Introduction

Wool Room Limited (“we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

1. Important Information and Who We Are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process personal data from people who visit our website at www.thewoolroom.com, including any data you may provide through this website when you purchase a product and from people who get in touch with us for any reason, including by phone or email. It will inform you how we use your personal data, the conditions under which we may disclose your personal data to others, how we keep your personal data secure and sets out your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Wool Room Limited is the data controller and is responsible for your personal data. We gather and process your personal data in accordance with this privacy policy, and in compliance with the General Data Protection Regulation (“GDPR”) and other relevant data protection laws and regulations.

Contact details

If you have any questions about this privacy policy, our privacy practices or to exercise any of your legal rights, please contact us in the following ways:

Telephone: +44 01780 461217
Email: info@thewoolroom.com
Address: Wool Room Limited, 33-35 Pilings Road, Oakham, Rutland, LE15 6QF

If you'd like to be removed from our catalogue mailing list, we ask that you click this link and fill in the form. We will endeavour to remove you from our outreach database within 30 business days.
Changes to the privacy policy and your duty to inform us of changes


We keep our privacy policy under regular review. We may change this privacy policy from time to time by updating this page. 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 wish to review and/or update personal data we hold about you, please contact our data protection manager using the details above.

Third-party links

This privacy policy applies to this website only. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. You should read any policies and statements on every website you visit.

2. The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed.

The following table explains the types of personal data which we may collect, use, store and transfer. We will only use your personal data as the law allows us to. The categories of personal data which we use include:

• Identity and Contact Data such as names, titles and other identifiers together with address, email address and telephone numbers.
  
• Financial Data including information you may need to provide us with to make a payment. This may include credit/debit card information, and your bank account details.
  
• Technical Data including internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website and our products and services.
  
• Transaction Data including details about payments to and from you and other details of products you have purchased from us.
  
• Profile Data such as username and password details you use to log in to your account, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  
• Usage Data including information about how you use our website, products and services.
  
• Marketing and Communications Data which includes preferences in receiving marketing from us and your communication preferences.
  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect certain types of 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 and trade union membership). However, from time to time we may collect other data about you depending on why you have contacted us. For example, if you are enquiring about the Allergy Seal offered on some of our products, then we may ask for information in respect of your allergies or particular needs. If you contact us in your capacity as a representative of the organisation for which you work (rather than in a personal capacity) we may take your job title and role. We do not collect any information about criminal convictions.

If you fail to provide personal data

Where we need to collect personal data by law, under the terms of a contract we have with you or the organisation your represent, or for another lawful reason and you fail to provide that data when requested, it may restrict us from offering some or all of our services. It may also prevent us from properly dealing with a request or enquiry you have made, or we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel a product you have with us but we will notify you if this is the case at the time.

3. How is Your Personal Data Collected?

Personal data is collected in a number of ways. We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• provide your phone number to receive marketing messages or basket reminders via SMS;

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Necessary to comply with a legal obligation.
  

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

In addition to email, we may also send marketing communications by SMS, provided you have given us your consent to do so. These messages may include exclusive offers, personalised product recommendations, and abandoned cart reminders. You can opt out of SMS marketing at any time by replying “STOP” to any message received or by contacting us directly using the details set out in this policy.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Woolroom Cookie Policy here.

Our website uses cookies and similar technologies to monitor basket activity and determine when to send SMS cart reminders, where you have consented to receive these messages.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of Your Personal Data.

We may contact you via email to invite you to review any products you received from us in order to collect your feedback and improve our service and products. We use an external company, Trustpilot A/S (“Trustpilot”), to collect your feedback which means that we will share your name, email address and order number with Trustpilot for this purpose. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you sign up to receive SMS marketing, we may share your phone number and relevant browsing or purchase behaviour with our SMS platform provider (Klaviyo) to deliver personalised messages. These providers act on our instructions and are not permitted to use your data for any other purpose.

6. International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “your legal rights” below for further information.

9. Data Sharing

We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. Retailers share information about their customers and what they buy. Epsilon Abacus processes this information as a processor on behalf of the retailers to help them understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending individuals suitable offers that should be of interest to them, based on what they like to buy. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  
• Object to processing of your personal data where we are relying on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it, to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  
• Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products to you. We will advise you if this is the case at the time you withdraw your consent.
  

