Westover Gallery | Privacy Policy

This Privacy Policy sets out how we collect and use your personal information and what your individual data protection and privacy rights are. This Privacy Policy was last updated on 1st May 2018 and is version 1.1.

Who is Responsible for Processing Your Personal Data

Picture Business (Bournemouth) Ltd trading as Westover Gallery is the Data Controller. This is the legal entity responsible for how your personal data is collected, stored and processed. Managing Your Personal Data When you share your personal information with us, you have a right to expect that information to be treated with total confidentiality. Therefore, it is our responsibility to manage your personal data that you provide to us with care and in accordance with all data protection legislation and industry best practice.

Whether you have supplied your personal details online, by phone, by email or in a letter, we will never use them without a lawful reason to do so. We will use your personal data for the purposes for which they were initially requested and as fully explained in this Privacy Policy. It is your responsibility to ensure that your personal data provided to us is accurate and up to date. You can update your personal contact details, including email address and phone number, by visiting My Account online or, if you need to update any other personal details, by ringing us on 01202 297682

Using Your Personal Data for Direct Marketing Purposes

Based on your marketing preferences, we use your email and home address to send you details of our latest products and promotions. We also use marketing Profiling techniques to determine what product offers may be of interest to you whether that be by email, telemarketing, direct mail or social media. For further information on how we use your personal data to keep you informed about our products and promotions and how you can change your marketing preferences, click the relevant sections below. We hold your personal data for the purposes of direct marketing to you and as proof of purchase for insurance and valuation purposes and therefore you will continue to receive marketing information unless you tell us otherwise. If you have only ever registered an account but never bought from us, we will continue to send marketing to you unless you ask to be unsubscribed by updating your marketing preferences or by telephoning the gallery on 01202 297682

Using Your Personal Data to Improve Your Online Shopping Experience

We will obtain your consent to send you details of our latest products and promotions via Email Marketing and Telemarketing in a number of ways. We will obtain your consent when you register your details with us, open a credit account, make a purchase, sign up to our email newsletters, request a catalogue from us, enter a competition or when we send you electronic receipts via email in the gallery. You can change your email and telemarketing preferences at any time - see Changing Your Marketing Preferences.

EMAIL MARKETING We would like to keep you informed about our latest product offers and promotions using the email address you provide to us. We will also use your date of birth to send you specific offers for your birthday. To do this, we will ask you to opt-in to receive marketing emails when you first register an account with us , sign up for our newsletter, enter a competition or prize draw or agree for us to use your email address for marketing purposes when we send you electronic receipts in store. You can opt out of email marketing at any time - see Changing Your Marketing Preferences. Telemarketing- We will ring you about our latest product offers and promotions when you make a purchase or open a credit account with us. You can opt out of telemarketing at any time - see Changing Your Marketing Preferences. If you have subscribed to the Telephone Preference Service, we will not contact you by phone unless you have explicitly opted in to receiving telemarketing calls from us.

Direct Mail – We will use your name and address to send you personalised marketing mails in the post. We have a legitimate business interest to send you information about our products and offers in the post as we know that many of our customers like to browse through catalogues or offers prior to placing an order with us. However, should you wish to exercise your right to stop personalised postal marketing activity, you can do this at any time - see Changing Your Marketing Preferences.

Social Media-We will use your email address to send you online targeted marketing information about our product offers and promotions via social media platforms. To do this, we will share your email address in a secure manner with social media organisations, such as Facebook, who will match our advertising requirements to your social media profile. We have a legitimate business interest to send you product information via social media which we believe is of relevance to you; this is known as Interest-Based Advertising. However, should you wish to exercise your right to stop targeted social media marketing, you can do this at any time - see Changing Your Marketing Preferences.

Third Party Marketing- We will not share your personal data with third party companies for the purpose of them marketing their products and services to you. Changing Your Marketing Preferences-You can change your marketing preferences for Email Marketing at any time by: Clicking unsubscribe in the body of the email sent to you; Going online to My Account; or Ringing the gallery on 01202 297682.

You can change your marketing preferences for Telemarketing at any time by: Going online to My Account; or Ringing the gallery on 01202 297682.  Please allow 48 hours for your changes to be processed for email and telephone marketing.You can exercise your right to object to Direct Mail or Social Media at any time by:

Going online to My Account;

or Ringing the gallery on 01202 297682

Please allow 48 hours for your changes to be processed for social media. You may still receive direct marketing materials that are already processed before we received your request for up to 2 months.

Using Your Personal Data to Improve Your Online Shopping Experience

We want to make sure that we only contact you with online content that you will find relevant and interesting. For this to work effectively, we collect information about your browsing activity using Cookies when you are using our websites. These Cookies pass back to us your browsing information using your Internet Protocol ("IP") address as the identifier, which we combine with other anonymised, non-personalised and aggregated data, allowing us to determine what content and product information is most relevant to you when you are shopping online. We have a legitimate business interest to use the aggregated and anonymised data obtained via Cookies (see our Cookie Policy) and other data sources to help us provide you with relevant product marketing and improve your online shopping experience.

