Privacy Policy

1. How we use your personal data
2. How our providers use your personal data
3. Joint use of your personal data

Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how the DK Wholesale LTD uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across the DK Wholesale LTD to build a picture of you.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
Our products and services are aimed at those aged 16 and over.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.
When you are using the DK Wholesale LTD website, DK Wholesale LTD is the data controller.
DK Wholesale LTD is a UK based company and therefore when visiting our website, personal data that we may collect through cookies or online forms will leave the EU for the UK.

Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary for 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 order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

Legal compliance
In specific situations, we 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, we will use your purchase history to send you or make available personalised offers.
We will also send you direct marketing emails when you shop with us and do not choose to opt out - this is often called a 'soft opt in'
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
We may contact you regarding market research

With your consent, or when you shop with us and do not choose to opt-out from receiving our emails ('soft opt in') we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable in the UK.

When do we collect your personal data?

• When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the Partnership on the phone, in a shop or online.
• When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
• When you create an account with us.
• When you shop online, we capture information through cookies and similar technologies; you can manage these when you visit our site.
• When you purchase a product or service in-store or by phone but don’t have (or don’t use) an account.
• When you engage with us on social media.
• When you sign up for my DK Wholesale LTD or joint loyalty membership, you will be given access to an area on dkwholesale.com. This will collect and store all of your receipts, guarantees and warranties for you when you make a purchase from DK Wholesale LTD.
• When you contact us by any means with queries, complaints etc.
• When you ask us to email you information about a product or service.
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send you.
• When you comment on or review our products and services.
• When you fill in any forms.
• When you’ve given a third-party permission to share with us the information they hold about you.
• We 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 use our car parks and shops which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.

What sort of personal data do we collect?

• If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
• Details of your interactions with us through contact centres, in-store, online or by using one of our apps.

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us.

• Any items you may have added to your Wish List.
• Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
• Details of your shopping preferences.

For example, which of our shops you prefer to visit and where you redeem your vouchers.

• Details of your visits to our websites or apps, and which site you came from to ours.
• Information is gathered by the use of cookies in your web browser. Learn more about.
• Open rates, and click through rates on email marketing campaigns through the use of Pixels.
• Personal details help us to recommend items of interest.

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.

How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

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

• To process any orders that you make by using our websites, apps or 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 need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.

• 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 send you email notifications when you place a product in your basket and you abandon your browsing before completing your checkout. We do this based on our legitimate interests. To provide you with tracking information so that you can follow your order. We do this under legitimate interest to enhance your customer experience and give you more information about where your delivery is and when your order will arrive.
• 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.

For example, by checking your password when you log in and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

• To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our stores and car parks which record images for security. We do this on the basis of our legitimate business interests.
• To process payments and 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, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK.

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.

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 Notice, 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 display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. If not through the use of cookies or similar technology, then on the basis of our legitimate interest.

For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

• 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, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

• To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law

• To send you surveys 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.
• To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the Partnership, third parties and data from 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.

For example, combining this data, will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.

• For DK Wholesale LTD members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become a DK Wholesale member. If you don’t want to continue receiving DK Wholesale LTD offers, you’ll be unable to continue your DK Wholesale LTD membership.

For example, if you consent through our apps, we may use your shopping preferences to offer you tailored rewards.

• Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery). Without sharing your personal data, we’d be unable to fulfil your request.
  Here’s more
• Help inform business decisions for example which 3rd Party websites we partner with to ensure our advertising reaches our customers.

Across the DK Wholesale LTD, we record your interactions with us e.g. looking at how often you might shop with us or how much you spend. We do this to create a profile on how you interact with the Partnership and, in turn, that can affect how we engage you. For example, if you shop with us regularly, then this can affect what offers and rewards you might receive from us. We rely on our legitimate interest to undertake this activity.

We do this to ensure we have a clear view of what you like and to ensure that you are rewarded appropriately so that direct marketing or browsing on our websites is tailored to your preferences. This also allows your receipts to be stored in your online account, if you have one, even if you are shopping in our store. We may also use the information we collect via the consolidation of your spending to inform our business decisions. This is done either by anonymising your spending and analysing it as part of a “spend-trend”, statistical view or by working with our third party suppliers, such as Google.