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.br/>

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Lodging a Complaint

We will only process your personal data in compliance with this privacy policy and all relevant laws and regulations. If you have cause for concern or are unhappy in any way, however, you may lodge a complaint with us using the contact details set out above.
You also 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.

Step-by-step complaints procedure

If you’re not completely happy with our service we’d like to hear about it so we can do something to put it right.

We do everything we can to make sure our customers get the best products and service possible, however, sometimes we understand that we may not get things right. If this happens, please let us know.

We want to:

• make it easy for you to tell us what went wrong;
• give your complaint the attention it deserves;
• resolve your complaint without delay; and
• Provide you with the right outcome to your complaint

How & where to complain

If you are not satisfied with any aspect of our service or products you can tell us in the following ways:

In writing
Write to us at Unit 33-35 Pillings Road, Oakham, Rutland, LE15 6QF and address your letter to Customer Service Team Leader.

By telephone
Call us on 01780 461217 during our office hours and ask for the Customer Services Department.

By email
Using the email address info@thewoolroom.com

To ensure a swift resolution to your complaint, we'd need you to include a brief description of the nature of your complaint, your name, address, order number and any relevant images where feasible.

How long will it take?
We always aim to resolve complaints in a timely manner and to the satisfaction of all concerned.

Please see timeframes below:

• Within 3 working days, you’ll receive an acknowledgement of your complaint via email, or phone call.
• We aim to resolve all complaints within a 7-10 working day period
• Where this isn’t possible, we’ll issue the complainant with a 4 week holding letter advising why we are not in a position to resolve the complaint.
• All complaints received and resolved will be recorded so we are able to identify trends and make the necessary business changes to improve the services to our customers and prevent repeat occurrences.

Please note:

• If a 3rd party is solely responsible for the complaint or the reasons for the complaint, we will refer the complaint to them within 5 business days and write to the customer to make them aware of this.
• If a 3rd party is jointly responsible for the complaint with us, we will refer the complaint to them within 5 business days, write to the customer to make them aware of this, and then investigate and handle the complaint points relating to us as per our normal process.
  

If we cannot resolve your complaint
If we are unable to resolve your complaint within 8 weeks, we will:

• Send you a letter explaining our reasons for the delay and an indication of when we expect to provide our final response

The purpose of this policy is to ensure that the operations of Woolroom Limited do not have any negative impact upon our vulnerable customers.

For the purposes of this policy, vulnerable customers could mean existing customers as well as prospective customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way.

What is a vulnerable customer?

The Financial Conduct Authority (FCA) defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

The FCA expects firms like Woolroom to treat customers fairly when we are dealing with people with vulnerable circumstances.

Identifying a vulnerable customer

Our staff are aware of the need to identify vulnerable customers so we can take extra steps to assist outside of our standard procedures and receive annual training on this. However, it is not always possible to recognise these characteristics. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your particular needs.

Vulnerability groups

We recognise that certain groups of customers may be vulnerable. Whilst not all customers in these groups may be vulnerable, we will consider a customer’s individual circumstances where a potential vulnerability is identified. These groups may include, but are not restricted to:

• Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia)
• A customer with a reduction in physical or mental capacity
  Customer with health issues - illness, whether physical or mental illness, severe or long term
• A sudden diagnosis of serious illness to the customer or close family member
• Personal circumstances of the customer – factors such as financial difficulties, bereavement, caring responsibilities or redundancy
  

Our key principles when engaging with a vulnerable customer

As soon we think we may be engaging with a vulnerable customer, whether this is through our identification process or you are approaching us, we will:

• Immediately make a record of this and ensure we adhere to this policy
• Provide additional opportunities for you to ask questions about the information we have provided
• Continuously seek confirmation that you have understood the information that has been provided
• Ask if there is anybody with you who is able to assist. If not, and we believe this will be beneficial, we will make arrangements to continue with the subject matter at another time.
• Offer you the opportunity to complete the transaction after a period of further consideration

If we can’t help a customer, we will try and make sure that they understand what alternative options are available to them.

To register as a vulnerable customer:

Email – info@thewoolroom.com
Phone – 01780 461 217
In Writing – Woolroom, Unit 33-35 Pillings Road, Oakham, Rutland, LE15 6QF

Effective Date: June 5, 2020

The social media pages of Woolroom Ltd (the “Company”), include but may not be limited to Facebook, Twitter, Pinterest, Instagram, and YouTube (collectively "Social Media").

