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Protecting your privacy

John Lewis Partnership

Contents of this Privacy Notice

  1. Introduction
  2. What is The John Lewis Partnership?
  3. Explaining the legal bases we rely on
  4. When do we collect your personal data?
  5. What sort of personal data do we collect?
  6. How and why do we use your personal data?
  7. Combining your data for personalised direct marketing
  8. How we protect your personal data
  9. How long will we keep your personal data?
  10. Who do we share your personal data with?
  11. Where your personal data may be processed
  12. What are your rights over your personal data?
  13. How can you stop the use of your personal data for direct marketing?
  14. John Lewis Finance
    1. How we use your personal data
    2. How our providers use your personal data
    3. Joint use of your personal data
  15. Contacting the Regulator
  16. If you live outside the UK
  17. Any questions?

1. 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 John Lewis Partnership uses your data.

For example, we will explain things such as our credit checking procedure and how we combine data across the the John Lewis Partnership to build a picture of you.

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.

When you are using the Waitrose websites, Waitrose Ltd is the data controller.

2. What is The John Lewis Partnership?

The John Lewis Partnership – which we’ll refer to as ‘the Partnership’ in this document – is made up of a number of related businesses:

For simplicity throughout this notice, ‘we’ and ‘us’ means the Partnership and its brands.

3. 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 in 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

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

4. When do we collect your personal data?

5. What sort of personal data do we collect?

6. 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.

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:

7. 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 both John Lewis and Waitrose. 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 – such as the Land Registry mentioned above.

8. 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 tokenized 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.

9. 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 and nursery items, we’ll keep the data for 10 years.

Inactive accounts

If you’ve not used your account for more than five years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we’ll close the account and delete or anonymise the personal data associated with it.

Warranties

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

10. Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, delivery couriers, technicians visiting your home, 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:

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.

  • 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:

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:

11. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Partnership in the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such as Australia or the USA.

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 inside the EEA. 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.

12. 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.

  • 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 can contact us to request to exercise these rights at any time as follows:

To ask for your information please contact Data Protection Officer, Partnership House 1st Floor, Carlisle Place, London SW1P 1BX or email DPO@johnlewis.co.uk. To ask for your information to be amended please update your online account or contact our customer services team.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.

We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

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.

13. 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 into your John Lewis or Waitrose 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 Partnership House, 1st Floor, Carlisle Place, London SW1P 1BX.

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

14. John Lewis Finance

14.1. How we use your personal data

When you purchase a product or service from John Lewis Finance, we might receive a copy of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you. You are free to opt out of receiving marketing communications from us at any time.

Find out more about the use of your data for marketing in section 7.

14.2. How our providers use your personal data

When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies.

Here are those individual privacy policies: (all links open in a new window; please note we can't be responsible for the content of external websites)

14.3 Joint use of your personal data

We will share data with our providers to bring you relevant offers, updates, products and services, and discounts that reward your loyalty to our brands.

We may check your details with appropriate third parties (for example credit reference agencies, such as Experian) before we send you promotions for our financial services products, to ensure your information is accurate and fulfils our legal and regulatory obligations, and to tailor those offers to you.

Rest assured that all applications for financial services products will be assessed on a case-by-case basis.

15. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

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 16.

16. If you live outside the UK

For all non-UK customers

This Privacy Notice will be available in English, French, Spanish, Portuguese, Malay and Chinese languages. In case of any dispute about its meaning, the English version will take precedence.

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.

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

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.

We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

We’ll ensure that any third parties process your personal data only in accordance with their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.

Australia

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, and whether or not the information or opinion is recorded in a material form.

If you are in Australia you may submit any questions, comments or complaints to our UK-based Data Protection Officer who will come back to you within 30 days.

If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.

We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.

If we have not come back to you within 30 days, or you are not happy with the response that you’ve received, you may submit a complaint to the Office of the Australian Information Commissioner.

We are committed to keeping your personal information secure and will take 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).

USA

To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our Cookies Notice.

Canada

As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.

The personal data we process may be accessed by people within the Partnership, or by our third-party service providers, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.

If you have any questions, please contact our Data Protection Officer.

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 information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.

South Korea, Malaysia, Singapore, Qatar

Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).

By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.

Hong Kong

When you agree to receive direct marketing emails from us, we’ll send you promotions on products we sell at John Lewis.

If you are in Hong Kong you may submit a complaint to our UK-based Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive, you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.

17. 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 on DPO@johnlewis.co.uk

Or write to us at
Data Protection Officer

Partnership House

1st Floor

Carlisle Place

London SW1P 1BX

This notice was last updated on 16/04/2018

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