Privacy Policy

                          Standard Privacy Policy
 

                                                       Wolseley UK Privacy Policy – August 2021

1. INTRODUCTION 
Wolseley UK Limited (“Wolseley”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we collect, use and look after your personal data. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

2. CONTROLLER 
Wolseley UK Limited is the controller and responsible for your personal data (collectively referred to as ”Wolseley”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

3. CONTACT DETAILS 
Our full details are: Wolseley UK Limited, 2 Kingmaker Court, Warwick Technology Park, Gallows Hill, Warwick, CV34 6DY (Company Number 636445) Data Privacy Officer: Dataprivacyofficer@wolseley.co.uk 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.

4. YOUR DUTY TO INFORM US OF CHANGES 
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. If you notify us of any changes to your personal information we will correct, update or remove your data as speedily as possible. If you would like us to, correct, amend or update your information please e-mail us at dataprivacyofficer@wolseley.co.uk.

5. INFORMATION WE COLLECT FROM YOU 
We may collect, use, store and transfer the following different kinds of personal data about you: 
1. Name and contact details – this includes your name, title, billing address, delivery address, email address and telephone numbers 
2. Date of birth information 
3. Payment and Financial information – this may include your bank account and/or payment card 
4. Purchase history – this includes details about products you have purchased from us 
5. Profile information – this includes your username and password for any systems or websites you have access to (for example extra) 
6. Marketing information – this includes your interests, your preferences in receiving marketing from us and your communication preferences 
7. Survey responses and competition entries 
8. Customer service history – this includes interactions with us over the phone, by email or letter, via the website or on social media 
9. Record of any complaints and related communications
10. Information about your device and how you use our website and apps – this includes information you give us when you browse our websites or apps, including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as how you use our websites and apps

Unless we have told you otherwise in a specific privacy notice, 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.

6. HOW WE COLLECT YOUR PERSONAL DATA 
We use different methods to collect data from and about you including through: 
1. Direction interactions: you may give us your name and contact details and payment information when purchasing a product from us or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
a) create an account with us; 
b) register on our website; 
c) purchase a product from us; 
d) subscribe to our mailing lists or newsletters; 
e) request marketing to be sent to you;
f) take part in a competition, promotion or survey; 
g) trade in a branch via CCTV records; and 
h) give us some feedback.
2. Automated technologies or interactions: As you interact with our website and our apps, we may automatically collection information about your device and how you use our website and apps. We collect this personal data by using cookies, server logs and similar technologies. For more information on cookies, please see our cookie policy. 
3. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as:
a) information about your device and how you use our websites and apps from analytics providers such Google based outside the EU; and 
b) Name and contact details, payment information and purchase history from providers of technical, payment and delivery services.

7. USES MADE OF THE INFORMATION 
We (and our trusted partners acting on our behalf) use information held about you in the following ways: 
1. where we need to perform the contract, we are about to enter into or have entered into with you 
2. 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; 
3. where we need to comply with a legal or regulatory obligation; 
4. for certain processing purposes, we may request your consent to authorise the processing.
Our legitimate interests include: 
a) Selling and supplying goods and services to our customers; 
b) Protecting customers, employees and other individuals and maintaining their safety, health and welfare; 
c) Promoting, marketing and advertising our products and services; 
d) Sending promotional communications; 
e) Performing market research; 
f) Understanding our customers’ behaviour, activities, preferences and needs; 
g) Improving existing products and services and developing new products and services; 
h) Complying with our legal and regulatory obligations; 
i) Preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; 
j) Handling customer contacts, queries, complaints or disputes; 
k) Use of CCTV to record in branch trading. Our CCTV records are typically held for between 28 – 32 days only determined by the type of CCTV equipment, when it is then automatically overwritten. Copies of CCTV footage should be requested via our data protection officer. 
l) Protecting Wolseley UK, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Wolseley UK; 
m) Effectively handling any legal claims or regulatory enforcement actions taken against Wolseley UK; and 
n) Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

8. WHO WE SHARE YOUR DATA WITH 
We will share your personal information with the following bodies. Please note that we will never sell or rent our customer data to other organisations for marketing purposes:
1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 
2. Selected third parties including:
a) business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; 
b) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; 
c) market research companies that require the data to fulfil marketing and research activities; 
d) analytics and search engine providers that assist us in the improvement and optimisation of our site; 
e) credit reference agencies (“CRA’s”) for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. CRA’s will also give us information about you, such as your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRA’s on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRA’s will share your information with other organisations. The identities of the CRA’s and the way in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.

2. We will disclose your personal information to third parties: 
a) In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. 
b) If Wolseley UK or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 
c) Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
              -      to comply with our legal obligations; 
              -      to exercise our legal rights (for example in or in order to enforce or apply our terms and conditions and other agreements); 
              -      for the prevention, detection, investigation of crime or prosecution of offenders; and
              -      or to protect the rights, property, or safety of Wolseley UK, our employees customers, or others.
d) Other companies and organisations for the purposes of fraud protection and credit risk reduction. 
e) In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.

9. HOW LONG DO WE KEEP YOUR DATA? 
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data. Please contact us if you require further details.

10. GLOSSARY 
We recognise that some of the privacy law terminology can be a bit complicated, so we have set out below some further detail on some of the terms used in this policy: 
Lawful basis:
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).
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. For example, where we are sending you a product you have purchased from us or where you have entered a competition on our website, we will be processing your personal data on the basis that it is necessary for us to do so in order to perform a contract between us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.



