1Important information and who we are
2The data we and our franchisees collect about you
3How is your personal data collected?
4How we use your personal data
5Disclosures of your personal data
8 Data retention
9Your legal rights
1 Important information and who we are
We are Just Shutters (Franchise) Limited, trading as Just Shutters. Our registered office is at 59 Southbourne Grove, Bournemouth, Dorset, United Kingdom, BH6 3QU and our company number is 05786177.
Our franchisees are independent business owners and each franchisee is responsible for its own data protection compliance. However, we work very closely together with our franchisees, including sharing data and information between us, to provide our goods and services to you. To keep it simple for you, this notice therefore explains how your personal data is collected and used by us and by the franchisee with whom you have a business relationship (or who we refer to). When we use the term “our franchisees” in this policy, we are referring to that particular franchisee and not our franchisee network generally.
This website is not intended for children and we do not knowingly collect data relating to children.
If you have any queries about this policy or how we or our franchisees use your data, please get in touch using the details shown in the Contact Details section below.
We and our franchisees are the parties responsible (the “data controllers”) for holding your data in relation to any queries or requests for quotes you submit, any transactions you enter into with our franchisees and any newsletters and marketing you’ve signed up to receive from us. We are also responsible for the operation of the website.
It is important that the personal data we and our franchisees hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2 The data we and our franchisees collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We and our franchisees may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or our franchisees.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we and/or our franchisees need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3 How is your personal data collected?
We and our franchisees use different methods or our franchisees to collect data from and about you including through:
• Direct interactions. You may give us or our franchisees your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Request a quotation for our products or services or to complete an order form;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• From our franchisees. If you are corresponding with one of our franchisees, for instance in relation to a quote or a contract for products or services or relating to any publications or marketing that franchisee produces, we may receive from that franchisee any Identity, Contact, Financial, Transaction and Marketing Communications Data you provide to them or that they create relating to your account.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as banks and credit card providers.
o Identity and Contact Data from our suppliers.
4 How we use your personal data
We and our franchisees will respectively only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Click here [Glossary] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we and our franchisees plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we and our franchisees may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer including completion of order forms||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Installation of goods
(e) Marketing and
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Responding to your enquiries
(c) Asking you to leave a review or take a survey
(c) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(d) Marketing and Communications
|To administer and protect our business and all website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(d) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We and our franchisees strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We and all our franchisees may use your Identity, Contact, Technical and Usage to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We and our franchisees will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us, all franchisees or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We and our franchisees will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us or the franchisee you have been in contact with.
If we and our franchisees need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we and our franchisees may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
For further information on how franchisees process, use and store your personal data, please contact them using the Contact Details section below.
5 Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
• Between us and our franchisees. We and our franchisees share your personal data between us in order for our franchisees to be able to provide Just Shutters products and services to you, for us to be able to maintain a centralised database of customers for customer services, in order for us and the franchisees to be able to respond to complaints and enquiries, and for marketing purposes (provided you have opted-in). For example, if you correspond with our franchisees in relation to a quote or a contract for products or services or relating to any publications or marketing that franchisee produces, we receive from that franchisee any Identity, Contact, Financial, Transaction and Marketing Communications Data you provide to them or that they create relation to your account. Similarly, if you correspond with us to subject a request for a quote for products or services via the website, we pass on to our franchisees Identity, Contact, Financial, Transaction and Marketing Communications Data that is needed for our franchisees to provide the requested service.
• External Third Parties as set out in the [Glossary].
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6 International transfers
We do not transfer your personal data outside the European Economic Area.
7 Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8 Data retention
How long will you use my personal data for?
We and our franchisees will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. For enquiries made or quotations given which have noted to you becoming a customer, we will keep the Contact and Identity Data collected for two years.
In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9 Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• [Request access to your personal data].
• [Request correction of your personal data].
• [Request erasure of your personal data].
• [Object to processing of your personal data].
• [Request restriction of processing your personal data].
• [Request transfer of your personal data].
• [Right to withdraw consent].
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10 Contact Details
For us. If you have any questions about the aspects of this policy relevant to us, or the use of your personal data by us, please contact: Just Shutters (Franchise) Limited: Address: 59 Southbourne Grove, Bournemouth, BH6 3QU Tel: 01202 240769
Email: [email protected].
For our Franchisees. If you have any questions about the aspects of this policy relevant to the franchisee you have been in contact with, or the use of your personal data by them, please use the details provided to you by in the correspondence received from that franchisee.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers.
• HM Revenue & Customs, regulators and other authorities.
You have the right (in relation to personal data held by us and our franchisees) to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we or our franchisees are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we or our franchisees (as the case may be) may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like to exercise any of the rights described above against either us or our franchisees, please direct your enquiry to the appropriate party, as described in the Contact Details section of this policy.
Last updated: 16 September 2019