Bensons for Beds Retail Ltd takes its obligations with regard to data protection seriously. As such, we are providing this notice (“Privacy Notice”) to you so that you are provided with information about how Bensons for Beds Retail Ltd collects and uses your Personal Data in accordance with applicable data protection law, including the General Data Protection Regulation 2016/679 (“GDPR”),”), and any UK laws implementing or superseding the GDPR including (from the 1 January 2021) the UK GDPR. Please read this Privacy Notice, as it contains important information of which you should be aware.

For the purposes of this Privacy Notice, (“Bensons Customers”, “you” or “your”) means customers of Bensons for Beds Retail Ltd and “Bensons for Beds UK” (“we”, “us” or “our”) means Bensons for Beds Retail Ltd(a company incorporated in the UK with company registration number 12528962).

Bensons is controller of your Personal Data (as defined below). The controller is the entity that determines how and why Personal Data is processed.

In order for Bensons for Beds Retail Ltd to deliver its products and services to you and manage its business efficiently, it is necessary for us to collect, maintain and process Personal Data about you. “Personal Data” is information which (either on its own or in combination with other information Bensons for Beds Retail Ltd holds) allows Bensons for Beds Retail Ltd to identify a Bensons for Beds Retail LtdCustomer and thus enables us to manage our relationship with Bensons for Beds Retail LtdCustomers. We may collect information from you when you visit our website, visit one of our stores, purchase goods or services from us, contact us by telephone, email or post or receive a communication from us relation to your purchase.

The term “processing” means any action taken, also with the help of electronic means, in connection with Personal Data, including collection, handling, use, transfer and disclosure by transmission, dissemination or otherwise making available, as well as recording, organisation, storage, retention, adaptation or alteration, access, retrieval, consultation, alignment or combination, blocking, anonymising, erasure, disposal or destruction.

The Personal Data which we process may include the following (please see the table below for further information):

• Name and address
• Contact information (including telephone number and email address)
• Bank account and payment card details and billing address
• Details of any credit requested on any purchase(s)
• Age/Date of birth
• Gender
• Current and past purchases and orders made by you
• Your password(s) for our websites
• The details of your online account with us
• Your communication and marketing preferences
• Your interests, preferences, feedback and survey responses
• Your location
• The Personal Data contained in any other communication you make with us
• Your online browsing activities on Bensons for Beds Retail Ltd websites
• Delivery preferences and requirements

Personal Data will primarily be collected from you directly. However, some Personal Data may, where lawful to do so, be collected by Bensons for Beds Retail Ltdfrom third parties (e.g. from marketing agencies) or publicly available information about you. We will only accept and use information about you from reputable organisations who have either obtained your permission to share your information with us or who have collated information about you from publicly available sources.

Please note that you are under no obligation to provide Bensons with your Personal Data; however, when we rely on the lawful bases of complying with a legal obligation or entering into/performing a contract with you (see the table below), not providing some of the Personal Data described above could prevent Bensons from performing its obligations in relation to your purchase of goods and services (and any related services) from us and/or we may not be able to enter into or continue our contract of sale or engagement with you.

Personal Data – Legitimate Interests

The specific legitimate interests pursued and how this is balanced against your interests:

• To enable us to operate efficiently, and to ensure any issue you may have is dealt with effectively, efficiently, and fully.
• To manage customer accounts, including keeping general records of customers, sales, customer care, and other interactions. This will ensure you receive the best service possible.
• To provide you with updates and promotional offers about our goods and/or services, where you have not opted out of receiving such communications from us. In doing so, we can ensure that we are providing you with relevant details of our products and services where these are of interest to you. These offer benefits to you and will hopefully save you money on future purchases.
• To target our direct marketing to you. This is necessary to build a better picture of the type of offers and products we can provide which you might be interested in, so that the communications you receive are more relevant to you and are not merely generic communications. We believe this is justified as you are in control over whether you receive our direct marketing.
• To follow up on any uncompleted sales; in doing so we can deal with any outstanding queries and ensure that if you want to go ahead with the sale, the process to complete it is as smooth as possible.
• To protect ourselves from fraudulent transactions. This is necessary to protect genuine customers and our business from fraud to minimise the risk of false details being used, and abuse of card details by fraudsters.
• To improve the operation of our business and our marketing activity more generally, including to assess what is working and what is not in terms of our marketing activity or our sales performance, so that we can develop our websites, products, and offers to be more relevant to our customers generally, to improve your online experience and the products we offer. Where possible, we will use statistical or pseudonymised data for these purposes.
• To offer credit facilities to you – i.e., giving you the option of spreading the cost of your purchase.

