What are ‘cookies’?
Cookies are small pieces of information, which online services provide when users visit them. Software on the user's device (for example a web browser) can store cookies and send them back to the website next time they visit.
By making a purchase of products or services from dwell, or by providing your contact details to us in our showrooms, by visiting dwell.co.uk, by registering an account, placing an order or by communicating with dwell online or by phone, you are accepting and consenting to the practices described in this policy.
When we say ‘we’, ‘our’, ‘us’ or ‘dwell’ in this policy we are referring to Coin Furniture Limited.
For the purpose of the General Data Protection Regulation (EU 2016/679), the data controller is Coin Furniture Limited. 1 Rockingham Way Redhouse Interchange, Adwick-Le-Street, Doncaster, England, DN6 7NA. Registered number 08586227 (England and Wales).
What information does dwell collect?
When you place an order with dwell in one of our showrooms, via our order-line or on our website, the information that we collect and store relating to you is primarily used to enable us to provide our products and services to you. This is to ensure that we can carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information, products and services that you request from us.
As we use third parties for all our delivery services, such as Wincanton, Royal Mail or other providers, your name, address and contact details may also be shared with them to ensure that we can fulfil our contractual arrangement with you to deliver the products and services you purchase from us.
dwell hold this information for a period of 10 years. After this period we will permanently archive any inactive customer accounts. Should you request us to, we will anonymise your information, removing all identifiers i.e. names and addresses connected to any transactions you have made with us.
If you choose to contact us using the chat function enabled on our website, this is supported by a selected third-party provider who will store details of the chat securely on their own servers for 12 weeks.
If you request a service or a repair from us, this will be completed by a third party, at which point we will share your name and address details with them. They will only use this information for providing you with the repair service.
DFS will give access to it's customer database to dwell, a DFS Group Company, to allow them to support DFS with providing a repair service in the event there is an issue with your purchase. They will only use your personal information to provide you with the repair service.
If you provide information to us about any person other than yourself, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us to use it for the purposes discussed with you e.g. to arrange for delivery of the furniture.
If you choose to communicate with us by phone, this information will be stored for our records and will be retained securely for 26 weeks.
If you use our website to register an account, participate in discussion boards, enter a competition or giveaway, complete a survey, request a call back from customer services or report a problem with our products and services, the information you provide to us will be stored and may be used to facilitate that request or service.
Finance applications: If you wish to enter into a finance agreement to purchase furniture, we will facilitate this for you by offering a direct link through to a finance provider who we have agreements with. We do not hold or have access to any information you supply to the finance provider. Those finance providers are third-party data controllers and are therefore responsible for any information that you provide to them. dwell enable you to set up a direct relationship with these providers. The third-party finance providers may, for example, ask credit reference agencies about you, keep records to help them decide whether to grant credit and to provide you with finance.
Once the finance company have accepted your application for finance, dwell only keep records in relation to which finance provider you have entered into an arrangement with in order to finance your purchase with us, as well as the loan terms and the value of the finance requested. If the first provider approached decides not to offer you a finance agreement, we will pass your information to alternative providers who may carry out their own credit searches. Credit is provided by Creation Consumer Finance Limited. Registered Office: 4th-6th Floor Wellington Buildings, 2-4 Wellington Street, Belfast BT1 6HT. Registration Northern Ireland NI032565. Authorised and regulated by the Financial Conduct Authority.
Information dwell receives from other sources
We may also collect information about you from other sources and combine such information with information we hold about you, including where:
- We communicate with members of your family or your household in relation to the provision of our services or products (for example, to arrange for delivery).
- Our trusted partners have collected information about you and you have consented for their disclosure to us. For example, you may have entered a competition with a third party and given your consent for your details to be shared with dwell for the purposes of entering a prize draw or receiving a product discount.
- Information is available about you publicly, or is aggregated or anonymised by a third party. For example, we may apply demographic analysis of your postcode such as average household size, and average income, and the general location.
- You provide information to us through your use or interaction with our social media channels.
Why do we collect information and how do we use it?
Under the GDPR we must have a lawful reason for using (or 'processing') your personal information. One of the lawful reasons is 'legitimate interests'. Legitimate interests means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests in doing so.
So, what does this mean? When you provide your personal details to us, we use your information for our legitimate business interests to ensure we can provide you with the best service possible and help us ensure you only receive relevant information from us.
Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.
Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our advertising.
We will process the personal information you have supplied to us to conduct and manage our business, which will enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider our legitimate interests.
The following are when and why we would use this approach:
If you have purchased from us from 18th August 2020, DFS and dwell, a DFS Group Company, will only send you marketing communications which relates to relevant promotions and offers that we feel will be of interest to you if you have actively consented to receiving it.
If you purchased from us prior to 18th August 2020 you will only receive marketing communications from DFS which relates to relevant promotions and offers that we feel will be of interest to you if you have actively consented to receiving it.
This information will be shared with partners, suppliers, and agencies so they can process your personal information on our behalf. We only share information that allows them to provide their services to us or to facilitate them providing their services to you. For example, some of our service providers place advertising for us online, about our products and services. As a result, where you have indicated you are happy to receive marketing from us, you might see online advertising that we have placed on the web sites you visit, or the interactive services you use.
