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Privacy

Privacy & Cookie Policy

 

Brora Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, Brora.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

 

1.Definitions and Interpretation

In this Policy, the following terms shall have the following meanings: 

 

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and EU Regulation 2016/679 the General Data Protection Regulation(“GDPR”); and

“We/Us/Our”

means Brora Ltd, a limited company registered in England under company number 04166713, whose registered address is at Unit 5&6 The Orbital Centre, Cockerell Close, Gunnels Wood Road, Stevenage, SG1 2NB

 

2.Information About Us

2.1-Our Site is Brora.co.uk operated by Brora Ltd , a limited company registered in England under company number 04166713, whose registered address is Unit 5&6 The Orbital Centre, Cockerell Close, Gunnels Wood Road, Stevenage, SG1 2NB and whose main trading address is.

2.2-Our VAT number is 625 9113 44.

2.3-Our Data Protection Officer is Mark Taylor, and can be contacted by email at dataprotectionofficer@brora.co.uk, or Alternatively, you can contact our customer service team by calling 03456 599 944 (+44 3456 599 944 from overseas), Monday to Friday: 9am-5:30pm as well as by using our online section: https://www.brora.co.uk/contact-us.

 

3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

4.Your Rights

4.1-As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:

4.1.1-The right to be informed about our collection and use of personal data;

4.1.2-The right of access to the personal data we hold about you (see section 12);

4.1.3-The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4-The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact Us using the details in section 14);

4.1.5-The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6-The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7-The right to object to us using your personal data for particular purposes; and

4.1.8-Rights with respect to automated decision making and profiling.

4.20-If you have any cause for complaint about Our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you.

 

5.What Data Do We Collect and How Do We Collect Your Personal Information

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see section 13 on our use of Cookies policy and similar technologies

5.1-Title

5.2-Forename

5.3-Surname

5.4-Address

5.5-Email

5.6-Telephone number

5.7-Transactions you make from Brora (whether in-store or via the website)

5.8-Details of your shopping preferences, such as which stores you prefer to shop in

5.9-Details of your visits to the website

5.10-Details of when you contact Brora by email, post or telephone. Please note that we may keep a record of that correspondence

5.11-Any other information from which we can identify you (or which is available on public registers)

We may collect your personal information through some of the following ways:

5.12-When you register or use Brora.co.uk (the “website”)

5.13-When you are registered on the CRM system

5.14-When you contact us by telephone or email

5.15-When you enter any prize draws or competitions run by Brora

5.16-When completing any for forms for transactional purposes

 

6.How Do We Use Your Data?

6.1-All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the General Data Protection Regulation. For more details on security see section 7, below.

6.2-We will treat all your personal information as private and confidential.

6.3-Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

6.3.1-Process any orders that you make via the website, in-store (please note that your details may need to be passed to a third party in order for them to supply or deliver the product or service that you ordered and we may retain your details for a reasonable period of time after you have completed the transaction in order to fulfil any contractual obligations such as refunds, guarantees etc).

6.3.2-Process payments and prevent fraudulent transactions (we may retain your details for these purposes for a reasonable period of time and we may pass your details to a third party to carry out these functions)

6.3.3-With your consent, retain your personal information, preferences and details of your transactions in order to keep you informed by email, post, mobile messaging, telephone and through other digital means including social media platforms, about products and services (including special offers, discounts, promotions, events, competitions and so on) offered by Brora, as well as recommending those which we feel will be of particular interest to you. Please note that this may involve passing your details to carefully selected third parties who may inform you about their products or services which may be of interest to you.

6.3.4-Register you on the website or via one of our in-store services and where this involves setting you up with an account, we will use your personal information to maintain and update your account (eg such as a change of address or change in your marketing preferences)

6.3.5-Improve the content and appearance of the website, to ensure that the content is presented in the most effective manner for you.

6.3.6-Administer any prize draws or competitions run by Brora. Please refer to the specific terms and conditions for each prize draw or competition.

6.3.7-Carry out assessment and analysis (for example market, customer and product analysis) to enable us to review, develop and improve the products or services which we offer.

6.3.8-Comply with our legal obligations

6.3.9-Enforce or apply our terms and conditions and other agreements; or to protect the rights, property, of safety of Brora, our customers or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk protection. Your personal information may be disclosed to other businesses within the Brora group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985. As mentioned above, we may also disclose your personal information to carefully selected and monitored third parties who are engaged to help us run, manage and improve the quality of products and services that Brora offer, as well as for marketing and fraud and credit checking purposes. We require all the third parties that we interact with to treat your personal information as carefully and confidentially as we do.

6.4-With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email telephone, text message or post with information, news and offers on our products or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Act 1998, General Data Protection Regulation and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.5-We process personal information for certain legitimate business purposes, which include some or all of the following:

  • Where the processing enables us to enhance, modify, personalize or otherwise improve our services / communications for the benefit of our customers
  • To identify and prevent fraud
  • To enhance the security of our network and information systems
  • To better understand the how people interact with our websites
  • To provide postal communications which we think will be of interest to you
  • To determine the effectiveness of promotional campaigns and marketing

Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights

6.6-Third parties (including Hotjar, _utma, _utmz, Brora.co.uk share tools and Criteo) whose content appears on our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.7-You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.8-We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Please refer to the data retention policy for full details.

