visit or contact the store via email or phone call to update your preferences. Find a store near you here. 

  • To build as complete a picture as possible of who you are and what you like and to inform our business decisions, we will combine data captured from across the business, third parties and on occasion publicly available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest. Combining data enables us to deliver you a personalised experience and decide what products and/or services we should share with you. We also use data from customer purchase histories to identify trends. This may then inform the products we stock. 

  • For Reward Members we use this data in order to decide which information to show and share with you and provide you with tailored offers with the help a third party system which applies computer algorithms. We do so on the basis of your consent when you become a Rewards member. If you don’t want to continue receiving Rewards offers, you’ll potentially unable to enjoy the benefits of the Rewards scheme delivers. 

  • To process your booking/appointment requests (for example with a personal stylist). Sometimes, we’ll need to share your details with a third-party who is providing a service (such as delivery couriers or a fitter/ estimator visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request. 

  • Combining your data for personalised direct marketing 

We want to provide you with offers and promotions that are most relevant to you. To help us form a better understanding of you as a customer, we combine your personal data gathered as described above, for example your purchase history. For this purpose we also may combine your data with that obtained from third parties to whom you have given consent to pass that data onto us for example Mosaic or Acorn consumer classification. 

Shopify Services 

Our online store is hosted by Shopify Inc., which provides us with the e-commerce platform to sell our products and services. When you visit our website or make a purchase, your personal data is processed by Shopify in order to provide these services, including services based on your interactions with our store, other Shopify-powered stores, and Shopify itself. 

Your personal information will be shared with Shopify and other third parties that may be located in other countries, this is in order to support the operation of the store.  

For more details, please review Shopify’s Consumer Privacy Policy. 

To understand how you can exercise your rights to withdraw consent or object to Shopify’s processing of your data for Enhanced Services, please visit Shopify’s Privacy Portal. 

 

International Transfers 

Please note that we may transfer, store and process your personal information outside the country you live in. 

If we transfer your personal information out of the European Economic Area or the United Kingdom, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection. 

we are the data controller of your personal information. 

 

 

Third Party Websites and Links 

The Services may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. 

 

 

Children's Data 

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children under the age of majority in your jurisdiction. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" (as those terms are defined in applicable law) personal information of individuals under 16 years of age. 

 

How we protect your personal data 

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. 

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. 

How long will we keep your personal data? 

When we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected. 

At the end of that retention period, your data will either be deleted completely, flagged as inactive or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. 

Rewards Accounts 
Customers who create a Rewards account will have their data held for a minimum of three years. Customers who do not use their Rewards account for three years will be contacted to ask if they wish to continue holding a Rewards account with us. If we do not hear back, after 3 months the accounts will be closed and personal data will be anonymised. 

Online Orders 
When you place an order through our website, we will keep the personal data you give us for at least three years so we can comply with our legal and contractual obligations. After three years with no new orders, we will contact you to ask if you would like to still have an online account with us. If we do not hear back, after 3 months the accounts will be closed and personal data will be anonymised. 

Customer Data not linked to a Rewards or an Online account 
For customers in our marketing database who do not have an online or Rewards account, if we observe continued inactivity from an email address over a three-year period, we will contact you to ask whether you would like us to stay in touch If we do not hear back, after 3 months the email address will be unsubscribed, and personal data will be anonymised. 

Orders 
When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations. In the case of products such as furniture and beds, we’ll keep the data for 10 years. 

Warranties 
If your order included a warranty, the associated personal data will be kept until the end of that warranty period. 

Inactive Rewards member and dormant newsletter email addresses 
If you haven’t used your Rewards card for more than three years, it will be flagged as inactive and we will contact you to ask whether you wish to continue as a member. Unless you reply to say ‘yes’ we will close the account and delete or anonymise the personal data associated with it. 

If we observe continued inactivity from an email address, for example over a two-year period it will be flagged as inactive. We will contact you to ask whether you would like us to stay in touch, unless you reply to say yes we will unsubscribe your email account. 

  

Who do we share your personal data with? 

We do not share your data with other third parties other than those required to legitimately run our business. Your personal data will only be shared with trusted third parties. 

For example delivery couriers, for fraud management, to handle complaint and to help personalise our offers to you. 

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy: 

  • We provide only the information they need to perform their specific services. 

  • They may only use your data for the exact purposes we specify in our contract with them. 

  • We work closely with them to ensure that your privacy is respected and protected at all times. 

  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous. 

Examples of the kind of third parties we work with are: 

  • IT companies who support our website and other business systems 

  • Operational companies such as delivery couriers 

  • Direct marketing companies who help us manage our marketing communications to you 

  • Marketing delivery systems enabling our digital marketing communications to you 

  • Google/Facebook to show you products/services that might interest you while you’re browsing the internet. This is on the basis of your consent or acceptance of the cookies on our website. Please see the section ‘What sort of personal data do we collect?’ 

