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Privacy & Cookies Policy
Privacy & Cookies PolicyPrivacy Notice
This privacy notice was last updated 23rd October 2024
Studio - Privacy PolicyFrasers Group consists of different brands and legal entities and the company responsible for the processing of your personal data is dependent on the purpose for which it is collected. For each processing purpose you will be informed of the responsible company.
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of your personal data, including encrypting your data to applicable industry standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
So, you only need to look in one place to find out all you need to know about how the Group collects and processes your personal data. This policy covers our Website (being any website operated by Studio, our App (being any app operated by Studio or a Group company), our stores and any correspondence you have with the Group in relation to our retail offering.
Any changes we make to this policy will be reflected on this page and notified to you by email, where appropriate.
Who we are?
As set out in our terms and conditions, this Website and the App are operated by Studio Retail Trading Limited, whose registered address is Unit A, Brook Park East, Shirebrook, NG20 8RY.
Studio Retail Trading Limited is the data controller in respect of information collected when you browse this Website and the App and purchase our products. Frasers Group Financial Services Limited is the data controller in respect of any purchases paid for using a Credit product.
If you have any queries regarding our use of your personal information or this privacy policy, you can write to Data Protection: Express House, Petre Road, Clayton Business Park, Accrington, Lancashire, BB5 5JB or email to data.protection@frasers.group.
Information we may hold about you
When you register to use our Website or App, purchase a product, register to receive our emails, apply for a job, register for our membership or loyalty services, enter a competition or promotion run by the Group or contact us, personal data you provide, such as your name, date of birth, contact details (including social media accounts), telephone number, transaction history, log in and payment information, and gender may be collected along with proof of identity (ID).
When you browse our Website or App, whether or not you are registered, purchase a product, register to receive our emails, receive and open or click our emails, or make a job application, we and our partner advertising networks, advertisers and advertising affiliates (Third Party Advertisers), will collect user information such as your location, language, assumed gender, IP address, when you visited our Website or App, how you arrived on our Website or App, where you visit after our Website or App, the pages you visited, how long you spend browsing individual pages on our Website or App, any products you have viewed, purchased, or put in your basket, and the browser (where applicable) and device you used to access our Website or App.
If we provide you with a Credit Account, we will supply details of your account to Credit Reference Agencies which includes details of how you manage your account, if you do not pay on time, or pay less than required. Please always be aware that this information will be recorded and may affect your ability to obtain credit with us or elsewhere in the future.
The three main Credit Reference Agencies are Experian, TransUnion and Equifax. To access the Credit Reference Agency Information Notices (CRAIN) please follow the links below.
In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes. Calls may also be monitored without your consent in the following circumstances: to provide evidence of a business transaction; to prevent or detect a crime; to ensure that the Group complies with regulatory procedures; to see that quality standards or targets are being met; and to secure the effective operation of the telecom system.
Information collected from third parties
When you apply for a Credit product, we will use Credit Reference Agencies to make sure we can identify your creditworthiness. The information shared may include your current and past financial data together with income verification, credit commitments and income and expenditure estimates.
We will also share your data with credit and fraud prevention agencies to check accuracy and for the purpose of fraud and other illegal activity. As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing, or employment to you.
Further details on how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by going to www.cifas.org.uk/fpn
Once you have a Credit Account with us, we will make periodic searches of Credit Reference Agencies to manage your account on an ongoing basis. These searches will not be available to other lenders for credit assessment purposes. We will regularly carry out credit risk checks and affordability checks with these Credit Reference Agencies.
How we may use your personal data
We may use your personal data in the following ways:
- to fulfil your order - we require your identification, contact and payment information to enable the relevant Group company to enter into a contract with you and are unable to do so without this information (please note that your details may need to be passed to another company within the Group and/or a third party, such as one of our couriers or one of their customs clearance agents, in order for them to supply or deliver the product that you ordered and certain products will be processed and delivered direct from some of our supplier partners either as part of our drop ship model or market place offering ("Direct Supply"). We may retain your details for a reasonable period of time after you have completed the transaction in order to fulfil any contractual obligations such as refunds, guarantees etc and to meet any legal obligations for the retention of transactional data)
- to assess your eligibility for Credit and to make lending decisions in accordance with our internal policies, principles, and regulatory obligations
- to provide information to, and receive information from, credit reference agencies and other third parties
- to provide you with Credit and a Credit Account and to maintain your Credit Account
- to meet our legal, regulatory and compliance requirements (e.g. in relation to financial crime and anti-money laundering)
- to tell you about similar products and services, or products and services that you ask us to send you information about, by email, post, mobile, telephone and/or through other digital means (depending on your stated preferences) including social media platforms
- to provide you with services you request from us including, the sale and/or distribution of products made available to you through Direct Supply, including the administration of your Group membership or loyalty services
- to register you on the Website or App (where this involves setting you up with an account, we will use your personal data to maintain and update your account (e.g. such as a change of address or change in your marketing preferences)
- to administer our Website and App
- to analyse, and improve, the use of our Website, App and retail offering, including how you move around our Website or App;
- to administer any competition run by the Group. Please refer to the specific terms and conditions for each competition
- to measure and analyse our advertising
- to make suggestions and recommendations to you, other users of our Website and App, and users of the services of our Third Party Advertisers about products or services that may interest you or them;
- to keep in touch with you regarding your marketing preferences
- to keep our Website, App and network safe and secure
- to process payments, to detect and prevent fraudulent transactions and/or any other criminal activity (we may pass your details to a third party to carry out these functions) and for debt tracing and recovery
- to assess and process your job application.
