Changing Lives in Together ("CLT") is committed to protecting your personal information.
For simplicity throughout this notice: "we", "our" and "us" means Changing Lives Together.
2. Who we are and how to contact us?
Our stores and website and the services we provide are all operated by Changing Lives Together.
Changing Lives Together is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: Z6829149.
Changing Lives Together is registered in England & Wales as Charity No. 1139983 and a Company Limited by Guarantee No. 07400060. The Registered Office is at Unit 12, Road Two, Winsford Industrial Estate, Cheshire, CW7 3QL.
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. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
3.1 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.
If your business with us is through a contract with a third party we have a contractual obligation to keep your information for a set amount of time.
We only keep your personal information as long as it is required.
In specific situations, we can collect and process your data with your consent. For example:
When you tick a box to receive email newsletters.
3.3 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 CLT to law enforcement.
3.4 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 may use your purchase history to send you or make available personalised offers.
We may combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We may 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?
Generally, we collect your information when you contact us. This could include:
When you purchase a product or service in store, online or by phone.
When you use one of our websites, for example this one, www.changing-lives-together.org.uk.
When you make a donation to us in store, online or by phone.
When you contact us by any means with queries, complaints etc.
When you fill in any forms for transactional, employment or other purposes.
When you engage with us on social media.
When you book any kind of appointment with us or book to attend an event, for example a Training Course.
When you comment on or review our products and services.
Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the partner who provided that service, it may be passed on to them if requested.
When you use our shops which usually have CCTV systems operated for the security of both customers and us. These systems may record your image during your visit.
When you enter prize draws or competitions.
When you choose to complete any surveys we send you.
When you’ve given a third party permission to share with us the information they hold about you. For example, if you apply to a Council Local Welfare Assistance Scheme or a Council Bulky Waste Service.
5. What sort of personal data do we collect?
We only collect information that is necessary to carry out our business, provide the service you have requested and to keep you up to date with our charity’s work.
5.1 Information we obtain directly from you that may include your name, billing/delivery/collection address, email and contact phone number, and orders and receipts.
We collect personal details mentioned above so we can fulfil our delivery and collection service.
We collect notes from our conversations with you.
Details of any complaints or comments you make.
Details of purchases you made.
Details of donations you made.
How and when you contact us.
5.2 Information about the services that we provide to you.
The items we have provided to you, when and where, the amount you paid.
5.3 Details of your interactions with us in store, online or through our reception and telephone systems.
5.4 Payment card information.
5.5 Whether you are a UK tax payer so we can claim Gift Aid.
5.6 Your image may be recorded on CCTV when you visit one of our premises.
5.7 Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
5.8 Your comments and product reviews.
6. How and why do we use your personal data?
The data privacy law allows us to use your data 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.
Please remember that 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 is available for delivery, we can’t do that if you’ve withdrawn your general consent to hear from us.
6.1 How and why we’ll use your personal data:
(a) To carry out our business and to provide a service or carry out a contract with you For example:
To fulfil, process and deliver products and services you have ordered. We may share your personal information with a third party to supply or deliver the product or service (or part of it). If we don’t collect your personal data during this time, we won’t be able to process your order and comply with our legal obligations.
We may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
Process payments. We do not store any payment card numbers once the transaction has been completed. We share your personal information with credit card companies and other payment providers.
To process your booking/appointment requests (for example with an electrician for cooker installation). 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.
Contact you with important information relating to your booking or purchase, such as confirming your order, letting you know about returns and refunds.
(b) To respond to your queries, refund requests and complaints. Handling the information you sent 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.
(c) To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our stores and car parks which record images for security. We do this on the basis of our legitimate business interests.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
(d) With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, 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.
(e) 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.
(f) To comply with our contractual or legal obligations to share data with law enforcement.
(g) 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 in your online account.
We do not knowingly collect Personal Data from children under the age of sixteen (16).
If you are under the age of sixteen (16), please do not submit any Personal Data through our Services.
7. How we protect your personal data?
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We do not sell your personal information for any purpose.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
Improper use or disclosure,
Unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
We know how much data security matters to all our customers. With this in mind we will treat your data with care and take all appropriate steps to protect it.
8. 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.
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 electrical items, we’ll keep the data for ten years.
If your order included a warranty, the associated personal data will be kept at least until the end of the warranty period. Thereafter different retention periods will apply.
When you give us a donation of any item, we’ll keep the personal data you give us for six years.
9. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties. For example:
Technicians and contractors visiting your home,
To handle complaints,
To help us personalise our offers to you.
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.
Have a public commitment to the principles and practices of GDPR.
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, installers and carpet fitters etc.
Sharing your data with third parties for their own purposes:
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.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
To help personalise your journey through our organisation we currently use the following types of companies, who will process your personal data as part of their contracts with us:
Search engine and email handling,
Online auction and sales sites.
Sharing your information
We use third party platforms to manage and deliver customer relationship management (CRM); email marketing campaigns; online advertising, customer analytics, events; booking of appointments, fulfilment of orders, delivery, returns, refunds, IT services; etc. In providing the services, your personal information will, where applicable, be used by the service provider on our behalf.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal information. We will have written contracts with them which provide assurances regarding the protections that they will give to your personal information and their compliance with our data security standards and international transfer restrictions.
10. What are your rights over your personal data?
An overview of your different rights.
10.1 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.
Also, 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:
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.
If we choose not to action your request we will explain to you the reasons for our refusal.
10.2 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.
10.3 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.
10.4 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.
10.5 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.
11. 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.
Write to Admin and Systems Manger, Unit 12, Road Two, 1-5 Winsford Industrial Estate, Winsford, Cheshire, CW7 3QL
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
12. 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 (please note we can't be responsible for the content of external websites)