  • Information is shared with Google and FaceBook, however data is anonymised and is solely used for the purpose of understanding how visitors interact on the site or engage with our Social Media posts. I.E. Via Google Analytics and FaceBook Insights. 

  • In cases of fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies. 

  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration. 

  • To help ensure your website experience is the best it can be we use Google Analytics and cookies on our site. Please see the section ‘What sort of personal data do we collect?’ 

  • For further information please email customerrelations@morleystores.co.uk or contact Customer Relations, Central HR Department, Morley Stores Ltd, 16 St Georges Road Wimbledon SW19 4DP 

 

What are your rights over your personal data? 

The following give an overview of your different rights. 

You have the right to request: 

  • Access to the personal data we hold about you. This will be provided free of charge in most cases. 

  • The correction of your personal data when incorrect, out of date or incomplete. 

  • Right to Delete. You may have a right to request that we delete personal information we maintain about you. 

  • Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions. 

For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty). 

  • That we stop using your personal data for direct marketing (either through specific channels, or all channels). 

  • That we stop any consent-based processing of your personal data after you withdraw that consent. 

You have the right to request a copy of any information about you that Elys holds at any time, and also to have that information corrected if it is inaccurate. 

  • To ask for your information, please contact Customer Relations, Central HR Department, Morley Stores Ltd, 16 St Georges Road Wimbledon SW19 4DP or email customerrelations@morleystores.co.uk

  • To ask for your information to be amended, please update your online Rewards account, or contact a management team member in Store. For newsletter customers personal preferences can be updated via a link featured in all email communications or by contacting a team member in store. 

If we choose not to action your request we will explain to you the reasons for our refusal. 

Your right to withdraw consent 
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. 

Where we rely on our legitimate interest 
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data. 

Direct marketing 
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request. All our communications provide links or means to unsubscribe. 

Managing Communication Preferences. We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made. We must always comply with your request. All our communications provide links or means to unsubscribe. 

 

Right to Opt out of Sale or Sharing for Targeted Advertising. Depending on where you reside, you may have a right to opt out of the "sale" or "share" of your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. You can exercise your rights to opt-out of those uses here. Please note that if you visit our website with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out for the device and browser that you use to visit the website. If we are able to associate the device sending the signal to a Shopify account, we will apply the opt out request to the account as well. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/. Other than the Global Privacy Control, we do not recognize other "Do Not Track" signals that may be sent from your web browser or device. 

If you reside in the UK or European Economic Area, and subject to exceptions and limitations provided by local law, you may exercise the following rights in addition to the rights outlined above: 

  • Objection to Processing and Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information for certain purposes. 

  • Withdrawal of Consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent. If you withdraw your consent, this will not affect the lawfulness of any processing based on your consent before its withdrawal. 

You may exercise any of these rights where indicated on the Services or by contacting us using the contact details provided below. To learn more about how Shopify uses your personal information and any rights you may have, including rights related to data processed by Shopify, you can visit https://privacy.shopify.com/en. 

We will not discriminate against you for exercising any of these rights. We may need to verify your identity before we can process your requests, as permitted or required under applicable law. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law. 

 

Checking your identity 
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. 

  

How can you stop the use of your personal data for direct marketing? 

There are several ways you can stop direct marketing communications from us: 

  • Click the ‘unsubscribe’ link in any email or text communication that we send you. We will then stop any further emails or texts from that particular division. 

  • Respond to the address provided on postal communications indicating you wish to be removed from future marketing 

  • If you have a Rewards account, log in into your account, visit the ‘My Account’ area and change your preferences 

  • Write to Customer Relations, Central HR Department, Morleys Stores Ltd, 16 St Georges Road Wimbledon SW19 4DP 

  • Email customerrelations@morleystores.co.uk

  • Visit the Store and speak to member of store management team 

  • Please note that you may continue to receive communications for a short period of time after changing your preferences while our systems are fully updated 

  

Finance 

When you apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies. 

Here are those individual privacy policies, all links open in a new window. (Please note we are not responsible for the content on external websites): 

 

Joint use of your personal data 
We may on occasion share data with our chosen providers to provide you with relevant offers, promotions, updates, products, services and discounts that reward your loyalty. 

  

Contacting the Regulator 

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. 
You can contact them by calling 0303 123 1113. 

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites) 

  

Any questions? 

We hope this Privacy Notice has been helpful in explaining the way we handle your personal data and outlining your rights to control it. 

If you have any questions that haven’t been covered, please contact email us at customerrelations@morleystores.co.uk 

Or write to us at Customer Relations, Central HR Department, Morleys Stores Ltd, 16 St Georges Road Wimbledon SW19 4DP. This notice was last updated on 01/01/2020