Profiling-Profiling is a term used to describe a form of data processing where significant volumes of data made up of lots of different data types - such as browser history from Cookies, age, gender, size, transaction history, demographics and buying habits - are all used in an aggregated, anonymised and non-personalised form to evaluate and predict, based on statistical analysis, what you may or may not want to purchase from us by assigning you to a profile type. We use this technique to understand what drives you to buy from us and the types of products you are most likely to be interested in whether that be by email, telemarketing, direct mail or social media. This is sometimes referred to as Big Data and Data Science and is widely used by retailers to improve their customer offering and Interest-Based Advertising.

Interest Based Advertising- The data that we collect and use when you browse or shop online, including where we use Cookies, uses your IP address as the unique identifier; however, it will not contain your name, home address or phone number. We may also use your email address to send you online targeted marketing information but we always use hashed email addresses to keep your data secure. The email addresses are scrambled before being utilised to ensure nobody else can gain access to your email address. This enables us to offer our customers the best possible online user experience and equally allows us to improve the relevancy of our advertising. This allows us to provide you with more of the content you want to see.

Using Your Personal Data to Open Your Personal Cash Account When you register to open a personal cash account, we will hold your personal data which you have provided to us. When you make a subsequent card or cheque payment to purchase products from us, we will use your personal data and card information to process the order. This involves sending your personal data to our card payment and banking providers to ensure that you have sufficient funds to cover the value of the transaction. Without this data, we are unable to fulfil your order. We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal cash account.

Processing Card Payments- We process all card payments in line with our obligations under the PCI-DSS regulations. Whenever you provide your card details to us either online or over the phone, we will encrypt the payment details before sending to our card payment and banking provider. If you pay over the phone, we will mask any card data that you provide so that this is not visible to our customer advisors as well as stopping card data from being recorded in our Call Recordings. This is regularly monitored for quality assurance as part of our PCI-DSS obligations. Any card details provided by customers via paper order forms will be immediately, and securely, destroyed once processed. Using Your Personal Data to Open Your Personal Credit Account

Westover Gallery do not offer credit facilities and all applications for a credit account are though V12 Retail Finance Limited and their Privacy Policy as at 25th May 2018 is as follows: V12 Retail Finance Limited is committed to protecting the privacy of your personal information.

V12 Retail Finance Limited is registered under the Data Protection Act and complies with the data protection principles set out in the Data Protection Act 1998. Our Privacy Policy explains what we do with any personal information which we collect from you on our website. If you have any questions regarding our Privacy Policy, please contact us at the address on the Contact Us page of their website. This Privacy Policy is not intended to create any contractual or other legal rights in or on behalf of any party. Your initial concerns should be sent in writing to:V12 Retail Finance Limited20 Neptune Court Vanguard Way CardiffCF24 5PJPlease note that this Policy applies only to this site and not to the sites of organisations to which we provide links. We are not responsible for the privacy policies or practices of such other organisations and you should make your own enquiries in respect of them.

Collection of Information - your Consent. We will only collect personal information from you if you provide it voluntarily. At any point on the site where you can provide personal information to us you will be referred to this Privacy Policy. If you do provide personal information to us, we will assume that you have read this Policy and have consented to us using your personal information in the ways described in this Policy and at the point on the site where you give us your personal information. If, after providing us with personal information, you later decide that you do not want us to use it for particular purposes, please write to us. Our use of Cookies If you wish, you can usually adjust your browser (the facility on your computer which enables you to visit websites) so that it does not accept cookies. Alternatively you can adjust it to tell you when a website tries to put a cookie on your computer. If you do not know how to adjust your browser, go to the "help" heading on the bar near the top of the screen and search for information on "cookies". Instructions on how to delete cookies will appear - follow these instructions. Alternatively follow these instructions after clicking onto this link www.allaboutcookies.org. Go to the heading "Manage Cookies". Click onto the option you prefer, either stopping or controlling cookies. From the list provided, click onto the programme, which your computer uses. If this is not shown on the list, click on the "help" heading on the bar at the top of this page, search for information on "cookies" - an explanation of how to delete cookies will appear, then follow these instructions. If you are a customer applying for Finance online we use a cookie to ensure our services work well on your computer. A session cookie is held in your computer memory and not on your hard drive. This contains no personally identifiable information and is deleted once your session with us is over - usually by leaving our site or closing your browser. You can disable the use of cookies by following the instructions above. Blocking this session cookie will not prevent you from applying for finance online. If you are a V12 Retail Finance Limited retail client using our secure Administration Site then we do use a stored cookie on your hard drive which is used to aid navigation of our Administration Site, memorise certain browsing preferences and to ensure our services work well on your computer. You can disable the use of cookies by following the instructions above. BLOCKING THIS COOKIE WILL PREVENT YOU FROM USING OUR ADMINISTRATION SITE. If you are browsing our 'brochure' web site which is www.v12retailfinance.com, certain pages may use a session cookie to ensure our services work well on your computer. The session cookie is held in your computer memory and not on your hard drive. This contains no personally identifiable information and is deleted once your session with us is over - usually by leaving our site or closing your browser. You can disable the use of cookies by following the instructions above. Blocking this session cookie will not prevent your enjoyment of the site. Transfer of Information AbroadWhilst it is not our current intention to transmit your personal information outside the European Economic Area, should we ever do so, then the recipient of your personal information will be contractually bound by us to observe the same Data Protection standards that we do. Change of PolicyV12 Retail Finance Limited will occasionally change the privacy policy to reflect customer and company feedback and legislative changes. However, we will not substantially change the way we use information you have already provided to us without your agreement.