- we will receive your personal data from other companies/legal entities or provide it to other companies if we merge with or acquire another business to link the account you hold with us to the account you have with the other brand and to share information about your purchases.
- where necessary when merging with or acquiring another business or re-organising our business, in which case some of your information may be shared with a prospective buyer or otherwise but only so far as is strictly necessary for the purposes of such sale or administration.
- to seek your feedback or undertake customer research to improve our products and services
We can only use your personal data if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests, such as to provide appropriate marketing and to maintain our services.
How long we keep your information
We will not keep your personal data for any purpose(s) for longer than is necessary and we will only retain the relevant personal information that is necessary in relation to the purpose.
We will retain the personal information you provided on registering an account on our Website or App so long as that account remains in existence. If you apply for a Credit Account with us, we will retain the personal data provided in your application, for registering an account, and relating to your usage of the account, for so long as that account remains in existence and for 7 years thereafter. If your application is not successful, or you choose not to register for an account, we will retain the personal data for 7 years.
In the case of any contact you may have with our customer services department, we will retain those details for as long as is necessary to resolve your query and for a short period after the query is closed.
On making a purchase through our Website or App, we will retain certain limited personal information such as your name, email address and postal address until you ask us to update or delete those details for the purpose of reporting new and existing users to our affiliate advertisers. We retain transaction information for the longer of as long as you hold a Recognition Loyalty Programme Account or required by law. We will retain information regarding your website browsing history for a similar period.
If we are legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also retain some of your personal information for a limited period of time, even after you have closed your account.
We will retain information relating to any job application for as long as it takes to process your application and, if it is unsuccessful, for an additional period of around 6 months. If your application is successful, your information will be retained in accordance with our staff privacy policy.
We will retain your information for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place.
How we might share your personal data
We may share your personal data with other companies in the Group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your personal data in connection with any merger, acquisition, insolvency situation or otherwise, in which case we will only disclose your information so far as is necessary.
We may also share your personal data with carefully selected third parties who assist us in providing you with products, advertisements and services. This will include the following types of third party:
- Our professional advisers, including, without limitation, our insurers;
- Our suppliers, business partners and sub-contractors;
- Our Third Party Advertisers;
- Our Direct Supply partners, who will provide certain products/services directly to you and will require your personal data to process and deliver your order (including warehousing, order packing, delivery, returns and general administration);
- Our Direct Supply middleware providers, who operate the platform through which the order you place on this Website is shared with the relevant Direct Supply partner; and,
- Search engine and web analytics providers.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
In the event that we were to sell our business or assets, we may disclose your personal data to any prospective/actual purchaser and/or their advisers.
We may also disclose your personal data where we are subject to a legal obligation to do so, in connection with the prevention or detection of crime, for the purpose of establishing, exercising or defending our legal rights, or where we consider that we receive a valid request for disclosure. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
You should be aware that if we are requested by the Police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information or any other information we obtain about you, we are entitled do so.
Our Website and App may, from time to time, contain links to and from the websites of third parties or utilise a piece of software or a service which requires your personal information be shared with a third party. Please note that these third-party websites/providers have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.
Where we store your personal data
The information that we collect from you may be transferred to and stored outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, third party providers, including, Direct Supply partners and middleware providers. Where we do so, the third country's data protection laws will have been approved as adequate by the European Commission, or other applicable safeguards are in place.
Automated decision-making for credit products
When you apply for credit, we may decide whether we can lend to you automatically comparing the information you provide to use against our lending criteria. This criteria includes:
- Credit score
- Credit history
- Employment status
- Assessment of affordability
Your information will be compared against this and we may make a decision automatically about whether to offer you credit and the amount.
We'll also analyse and combine the information collected (sometimes automatically) to understand the way you use your account and our services as well as what you might like and what you might do. Through our analysis we may create a profile of you to help us predict your financial behaviour and preferences so we can provide services to you ('profile information').
Your rights
Under the UK GDPR, you have the following rights which, in most cases, you can exercise free of charge:
Right of Access
This is commonly referred to as a Subject Access request or ‘SAR’.
The right to be provided with a copy of your personal data and to certain other supplementary information that this Privacy Policy is already designed to address.
Right to Rectification
The right to have inaccurate personal data rectified e.g., if you consider that your personal data is incorrect, out of date or incomplete.
Right to Erasure
This right is also known as ‘the Right to be Forgotten’.
The right to require us to delete your personal data.
This right is not absolute and only applies in certain circumstances.
Right to Restrict Processing
The right to restrict the processing of your personal data where you may have a particular reason for wanting the restriction.
This right is not absolute and only applies in certain circumstances.
Right to Data Portability
The right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format. It also gives you the right to request that we transmit this data directly to another data controller.
Right to Object
The right to object to the processing of your personal data at any time. This effectively allows you to stop or prevent us from processing your personal data.
The right to object only applies in certain circumstances.
You have the absolute right to object to the processing of your personal data if it is for direct marketing purposes (refer to section below).
Rights related to automated decision-making including profiling
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Your right to withdraw consent
Where 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
If you would like to exercise any of these rights, please write to the Data Protection Team, Unit A, Brook Park East, Meadow Lane, Shirebrook, NG20 8RY or email data.protection@frasers.group.
If we choose not to action your request, we will explain the reasons for our refusal.
To maintain the security of our customers' personal details, we may need to request proof of identity before we disclose personal data to you in response to any of the above requests.
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 communication that we send you. We will then stop any further emails from us.
- If you have an account, log in into your account, visit the ‘My Account’ area and change your preferences.
- In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
- Write to the Data Protection Team, Unit A, Brook Park East, Meadow Lane, Shirebrook, NG20 8RY or email data.protection@frasers.group
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
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