- Our Commitment
We respect your right to privacy and are committed to protecting it. We’ll always keep your personal data safe and will never sell it to third parties. We’ll be clear and open with you about why we collect your personal data and how we use it. Where you have choices or rights, we’ll explain them to you and respect your wishes.
- Please help us keep your data accurate
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Contact us at email@example.com.
- Please read me
Please read this privacy notice and any other privacy notice or fair processing notice we may provide on specific occasions carefully, as it is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export and delete your information.
This privacy notice supplements the other notices and is not intended to override them.
- Who we are
John Cotton Group
John Cotton Group Limited (JCG), Company Number: 273492 referred to here after as we, us and our. VAT Number is 183 3663 49. EarthKindTM is a trading name of JCG.
The Data Controller
John Cotton Group Ltd (“We”, “us”, “our”) is the data controller (registered with the ICO under registration number: ZA279890) for all the organisations within the group and our registered office address is No 1 Park Row, Leeds, LS1 5AB.
This means that John Cotton Group Ltd determines what data is collected by each organisation within the group, how this data is going to be used and how this data is protected.
- How to contact us
If you have any questions about this privacy notice or data protection generally or you want to exercise your rights, please contact our Privacy team at firstname.lastname@example.org.
John Cotton Group
Low Mill Lane
- Your Rights
You have a number of ‘Data Subject Rights’. Below is some information on what they are and how you can exercise them. There is more information on the Information Commissioners website www.ico.org.uk
- Right of access – You have the right to request a free copy of the personal information that we hold about you.
- Right to rectification – If you think any of your personal information that we hold is inaccurate, you have the right to request it is updated. We may ask you for evidence to show it is inaccurate.
- Right to erasure (also known as the Right to be Forgotten) and the Right to restriction of processing – You have the right to request that we stop processing, or delete, all of your personal information that we hold. If you exercise this right we will keep a note of your name linked to your request and it won’t prevent us from processing any new information you provide to us subsequently.
- Right to data portability – You have the right to ask us to electronically move, copy or transfer your personal information in a machine-readable format.
- Rights with regards to automated decision making, including profiling – We may sometimes use your personal information to make decisions by automated means. This involves us analysing your account activity including applications, orders, payments etc. We do this to confirm your identity, prevent and detect crime, and lend responsibly. This automated decision making is necessary if you would like to continue to shop with us online. You have a right to reject automated decisions but it may mean that you can only shop with us in our stores.
- Right to withdraw Consent – Where we are relying on your consent for processing you can withdraw or change your consent at any time.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
If you have any general questions or want to exercise any of your rights please contact email@example.com. Our security procedures mean that we may need to request proof of identity before we disclose personal information to you in response to any request.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the Information Commissioners Office, the data protection regulator in the UK, their contact details can be found on their website www.ico.org.uk
- The lawful bases we use to process data
We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are;
- Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime or to meet responsible lending criteria.
- The information we collect and how we use it
To process any orders that you place with us and to facilitate any returns (Contract)
- We take payment details to process payment for any credit or debit card orders you place with us. We share these details with our chosen payment processors (for example Globalpayments or PayPal)
- We use your account information plus your chosen delivery address details to; deliver your purchases and keep you informed of their status, and to process any returns including (where appropriate) collecting the item from you.
- Our chosen payment processors store your payment card details at your request to speed up your checkout in the future (consent)
To provide you with access to an account (Contract)
- To register an account with us we capture information such as your name, contact and delivery information, and a password to protect your account (account information). We use the same information on an ongoing basis to manage and provide secure access to your account, and provide you with the services you request.
To provide customer service to you (Legitimate interest)
- We may record calls and keep correspondence (customer service records) when you contact our customer service teams or interact with us on social media. We use these customer service records to manage your queries or complaints effectively, for quality monitoring and to continually improve our services.
To personalise and improve your experience when you shop (Legitimate Interest)
- We keep a record of how you interact with our website and any marketing you are exposed to, we use this data, along with purchase history, demographics, account information and third-party information, to show you products and offers from across our brands that we think you will be most interested in and to tailor your experience.
- We use your account information, information on the devices you use to access our sites and your interactions with us to operate personalised features across our websites, apps and communications.
To inform you about products and services that may interest you (Legitimate Interest)
- We use technologies such as cookies within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you and other customers. We share aggregated and anonymised information about the customer segments we are interested in reaching with advertising partners, so they can focus on showing adverts to those who are most likely to be interested in our products, services and offers, and to prevent them showing you irrelevant or repetitive advertisements.