We may convert your Personal Data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct research and analysis, including to produce statistical research and reports. We may share such anonymous aggregated data with third parties. Aggregated and anonymous information does not personally identify you and is therefore not Personal Data (and so not caught within the GDPR or its implementing UK laws).

Personal Data will be shared and transferred from us to other companies in our group for the purposes noted above (or for such other purposes as are notified by Bensons for Beds Retail Ltd to you from time to time).

In the course of its business, Bensons may disclose Personal Data to third parties that are performing services under contract for Bensons, such as I.T. hosting, marketing optimisation, maintenance providers, and organisations that we instruct to deliver the products you have purchased from us. Personal Data may also be disclosed (upon lawful request) to government authorities, law enforcement and regulatory authorities, courts, court-appointed persons/entities, and where required or permitted by relevant local law and for tax or other purposes. Further, Personal Data may be disclosed to third parties in response to legal process and when required to comply with laws, or to enforce Bensons’ agreements and corporate policies or to protect the rights, property or safety of Bensons, its employees, agents and third parties (including to legal advisors, other professional advisors and insurers). In addition, Bensons may disclose Personal Data to parties to whom the relevant Bensons Customer has authorised Bensons to release his Personal Data, such as when that Bensons Customer has participated in a competition or when Bensons is investigating any customer complaint made by that Bensons Customer which may, in both cases, require disclosure of Personal Data to Bensons’ PR company (amongst others). We will also share details of your purchase with PPL where you choose to obtain a credit facility for your purchase (PPL is our principal where we act as an agent in facilitating a credit facility for our customers).

We may share any of your Personal Data with a prospective purchaser or purchaser of any part of our business, on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition.

For the purposes described above (or for such other purposes as are notified by Bensons for Beds Retail Ltd to you from time time), your Personal Data may be transferred to, and stored, and otherwise processed in, one or more countries outside of the (“United Kingdom”). The jurisdiction of other organisations outside the UK may not have adequate data protection laws equivalent to those in place within the UK. For transfers of your Personal Data to third parties outside of the UK, we take additional steps where required in line with data protection laws. In some instances, we have implemented appropriate technical and organisational measures to protect your Personal Data in the form of EU Commission approved forms of contract with the relevant recipient(s) of your Personal Data. In addition, we will take reasonable steps to ensure that your Personal Data is adequately protected in accordance with the requirements of the UK data protection law. If you would like to obtain a copy of the EU Commission approved forms of contract, please contact us by using the details below.

Bensons may also, where permitted (and having obtained any necessary consents as may be required by law), disclose Personal Data outside of the UK for the purposes noted above in respect of Bensons, or:

where required as matter of law (for example, to tax and social security authorities); • where required to protect Bensons’ and/or other Bensons group companies’ legal rights (for example, to defend against litigation); and/or for such other purposes as are notified to you by Bensons for Beds Retail Ltd from time to time.

As stated above, Bensons takes the protection of your Personal Data seriously and we have implemented technical, physical and organisational measures to help us keep Personal Data (including Special Categories of Personal Data) accurate, up to date and protected against unauthorised or accidental destruction, alteration or disclosure, accidental loss, unauthorised access, misuse, unlawful processing and/or damage.

Bensons for Beds Retail Ltd will retain your Personal Data only for such period as is necessary to perform the purpose(s) for which it was collected. In many cases this means that Personal Data will be retained for the duration of the time that we provide goods and services to you and then for a reasonable time thereafter in order to manage any problems, process any returns, manage our relationship with you, defend any claims, for tax purposes and/or for any other record keeping purposes. This period is typically a period of not less than 6 years from the date of delivery of your last order with us.

You have certain legal rights, which are briefly summarised below, in relation to any Personal Data about you which we hold.

Where our processing of your Personal Data is necessary for our legitimate interests, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights, and freedoms, or that the processing is necessary for us to establish, exercise, or defend a legal claim.

If you would like to exercise any of your rights as described above (or if you have any questions about this Privacy Notice or concerns about our dealings with your Personal Data), please contact gdpr@bensonsforbeds.co.uk.

We will try to resolve any concerns you may have. However, if you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/).

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or of an alleged infringement of the GDPR.

Bensons may change this Privacy Notice from time to time in order to reflect changes in the law and/or its privacy practices. We encourage you to check this notice on a regular basis.

Policy last updated 5/12/2022