When you purchase a product from us that is delivered by the manufacturer or supplier of said product, we will pass on your contact details so that they can deliver your purchased product. The same with regard to warranties provided by the manufacturer or supplier of the product you bought. For example, if you buy an air fryer from us we will pass your details to the supplier of the air fryer to ensure the delivery of the goods and to fulfil any supplier product guarantees. We do that to ensure that we fulfil our contractual obligations to you.

If the manufacturers or suppliers wish to pass your details to other third parties or use it for other purposes, they must provide you with sufficient information about whom they share your personal data, for what purposes they intend to use it, and in some cases, they may be required to ask for your consent to do so. If they do not provide you with that information or collect your consent, and you are worried that they may have shared your personal data with someone else, you are entitled to contact them directly for clarification.

Combining your data for personalised direct marketing

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Partnership as described above, for example, your shopping history at DK Wholesale LTD. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.

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 secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and encrypted to ensure it is protected.
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 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.

Some examples of customer data retention periods:
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 certain products, such as electrical items, we’ll keep the data for 10.5 years.
Warranties: If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.

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 to contact you about your order delivery & occasionally service review messages
• Direct marketing companies who help us manage our electronic communications with you.
• Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details..
• Data insight companies to ensure your details are up to date and accurate.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

For example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.

• For 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.
• For further information please contact our Data Protection Officer.

To help personalise your journey through Partnership websites we currently use the following companies, who will process your personal data as part of their contracts with us:

• Trustpilot
• Doubleclick
• Google
• Twitter
• Instagram
• YouTube
• Yahoo
• Pinterest
• Facebook
• TikTok
• Yodel
• DPD
• Royal Mail
• Adobe Magento

Where your personal data may be processed

The Partnership is a UK based company and so we will transfer your data to the UK, which is outside of the EU. We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

Protecting your data outside the UK
We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK.

For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

What are your rights over your personal data?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• The deletion of the data we hold about you, in specific circumstances; 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).
• A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
• Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
• That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
• 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.
• Review by a Partner of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
• You can contact us to request to exercise these rights at any time by
• If we choose not to action your request, we will explain 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, such as the administration of an extended warranty.

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, such as the administration of an extended warranty.

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.

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 communication that we send you. We will then stop any further emails from that particular division.
• If you have an account, log in to your dkwholesale.com account, visit the ‘My Account’ area and change your preferences.
• Write to Data Rights Team – DK Wholesale LTD, 4 Harthill Street, Manchester – M8 8AG, United Kingdom.

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

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
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 15.

If you live outside the UK

For all non-UK customers
This Privacy Notice shall be provided in English language.

When placing an order with the Partnership, browsing our website, including for analytics and website usage research, and/or agreeing to receive direct marketing electronic communications as described in this Privacy Notice and our Cookies Notice, your personal data will be processed by us or on our behalf. Of course, you still have the right to ask us not to process your data in these ways, and if you do so, we will respect your wishes.

Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we will transfer your personal data to the UK and may also transfer your personal data to third parties located in the UK to your country of residence.

We will ensure that any third parties only process your personal data in accordance with their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside. We do not actively take steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.

If you have any questions, please contact our Data Protection Officer, and we will respond within your local timeframe response requirements. To complain about an alleged breach of this Privacy Notice or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.

For the purposes of this Privacy Notice, “personal data” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, or opinion is recorded in a material form.

We are committed to keeping your personal information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

As your data may be transferred to third parties outside the country where you are located, local police or other enforcement, regulatory or Government bodies may have access to that data with or without the Partnership’s knowledge. The personal data we process may be accessed by persons within the Partnership, or our third-party service providers, who require such access to carry out the purposes indicated in this Privacy Notice or such other purposes as may be permitted or required by the applicable law. Personal data we collect is maintained primarily in the UK.

Any questions?

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

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

• Email us at info@dkwholesale.co.uk