                                                                           Processor Terms

WOLSELEY UK LIMITED 
GDPR ADDENDUM 
Effective: 25th May 2018
                                                                                                                                                                                                                                                                                                                                                                                                                            

                                                                               DATA PROCESSOR TERMS 
                                                                                    GDPR ADDENDUM
1. DEFINITIONS 
1.1. In this GDPR Addendum, the following words and phrases will have the following meaning:
 

 1.2. In this GDPR Addendum, expressions defined in the Terms and Conditions and used in this GDPR Addendum have the meaning set out in the Terms and Conditions.

2. ROLES OF THE PARTIES 
2.1. Both parties will comply with all applicable requirements of the Data Protection Legislation. This clause 2.1 is in addition to, and does not relieve, remove or replace, a party's obligations under the Data Protection Legislation.
2.2. The parties acknowledge that for the purposes of this GDPR Addendum and the Data Protection Legislation, the Customer is the Controller and the Company is the Processor (where Controller and Processor have the meanings as defined in the Data Protection Legislation). 
2.3. Appendix 1 sets out the scope, nature and purpose of Processing by the Company, the duration of the Processing, the types of Personal Data and categories of Data Subjects.

3. CUSTOMER OBLIGATIONS 
3.1. Without prejudice to the generality of clause 2.1 the Customer:
3.1.1. shall ensure that it has all necessary and appropriate consents and notices in place to enable the lawful transfer of th Personal Data to the Company (on a lawful basis under Data Protection Legislation) for the duration and purposes of this GDP Addendum;
3.1.2. comply with Data Protection Legislation and ensure that any instructions it issues to the Company shall comply with Data Protection Legislation;
3.1.3. have sole responsibility for the accuracy, quality, and legality of Personal Data, and the means by which the Customer acquired Personal Data and shall establish the legal basis for Processing under Data Protection Legislation.
3.2. The Customer warrants that:
3.2.1. the disclosure of Personal Data to the Company is limited to what is necessary in order for the Company to perform the Services; and
3.2.2. such Personal Data is accurate and up-to-date at the time that it is provided to the Customer.

4. COMPANY OBLIGATIONS 
4.1. Without prejudice to the generality of clause 2.1, the Company shall, in relation to any Personal Data Processed in connection with the performance by the Company of its obligations under this GDPR Addendum and the Terms and Conditions:
4.1.1. Process that Personal Data only on the written instructions of the Customer or as required by law;
4.1.2. inform the Customer if, in its opinion, an instruction infringes Data Protection Legislation; 
4.1.3. ensure that all personnel authorised by the Company to Process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
4.1.4. implement appropriate technical and organisational measures to protect against unauthorized or unlawful Processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data having regard to the nature of the Personal Data which is to be protected and the risk of harm which might result from a Personal Data Breach;
4.1.5. inform the Customer without undue delay of any Personal Data Breach; 
4.1.6. assist the Customer, at the Customer’s cost, in responding to any request from a Data Subject and in ensurin compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities including the Information Commissions Office, or any other regulator;
4.1.7. at the written direction of the Customer, delete or return Personal Data on termination of the Contract and/or thi GDPR Addendum unless required by law; and;
4.1.8. maintain complete and accurate records and information to demonstrate its compliance with this clause 4 and (at th cost of the Customer) allow for reasonable audits to take place, by mutual agreement together with reasonable notice, by the Customer or the Customer’s designated auditor.

5. APPOINTMENT OF SUBPROCESSORS
5.1. The Customer provides a general authorisation to the Company to engage subprocessors to process Personal Data.
5.2. Where the Company engages a subprocessor to Process Personal Data in connection with the performance by the Company of its obligations under this GDPR Addendum and the Terms and Conditions, the Company will have in place a contract with such subprocessor on substantially the same data protection obligations as those set out in this GDPR Addendum.
5.3. If the Customer requests, the Company will inform the Customer of the name, address and role of each subprocessor it uses to provide the Services.
5.4. The Company’s use of subprocessors is at its discretion, provided that the Company shall provide the Customer with written notice of the appointment of any new or alternative subprocessor.
5.5. If the Customer reasonably objects to the appointment of a new or alternative subprocessor and has the right to object to such appointment pursuant to the express terms of the Data Protection Legislation, the Customer may (within 30 days of such appointment) escalate any reasonable objection to their relationship manager for discussion.
5.6. If the Customer has not notified the Company in writing of any reasonable objection within 30 days of the date of the notice then the Customer shall be deemed to have approved the use of such subprocessors.

6. TRANSFERS OUTSIDE EEA
6.1. The Company will ensure that no Personal Data is transferred out of either:
6.1.1. The European Economic Area; or 
6.1.2. Any other territory in which restrictions are imposed on the transfer of Personal Data across borders under Dat Protection Legislation; without the prior written consent of the Customer, which is hereby given, subject to Clause 6.2.
6.2. The Company will ensure that Contractual Clauses or other appropriate safeguards are in place to ensure an adequate level of data protection.

7. LIABILITY
7.1. The exclusions and limitations of liability set out in the Terms and Conditions shall apply to the terms of this GDPR Addendum.

APPENDIX 1: Data Processing Register