- We share limited information with selected suppliers to enable them to identify new prospective customers on our behalf and to prevent us repeatedly advertising products or services you have already bought.
- We receive information on how you interact with our adverts and content on third-party websites and social media platforms (such as Google or Facebook) which we use to tailor the information that is displayed to you.
To keep in touch with you (Legitimate Interest)
- When you register for an account and shop with us, we keep you up to date with the status of your order.
- We use your account information to notify you about important service messages, such as product recalls or information about your account.
To ensure the Website and the services we offer you operate properly (Legitimate Interest)
- We use other cookies and similar technologies to help us understand how you use the site, this allows us to optimise your shopping experience and continually improve our site.
- We gather information about the devices you use to access our sites (desktop and mobile) for example your IP address and device type, to ensure the site is secure and works across multiple platforms.
- We use information for Logistics planning, demand forecasting, management information, dealing with errors on our site, and general research and development.
To develop and improve our products, range and services (Legitimate Interest)
- We may contact you to take part in customer satisfaction surveys, if you respond, we collect your feedback and contributions (customer feedback). We use this information to develop the services we offer.
- We use information about how you browse and engage with our website to improve our websites.
- We use all information, including third party data in the development of new products, services and systems to ensure they work as expected and will be useful to our customers.
To prevent and detect crime (Legitimate interest/Legal obligation)
- We use your account information, order history and payment history to assist in monitoring for fraudulent transactions or suspected money laundering.
- When you register an account or contact our customer services, we use your account and purchase history information to confirm your identity.
- We use device identifiers and IP addresses in fraud prevention and investigation, and to maintain network and data security.
To fulfil our legal obligations (Legal obligation)
- We use your data to ensure we comply with any requirements imposed on us by law or court order, including disclosure to law or tax enforcement agencies and authorities or pursuant to legal proceedings.
- We will share data with regulatory and other official bodies if they make formal requests.
- We will maintain records to meet regulatory and tax requirements.
- We will use your account information to contact you in connection with product recalls or other similar product quality issues and to comply with our legal obligations.
- How long we keep it for
We keep your personal information as long as you are a customer of ours and generally for five years afterwards to comply with legal requirements. During that time we take steps to remove any personal data as soon as we no longer need it.
We consider you a customer
- as long as you hold an active account,
- for 5 years from the point you last made a purchase from our website, or
- during any time we are managing a customer service request from you.
- Third Parties we share data with and receive data from
We work with a number of trusted third parties to provide you high quality goods and services. Anybody we work with is subject to stringent security and data privacy assessments before we begin to do business with them and on an ongoing basis.
We always make efforts to anonymise data and only pass over personal information that is absolutely necessary for the purposes it is being processed. We always do so securely.
We have contracts in place with all suppliers that help us to ensure security and privacy of your personal information, these are reviewed and updated regularly and always in line with data protection laws.
- Delivery Partners – Helping us to deliver the goods you order to you including our brand partners that dispatch and deliver goods to you directly.
- IT Companies – Supporting us in maintaining our website and other business systems including; providing phone lines, data storage facilities, and providing and supporting server based infrastructure used in providing our products and services.
- Marketing Companies and Online Advertising – Helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in, Companies that provide marketing and advertising assistance (including management of email marketing operations and services that deploy advertising on the internet or social media platforms, such as Facebook and Google) as well as analysis of the effectiveness of our advertising and communications campaigns.
- We use technologies such as cookies, pixels, and device IDs within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you.
- Consumer profiling organisations – These organisations provide demographic or other data to help better understand customers’ demographics, lifestyles or shopping.
- Payment processors – Payment card processors to process credit and debit card payments and store payment information; for example Globalpayments and Paypal.
- Sending information outside the European Economic Area
Our operations are based in the UK and your personal information is processed, stored and used within the UK.
You can find out more about the above data protection safeguards on the European Commission Justice website.
- Third-party apps, websites and services
If you use any third-party apps, websites or services to access our services, your usage is subject to the relevant third party’s terms and conditions, cookies policy, and privacy notice. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy notices of the relevant social media platform (Facebook, Twitter etc.). The same stands if you use third-party services, like Amazon’s Alexa, as your use of the service is subject to their applicable terms and conditions. We may be required to share customer information relating to transactions and use of such third-party services with that third party.
- How you can get in touch
Should you need to contact us please write to:
John Cotton Group
Low Mill Lane
or via firstname.lastname@example.org