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:
In specific situations, we can collect and process your data with your consent.
For example when you become a member of Elys 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.
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.
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.
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 an Elys Rewards member
- When you join our Elys 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 Elys Rewards or request newsletter information we will with your consent collect the following information: Name
Date of birth
- 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
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
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 Elys Rewards members, we will also offer you personalised, relevant and appropriate promotions and incentives.
As an Elys 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 Elys 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 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 by updating your preferences in your online account.
- 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 Elys 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.
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?
Whenever we collect or process your personal data, we’ll 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.
Examples of our customer data retention periods
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.
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 email@example.com 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.
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 firstname.lastname@example.org
- 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.
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.
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 email@example.com
- 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
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)
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 firstname.lastname@example.org
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