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 ERA uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

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 what catagories of products you are opting in to receive information about and how you want to be contacted. 

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, we’ll collect your address details to deliver your purchase, and pass them to our courier. 

If you have a credit account with us and an established price list, we may also need to use your contact details to alert you of any changes to your agreed contractual pricing.

Legal compliance

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

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

Legitimate interest

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 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 or email, telling you about products and services that we think might interest you.

When might we collect your personal data?

• When you visit any of our websites, and use your account to buy products and services
• When you make an online purchase and check out by credit card (in which case we just collect transaction-based data).
• When you register for an account with us.
• 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 download or install one of our apps. 
• When you contact us by any means with queries, complaints etc.
• When you enter prize draws or competitions.
• When you book any kind of appointment with us.
• When we see you at an exhibition or show and you have shown an interest in our products
• When you choose to complete any surveys we send you. 
• When you comment on or review our products and services.
• When you’ve given a third party permission to share with us the information they hold about you.
• We may collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.

What sort of personal data do we collect?

• If you have a web account with us: your name,  invoicing &delivery address, orders and receipts, email and telephone number. For your security, we do not keep any record of your password but in the event you lose it, you can request for it to be reset.
• Your email address from any of our app sign ups with your opt in/out preference
• Details of your shopping history
• Details of your visits to our websites and which site you came from to ours
• Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and 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.
• Your address and contact details in relation to our Find an Installer Scheme

How and why do we use your personal data?

It is important to ERA that we give you the best possible customer experience and only contact you about relevant products or services we feel you may be interested in. We use data collected to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

You can choose to change your preferences in how we contact you and what information we hold – see more in ‘What are my rights?’ section below.

Remember, it is important to consider whether you truly want to opt out completely as doing so may mean we cannot provide all of the services or information you have asked for.  Changing preferences is often a better way to manage contact, rather than opting out altogether. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

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

• To process any orders that you make by using our websites. 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 your information 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. 

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

• 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.
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, post or 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.

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 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.

• 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 which are accessible at the bottom of every marketing email or contacting us on: [email protected] and requesting to be removed.

• To process your booking/appointment requests (for example with an installer). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or a fitter 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.

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

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by encryption.

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

Suppliers who receive your data from us for processing purposes, such as delivery companies, are also GDPR reviewed periodically to ensure their data is maintained appropriately under the same, strict access and storage conditions.

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 six years so we can comply with our legal and contractual obligations. In the case of certain products, such as British Standard Nightlatches where they have a 10yr Guarantee, we’ll keep the data for 10 years. 

Warranties

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

Marketing

For marketing purposes, your information will be maintained for 3 years following inactivity, or for as long as you are an active customer, or have opted in via preferences to continue receiving information.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. 

For example, delivery couriers, engineers visiting your home, for fraud management, or to handle complaints. 

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.
• We have reviewed all GDPR policies to ensure their practices in storage and access of data are acceptable.

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 electronic communications with you.
• 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.

For further information please contact our Data Protection Officer at [email protected]

Where your personal data may be processed.

When transacting through our websites, by email or by telephone, your data is transacted and stored in the EU according to legislation.  Any external suppliers are fully compliant with GDPR and internal systems are fully secure and protected.

For smartware registration data and cloud based storage of personal settings, video or image content, please refer to our separate smartware privacy policy.

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?

An overview of your different rights

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.
• 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.
• Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, ERA, Valiant Way, Wolverhampton, WV9 5GB.

To ask for your personal information to be amended such as your name, or telephone number, please contact our Customer Services team or email [email protected]

To change your contact preferences for marketing emails, please click on the preferences link at the bottom of a previous email we have sent you and change the settings to your requirement, or email us on [email protected]

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.

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

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

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 ‘change preferences or unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• 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 when you register.  Should you wish to opt out from contact, please unsubscribe in any emails you receive from us.
• Write to our Marketing Department at ERA, Valiant Way, Wolverhampton, WV9 5GB or contact [email protected]

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

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 [email protected]
• Or write to us at Data Protection Officer, ERA, Valiant Way, Wolverhampton, WV9 5GB.

This notice was last updated on 21 May 2018.