Privacy & GDPR Policy

The Robert Price Group: Privacy Policy

• Robert Price (Builders’ Merchants) Ltd.
• Gower Timber Ltd.
• P. Davies & Sons Ltd.
• Tudors Building Supplies (Hereford) Ltd

          (together, the Robert Price Group)

The members of the Robert Price Group (“the Group”) respect your privacy and are committed to protecting your personal data in compliance with the UK General Data Protection Regulation and all relevant laws in respect of personal data and the protection of the rights of freedom of individuals, whose information members of the Group collect and process. This privacy policy informs you how members of the Group look after your personal data when you visit our websites and/or make purchases from us, including any data that you may provide when you sign up to our newsletters, purchase a product or service, ask for advice or a quotation, maintain an account with the Group, or take part in a competition. This privacy policy also tells you about your privacy rights and how the law protects you.

Our products and services are not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing 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.

The Group is made up of different legal entities, details of which are listed above. This privacy policy is issued on behalf of the members of the Group so when we mention “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data.

Changes to this privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [20th March 2023]. Historic versions can be obtained by contacting us.

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.

Information Collection and Use

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We have grouped together the types of information that we may process, collect, store and transfer as follows:

• Identity Data includes first name, maiden name, last name, title, job title, username or similar identifier, marital status, date of birth and gender.
• Contact Data includes billing address, residential address, period lived at the residential address, previous addresses, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Profile Data includes your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may 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 any 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, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, 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 or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

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:
  • place an order for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request product advice, a quotation, or marketing information to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

• 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 (below) for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    (a) analytics providers [such as Google based outside the UK];
    (b) advertising networks [such as Meta based outside the UK]; and
    (c) search information providers [such as Glenigan Construction Leads based inside the UK].
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as Sage based inside the UK].
  • Identity and Contact Data from:
    (a) credit reference and fraud prevention agencies [such as Creditsafe based inside of the UK];
    and
    (b) publicly available sources [such as Companies House, the Electoral Register and Council Planning Permission & Application websites based inside the UK].

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 a contract we are about to enter into or have entered into with you.
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

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 would like to send you information about the Group’s products, services and special offers which you may find interesting. 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, services 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 or services from us and you have not opted out of receiving that marketing. We sometimes ask our customers to take part in market research.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

To stop us contacting you for marketing, you may withdraw your consent at any time by contacting us using one of the methods given at the end of this privacy policy. 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/service purchase, warranty registration, product/service experience or other transactions.

Security

We work hard to keep your data safe and to prevent loss or unauthorised access, use or disclosure. We use an appropriate combination of physical, technical, electronic, and organisational measures and procedures to ensure, as far as reasonably possible, the confidentiality integrity and availability of your information at all times. 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. If you have a security related concern, please contact us using one of the methods given below.

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.

Website cookies and links

Our website uses cookies, which do not store any personal information. By analysing web traffic and activity, cookies allow web applications to respond to you as an individual. We use traffic log cookies to identify which of our web pages are being used. This helps us improve our website and tailor it to our customers’ needs. We only use this information for statistical analysis. A cookie does not give us access to your computer, smart phone or web-enabled device to obtain information about you other than the data you choose to share with us. You have the right to accept or decline the use of cookies when browsing our website.

Our website may contain links to other websites which are not under our control, and which are not governed by our privacy policy. If you use these links to leave our site, we are not responsible for the protection and privacy of any information you may provide while visiting other sites. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Information that we share with third parties

We may disclose your information to third parties in certain circumstances:

• where it is necessary, for legitimate business reasons, including processing and managing your account, enquiry or order and fulfilling our contractual obligations to you;
• where we are under a legal, regulatory or professional obligation to do so;
• where the third party is an IT provider who supports us in hosting, transferring, processing, testing and problem solving;
• where the third party is an audit company providing expertise and assurance over our processes and controls;
• where we disclose information to a successor if we merge, re-organise or transfer all or part of our business.

Before sharing personal information with third parties, they will be required to agree to comply with our privacy policy and to obligations no less onerous than those to which the Group is committed.

The third parties to whom we may disclose your information are:

• Internal Third Parties: other companies in the Group, who are based in the UK and where it may be more efficient for another company in our Group to provide a required service [such as our specialist Group companies, where they are better placed to provide a product or service to match your enquiry or order.]
• External Third Parties;
  • Service providers based in the UK who provide delivery services;
  • Manufacturers based in the UK who provide order fulfillment and direct delivery services;
  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances; and
  • Marketing agencies based in the UK and the US
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

Transferring your information outside the United Kingdom (UK)

In order to provide our services, the information you give us may be transferred to countries outside the UK. These countries may not have similar data protection laws to the UK. When we do transfer your personal data outside of the UK, we will ensure that any party with access to our information has implemented the necessary security and privacy measures so that your personal data is kept as secure and confidential as outlined in this Policy.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we will use appropriate safeguards such as binding corporate rules, standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism to ensure personal data is given the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data Retention

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 individual rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Individual Rights

Under certain circumstances you have a number of rights with regard to the personal information that we hold about you:

• Right of Access – You have the right to request a copy of the information that we hold about you. We will usually provide you with this information within one month of receiving your request and verifying your identity. If the request is complex, we may extend the response time. We will inform you if this is the case and explain why.
• Right to Rectification – We want to make sure that your personal information is accurate and up to date. You may ask us to correct, update or remove information you think is inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us.
• Right to Erasure – You may also ask us to erase your personal information from our systems, in certain circumstances where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data 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 local law. There are some specific circumstances where the right to erasure does not apply and we are permitted to hold your data. We will explain the reason for this at the time, should this occur.
• Right to Restricting Processing – You have a right to request that we suspend the processing of your personal data in certain circumstances. These are 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; you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. We will inform our third parties to whom we have disclosed your personal data that they must also suspend processing. We will inform you when the suspension on processing your personal data ends.
• Request the Transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, 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 or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to exercise these rights, please write to us outlining your specific request, using one of the methods given below.

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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

How to contact us

If you have any questions about this privacy policy or our privacy practices, your request should be made in writing and sent either to our head office address: Robert Price (Builders Merchants) Ltd., Park Road, Abergavenny, NP7 5PF, marked for the attention of the Directors, or by email to: contactdatabase@robert-price.co.uk There is normally no charge for a subject access request.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

W A Godfrey
Managing Director

20th March 2023