Using Your Personal Data to Operate a Loyalty Membership We will use the information, including personal data, which you provide to us when you register for your Westover Gallery customer account to administer your Westover Gallery Rewards loyalty membership. Without this data, we are unable to administer your Westover Gallery Rewards loyalty membership. For more details on how we use your personal data, click on the heading below. We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your Westover Gallery loyalty membership.

Operating Your Westover Gallery Rewards Loyalty Membership- We will use your personal data to operate your Westover Gallery Rewards loyalty membership in the following manner: Your personal data, such as name, postal address and email, will be transferred to our third party processors so they can process and distribute your rewards on our behalf. Details of rewards that are available to you will be sent to the email address you provided. Your rewards will be available when you log in to your Westover Gallery customer account online. Data from your Westover Gallery customer account may be used for the purposes of analysis and so that we can provide rewards that are tailored to you. It is important that the contact information on your Westover Gallery customer account is accurate and up to date at all times. If you need to amend any of your details, you can do this online via your Westover Gallery customer account or by calling us. If you have opted out of receiving email marketing from Westover Gallery when registering your Westover Gallery customer account, or at any other time, you will not receive any email notifications about any new or existing rewards available to you. You can still be a part of Westover Gallery Rewards and view your rewards online. You can change your email preferences at any time if you wish to opt back in - see Email Marketing.

Using Your Personal Data to Operate Your Personal Account We will use your personal data to administer and to operate your personal credit and cash account as set out below. We will collect and use the contact details that you provide to us to communicate with you about your account and in relation to the products and services we provide to you. We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit and cash account.

Delivering Your Goods- We will use your personal contact details such as name, postal address, phone number and email address that you provide to us in respect of delivering products or services to you. We will share this information with our suppliers who directly despatch orders to you or our delivery partners who may contact you to arrange a convenient delivery time and provide you with updates as to when they will arrive.

Processing Returns and Refunds- We use your customer account and contact details to verify any returns and refunds that we process either by card or via your credit account. We process all card payments in line with our obligations under the PCI-DSS regulations and will encrypt the payment details before sending to our card payment and banking provider.

Operating Your Credit Account-We use your personal contact details such as name, postal address, phone number and email address to notify you about any updates, changes or issues with your personal credit account. If you choose to pay for goods via BACS, we will require a bank account number, sort code and the type of payment you wish to make e.g. full balance or fixed amount. We will use the personal data provided to verify that the account number and sort code combination are valid. We will also ask you for the bank account holder’s name which the bank will use to verify the direct debit payment request. It is your responsibility to ensure that you either have a sole authority or that you have the bank account holder’s permission to make payments from their bank account. Where you pay by cheque, we will also store the cheque details including account number and sort code which are required to deal with any queries raised to us by your bank. Where you pay by credit or debit cards, we process all card payments in line with our obligations under the PCI-DSS regulations. Please see Processing Card Payments section for more detail.

Electronic Statements & Other Documents via Email-We will use the email address that you provide to us to communicate with you about your account and in relation to the products and services we provide to you. Unless you have specifically requested otherwise, we will send your account statements and other account information and documentation to you electronically using your email address. We will hold your statement data for 6 years, plus the current financial year, after the date of your last statement. Call Recordings-We record all calls into our contact centre for quality assurance, regulatory compliance and training purposes. We retain all call recordings for a period of 12 months. Enquiries and Complaints-If you have any complaints with regards to the operation of your personal cash or credit account, please contact Westover Gallery on 01202 297682 so we can deal with your complaint as quickly as possible. We will need to access your personal data and account history to verify your identity for security reasons and deal with the details of your complaint. Details of any complaints received will be logged and recorded so they can be dealt with accordingly.