 

7.Where Do We Store Your Data?

7.1-We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

7.2-Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).]
 

8.Do We Share Your Data?

8.1-In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.

AND
 

8.1-We may share your data with other companies in our group. This includes our holding company and its subsidiaries.

8.2-We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.3-We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.4-In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

8.5-Our marketing preferences allow for non-third party sharing usage and preferences can be opted out at any time by contacting Brora

8.6-We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food and wine, gardening, gadgets and entertainment, health & beauty, household goods and interiors categories. They share information on what their customers buy. Epsilon Abacus analyses this pooled information to help the retailers understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.”

8.7-Epsilon Abacus may transfer data outside of the EEA. The transfer will take place in the presences of appropriate safeguards, including standard data protection clauses adopted by the EU Commission. Any communications from Epsilon Abacus is designed to tell you about the benefits we can offer so that you have exclusive access to our best deals. We use the information we have about you to tailor the content and try to ensure that the offers are as relevant to you as possible”

9.What Happens If Our Business Changes Hands?

9.1-We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

9.2-In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

 

10.How Can You Control Your Data?

10.1-In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).

10.2-You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

10.3-If at any point you no longer wish us to hold your personal information or you do not wish to receive information from us then there are a number of ways you can unsubscribe. These are as follows:

You can click onto “unsubscribe” link in any communication that we send to you by email which will automatically unsubscribe you from that type of communication. Each “unsubscribe” link only relates to that specific type of communication (eg marketing communications or survey communications). This means that unsubscribing from marketing communications will not automatically unsubscribe you from our survey communications (or visa versa).

Alternatively, you can contact our customer service team by calling 03456 599 944 (+44 3456 599 944 from overseas), Monday to Friday: 9am-5,30pm as well as by using our online section: https://www.brora.co.uk/contact-us.

In store, you can ask a team member to update your preferences (eg you can specify that you are happy for us to send you marketing emails, but not to receive direct mailings.

Please allow up to 30 days from the day that you unsubcribe for your details to be removed from our various paper mailings and emails.

Our preference options are as follows

“From time to time, we’d like to send you our latest catalogues, promotions and exclusive offers. If you would like to receive these updates, then please click this box. You can opt out at any time”

“Would you like to enjoy some of the latest products and offers by post from other trusted retailers. Please check this box to receive these.

 

11.Your Right to Withhold Information

11.1-You may restrict Our use of Cookies. For more information, see section 13

 

12.How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the General Data Protection Regulation, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact Us for more details at dataprotectionofficer@brora.co.uk or using the contact details below in section 14. 

 

13.Our Use of Cookies

13.1-Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2-By using our site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than us. Third party Cookies are used on our Site for personalised advertising. For more details, please refer to, section 13.5 below. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.

13.3-All Cookies used by and on our Site are used in accordance with current Cookie Law.

13.4-Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.

13.5-The following first party Cookies may be placed on your computer or device:

 

Name of Cookie

Purpose

Strictly Necessary

Hotjar

Hotjar provides session replays, advanced website heat maps, conversion funnels and form analytics to help us make our website more usable for you. The information collected is stored and used internally for our own statistical reporting. Please note that although Hotjar is recording your browser screen, it does not record or store your payment details or passwords.

No

_utma, _utmz

These cookies help us make the most of our investment on advertising. Google Analytics uses these cookies to discover when you first visited our site, how often you come back and how long you spend shopping. The information stored by these cookies can be seen only by the relevant teams at Brora and Google and never shows any confidential information.

No

Brora.co.uk share tools

We know you love to share great content we have on Brora.co.uk. Please be aware that social networking sites, like Facebook and Twitter, might send cookies. We don’t control the setting of these third party cookies, so we suggest you check third party websites for more information about their cookies and how to manage them. The business partners that may set cookies on Brora.co.uk include:

 

Criteo

This uses cookies to provide you with personalised adverts when you visit other selected websites. Banner advertising appears on websites with which we are affiliated and we use the information we have learned from cookies to tailor this advertising to thinks we think you will like, based on your browsing at Brora.co.uk

 

No

 

13.6-Our site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our Site and the products offered through it. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our site, making it a better and more useful experience for you.

13.7-The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

13.8-In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

13.9-You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

13.10-It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 

14.Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact us by email at dataprotectionofficer@brora.co.uk, by telephone on 03456 599 944, or by post at Unit 5&6 The Orbital Centre, Cockerell Close, Gunnels Wood Road, Stevenage, SG1 2N. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).

 

15.Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). If any changes are made to the Privacy Policy, we will contact you via a service email or alternative communication method to inform the data subject of the changes to be made and the impact on the data subject. No changes will be made within 30 (thirty days) of the service email that has been sent to ensure that the data subject has adequate time to review the policy and impact on personal data.

 

16.Compliance with the EU-US Privacy Shield

We comply with the EU-US Privacy Shield framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union to the United States. Brora has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Programme, and to view our certification, please visit https://www.privacyshield,gov/

In compliance with the Privacy Shield Principles, Brora commits to resolve complaints about our collection or use of your personal information. EU individuals with complaints regarding our Privacy Shield policy should first contact the dataprotectionofficer@brora.co.uk

Brora commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to Human Resources and non-Human Resources data transferred from the EU.

Under the compliance with the EU-US Privacy Shield, Brora is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)