We will continue to process your information in this way until you advise otherwise. You can opt out of this processing activity at any point using the unsubscribe link on all emails and included within SMS, and by using the contact us function on our website.
We will never sell your details to other companies so that they can market to you.
Add items to your basket: If you create an account on our websites and add items to your basket but the sale has not been completed, we may contact you by telephone or email to ensure that there were no technical issues that prevented you from completing your purchase. This information will be stored for 30 days before being deleted.
Customer service surveys: When you place an order with us, we will share your name and contact details with our chosen third-parties who will contact you on our behalf to conduct customer service surveys by email. These surveys allow us to review the customer experience and to provide a better service to you based on your feedback. The personal information we share with the third parties is deleted from their systems after 5 years. These surveys contain no promotional material or marketing messages, however, if you do not want to receive further surveys you can opt-out of them as you receive your first one. These third parties will store your email address if you choose to unsubscribe to ensure that they do not send you further surveys on our behalf.
Analytics: We process your personal information, collected as part of your furniture purchases for the purposes of customer analysis, assessment, profiling and direct marketing. This may be on a personalised or aggregated basis to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
This may include sharing information about you, collected as part of a purchase, with any of our group companies including DFS, Sofa Workshop and Sofology. dwell use selected third parties to do this. Where your personal information is disclosed to any of our service providers for these purposes, they will only have access to the information needed to perform the functions, and our contractual agreements with them do not permit them to use your personal information for their own purposes.
Call recording: Any phone calls you receive from, or make to dwell Customer Care team may be recorded. This is for training and quality purposes to allow us to ensure a high level of customer service is achieved. We may also record your details of the phone number you use to contact us. This phone number will be deleted after 26 weeks.
Protecting you: We process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
Using our websites or apps: During each of your visits to our website we may automatically collect the following information from you:
- Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet, your dwell account login information, browser type and version, time zone setting, the country and telephone area code where your device is located, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our websites (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from a page, and any phone number you dial to contact our sales or Customer Care departments.
This information will be used to administer our websites and phone services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. It allows us to improve our websites and phone services to ensure that information is provided in the most effective manner for you (and for your device). It allows you to participate in the interactive features of our service if you choose to do so. It will also allow us to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
We may combine the information you give to us with information that we collect from third parties about you. We use this information for the purposes set out above.
The personal information collected in this way is held on file for as long as necessary to provide the products and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will 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).
How do we store your data?
Any personal data that is provided to us is stored on our secure servers. Any download of information relating to any transactions entered into on our site will be encrypted to help ensure its safety. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share passwords with anyone.
dwell will only retain personal data for as long as is necessary to provide the products and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations. If you have any questions relating to our retention or destruction of your data, please contact us.
In accordance with the General Data Protection Regulations (EU 2016/679), we employ strict physical, electronic and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line. The transmission of information via the internet is, however, not secure (e.g. email) and therefore we cannot guarantee the security of data sent to us electronically by you. Any transmission of such data is therefore entirely at your own risk. Where we send data to third parties via the internet (e.g. emails) for the processing of a service, all of the data is sent securely and password protected. If you have any questions relating to the security of your data, please contact us.
You should be aware that if we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information, we may be obliged to do so.
Where we sell part or all of our business to a third party, we may disclose your personal data to the prospective or actual seller or buyer of such business or assets.
Where we are legally required to disclose your information in order to enforce or apply our terms and conditions or other agreements; or to protect our rights, property, or safety or those of our customers or other third parties, we may be obliged to do so.
Microsites: We have partnered with various trusted third parties to provide services to you. Such services can be accessed through links on our website, email and text links to the third-party company’s microsite. A microsite is a website which is operated by a third-party company and may be dwell branded or not.
We are not responsible for their policies or the way they use your data or cookies, and we will not be liable for any loss, damage or distress you may suffer or incur as a consequence.
Access to information and other rights
The GDPR gives you the right to:
- Access information that we hold about you. If you wish to exercise your right of access, you must submit a written request and provide proof of your identity before we supply the information to you.
- Ask us to prevent processing that is causing, or is likely to cause you substantial damage or distress.
- Require us not to make certain decisions automatically if they significantly affect you.
- Ask us to make any necessary changes to the personal data we hold about you in order to ensure that it is accurate and up to date.
- Ask us to have your personal data erased and to prevent processing in specific circumstances outlined below:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When the individual withdraws consent.
- When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
- The personal data has to be erased in order to comply with a legal obligation.
We may refuse to comply with a request for erasure when personal data is processed for the following reasons:
- To exercise the right to freedom of expression and information.
- To comply with a legal obligation for the performance of a public interest task or exercise of official authority.
- For public health purposes in the public interest.
- Archiving purposes in the public interest, scientific research historical research or statistical purposes.
- The exercise or defence of legal claims.
Please contact us if you have questions regarding any of these matters.
If you have any questions or concerns with how dwell process your personal information, please do not hesitate to contact us via our website or by email on [email protected] If you are unhappy with how we are processing your personal information you have the right to refer the complaint to the regulator, the Information Commissioners Office. You can do this by visiting their website or contacting them at 0345 013 0515.