General Service Communications-We will use your personal data for all general service communications including sending your statements, processing orders, notifying you of orders received, updating you on deliveries, despatched or products out of stock. We need to do this for the performance of the contract and terms and conditions that you have signed. Using Your Personal Data to Improve Our Services. As a valued customer, we may use your personal data to contact you by phone, SMS, letter or email to ask you to participate in one of our service improvement programmes. We will share your personal contact details with our chosen third party partners and service providers who may carry out these service improvement programmes on our behalf. We will always make you aware of how we will use the information that we gather from you at the time of contacting you for any specific service improvement programme. We have a legitimate business interest in contacting our customers in this way and will always treat your involvement in any service improvement programme, and associated personal data, in confidence. Should you not wish to participate in our service improvement programme, you can simply decline to participate at the point of contact or, should you wish never to be contacted for the purpose of market research, you can tell us at any time by ringing the gallery on 01202 297682

Social Media-We actively use social media platforms as a way of connecting, and getting closer, to our customers to hear and understand what our customers think about us and our products and services. Occasionally, we may contact you directly via those social media platforms if we would like to share your comments or pictures with other customers or publish them in our marketing materials. We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.

Using Your Personal Data to Process Insurance Claims In the event that you need to make a claim against us, whether that be a product issue or personal injury claim, we will use your personal data and any supporting evidence that you provide to us to process your claim, including sharing this with our chosen insurance companies. From time to time where a claim is outside of our insurance policy, we may also need to engage with external lawyers and share your personal data with them.

Sharing Your Personal Data with Third Party Processors & Partners As part of delivering our products and services to you, we will share your personal data with carefully chosen Third Party Processors and Partners who carry out a number of services on our behalf. Should you wish to obtain a list of our latest Third Party Processors and Partners, you can request this at any time by contacting our Data Governance team. Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services. If you have any concerns about any of our third party processors and partners, please contact our Data Governance team.

How to Contact Us If you have any questions, comments or complaints about this Privacy Policy or our use of your personal data, please contact us at: Westover Gallery 4 Westover Road Bournemouth BH1 2BY enquiries@westovergallery.co.uk Tel: 01202 297682If you are at all dissatisfied with the information provided herein, please address any complaints to the Data Protection Officer at the same address.

Your Personal Data Rights Right of Access-You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request. You can do so by ringing, writing to or emailing the Data Governance team. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days. However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time that we have validated your identity.

Please be aware that for security reasons we do not usually provide details of any bank details that we hold against your account(s). Please speak to our Data Governance team should you need this additional information. Right of Rectification-If you believe we have made an error as to the personal data we hold about you, please speak to one of our customer service advisors on 01202 297682 who will be able to process the correction for you. Alternatively, you can visit My Account (if you have opened an online account) to update your contact details online. Should you wish to discuss this matter further, please contact the Data Governance team.

Right of Erasure-You have the right to request your personal data to be permanently deleted from our records and systems to avoid any further communication with you. Your request will always be considered in light of the legal bases that we hold, store and process your personal data and the purpose that we collected your data. Where the legal bases permits, we will carry out your instruction without undue delay. Please note, however, that where we have a legal or contractual obligation to hold your personal data, we may not be able to carry out your request but we will explain this fully to you. Please address any request to delete your data to the Data Governance team.

Right to Restrict Processing-Should you believe that we are processing your personal data in a way that you did not understand or agree to and wish to restrict such processing, please speak to the Data Governance team who will be able to assist you.

Right to Object to Processing-You have the right to object to certain types of processing of your personal data. We will always make it clear at the outset of any new arrangement with you how we are going to process your personal data. Should you wish to object to such processing, particularly concerning Automated Decisioning and Profiling, we will give you the option to opt out on application. However, should you wish to discuss this matter further, please speak to the Data Governance team.

Right to Portability-In the event that you wish to move your personal data that we hold on you to another organisation in the form of an excel or csv format, please contact the Data Governance team who will be able to assist you. Right to be Informed-You have the right to be informed about the collection and use of your personal data. This is commonly known as a 'privacy statement' or 'privacy policy'. We will provide you with the information about how we collect and use your data in various means, such as by 'just in time' notice provided to you at the time of collecting your personal data and via this Privacy Policy. Our Privacy Policy is regularly reviewed in line with our business processes. Any changes to this Privacy Policy will be communicated via email and credit account statements to all active customers.

We will also advise customers of changes when ringing the call centre via a recorded message. You can ask for a printed copy of our Privacy Policy by contacting the Data Governance team.

Right to Complain to the Information Commissioner's Office (ICO)-You have a right to lodge a complaint with the Information Commissioner's Office (ICO) if you have a complaint with how you believe your personal data has been handled. For more information, please visit https://ico.org.uk/concerns

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