Social Media is used by the Company and its customers use to communicate on topics related to our products and customer service. While the Company values an open exchange of ideas, it does maintain a few “rules of the road” to make sure that it is able to assist people with questions and issues related to its products quickly and efficiently. Social Media is delivered to you in accordance with Woolroom's Website Terms of Use (the “Terms”) and the terms of use of each of the Social Media operators.

Any information, pictures, creative works, ideas, testimonials, suggestions, concepts, methods, systems, designs, plans, techniques or other materials submitted that you send to us or post on or through Social Media ("Submitted Materials") shall be deemed not to be confidential or secret, and may be used by us in any manner consistent with the Terms and the terms of use of each of the Social Media operators.

By submitting or sending Submitted Materials to us or posting it on or through the Social Media, you represent and warrant that the Submitted Materials are original to you, that no other party has any rights thereto, and that any "moral rights" in Submitted Materials have been waived. We are not responsible for maintaining any Submitted Material that you provide to us, and we may delete or destroy any such Submitted Material at any time and for any reason and without advance notice to you.

By submitting or sending Submitted Materials to us or posting it on or through Social Media, you grant us and our subsidiaries and affiliates a royalty-free, unrestricted, worldwide, perpetual, irrevocable, non-exclusive and fully transferable, assignable and sublicensable right and license to use, copy, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform, display and incorporate in other works any Submitted Materials (in whole or part) in any form, media, or technology now known or later developed, including for promotional and/or commercial purposes. You agree that we may use, or permit others to use, without charge, your name, biography, picture and likeness with the content you submit and otherwise in materials promoting, marketing or advertising the Services, or Social Media, or our goods or services, in any media, without any compensation or advance notice to you.

We reserve the right, but do not have an obligation, to monitor and review all materials posted by you to Social Media. We are not responsible for the content of any materials posted by users. We reserve the right to edit, refuse to post, remove any content you post, or block any social media account, for any reason, at any time and without advance notice to you. Our reasons for removing or refusing to post content include, that such content is objectionable to us in our sole discretion, that it violates the Terms, or that it violates any applicable law, ordinance or regulation. We may also limit your access to all or certain portions of Social Media without notice to you for any reason.

By accessing and/or using Social Media, you agree not to do the following:

(a) use, copy, sell, post, display, print, publish, reproduce, distribute, transmit, modify, perform, broadcast, re-broadcast, translate, sell, adapt or otherwise create derivative works or improvements, whether or not patentable, of the Company, or any part thereof, except as expressly permitted by the Terms for your own personal, non-commercial, non-promotional use;

(b) use Social Media in a manner that: (i) violates any law, statute, ordinance, or regulation; (ii) violates, exploits, or harms, or attempts to violate, exploit, or harm, the legal rights (including the patent, trademark, copyright, privacy, or publicity rights) of any person or third party; (iii) promotes any illegal, commercial, advertising, or political activity, or advocates, promotes, or assists any unlawful, commercial, advertising, or political act; (iv) causes annoyance, inconvenience or needless anxiety or be likely to upset, embarrass, alarm or annoy any person or third party; (v) defames, abuses, threatens, stalks, harasses, intimidates, or harms any person or third party, or discloses personal information; (vi) tracks any person or third party without their explicit consent; or (vii) could give rise to any civil or criminal liability under any applicable local, state, national or international laws, statutes, ordinances, rules, regulations or ethical codes governing your jurisdiction, including confidentiality, data protection, and intellectual property laws;

(c) edit, remove, delete, alter, change or obscure any trademarks or any copyright, trademark, patent, or other intellectual property or proprietary rights notices, including any copy thereof;

(d) remove, disable, circumvent, or otherwise create or implement any workaround to any copy protection, rights management, or security features;

(e) impair the or interfere with any other party’s use of Social Media.

The Company shall, in its discretion, cooperate with any law enforcement authorities or court order requesting or directing the Company to disclose the identity of anyone violating these restrictions.

The Company welcomes your questions or comments regarding this Social Media Policy. Please contact us at the following email: info@thewoolroom.com, or at the following address:

Woolroom Ltd
33-35 Pillings Road
Oakham
Rutland
United Kingdom
LE15 6QF