Badulino.com  (“Badulino”) are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018, once enacted. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised shopping experience.

We have published this notice to help you understand how and why Badulino.com collect information from you; who we share your information with, why and on what basis; and what your rights are.

If we make changes to this notice we will notify you by updating it on our website. Badulino.com will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Badulino.com determines the purposes and way in which any personal data are, or will be, processed.

Should you need to contact us please write via email to [email protected] for quoting Security and Privacy Enquirys.

 

What information we collect when you register and why?

When you buy goods from us, you are entering into a contract with us. You will need to set up a Badulino.com Account before ordering from us, so we can set this up we will ask you to provide some personal information such as:

  1. Full name
  2. Address (and previous addresses)
  3. Date of birth
  4. Contact numbers
  5. Email address

As an existing customer if you have shopped with us using a credit or debit card, or we have taken these details for a payment authorisation, we will securely collect and store this payment card information. New customers and existing customers whose payment cards have expired will be asked if they would like to automatically store these details in order to speed up the payment process. If you set up a direct debit payment, we will also collect bank details from you.

When you apply for a credit account, we get information about you from credit reference agencies. This is covered in more detail in the section, Who we share your information with and why.

In order to undertake website personalisation, we will also gather information about the devices you use to access our sites (desktop and mobile), and this may include IP address. For further information on our use of cookies and tracking please see our Cookie Notice.

When you shop in our stores Badulino.com uses CCTV for security monitoring purposes.

 

How do we use your information?

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:

  1. Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. in order to send you your Directory catalogue.
  2. Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
  3. Legitimate Interests – this means the interests of Badulino.com in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Party’s such as delivery partners.
  4. Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

 

Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.

  1. What We Use Your Personal Information For Our Reasons (Legal Basis) Our Explanation Of Badulino.com’s 
  2. Set up your Badulino.com account • Legitimate interest Process efficiency in dealing with such activity.
  3. Storing payment cards • Consent N/A
  4. Process your orders • Fulfilling a contract N/A
  5. Notify you of your order status. • Legitimate interests Process efficiency in dealing with such activity, and to make improvements to our services.
  6. Manage your account/ provide customer services to you. This may include: transfers to Third Countries who undertake customer services/communications activities call recording data verification customer complaints/queries • Legal obligation/ Legitimate interests (depending on nature of services) Keeping our records up to date, handling our customer contact efficiently and effectively, working out which of our products and services may interest you and telling you about them.
  7. To detect, investigate and report financial crime (e.g. Fraud) • Legal Obligation / legitimate interests Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators such as the FCA. Complying with any regulations that apply to us. Process efficiency in dealing with such activity, and to make service and process improvements.
  8. Undertake website personalisation and administration. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites. Defining types of customers for new products or services
  9. Marketing communications to inform you of special offers, promotions, new lines and Sales. Provide you with online advertising. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.
  10. Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.
  11. Contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research. • Legitimate interests Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.
  12. Maintaining network and data security • Legitimate interests To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.
  13. Logistics planning, demand forecasting, management information and research • Legitimate interests We use information about shopping habits, products bought and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges.

 

Who we share your information with and why

Badulino.com works with a number of trusted suppliers, agencies and businesses in order to provide you the high quality goods and services you expect from us such as delivery companies, credit reference agencies, fraud prevention agencies, product technicians visiting your home and market research companies amongst others.

 

Some examples of the categories of third parties with whom we share your data are:

  1. Supplier Partners -Badulino.com works with a number of trusted partners who supply products and services on our behalf. All partners are subject to thorough security checks, and will only hold the minimum amount of personal information needed in order to fulfil the orders you place or provide a service on our behalf.
  2. Delivery Partners – In order for you to receive your goods, Badulino.com works with a number of delivery partners. Again, we only pass limited information to them in order to ensure delivery of your items.
  3. IT Companies – Badulino.com works with business who support our website and other business systems.
  4. Marketing Companies – We work with marketing companies who help us manage our electronic communications with you or carry out surveys and product reviews on our behalf.
  5. Payment processing – Badulino.com works with trusted third party payment processing providers in order to securely take and manage payments.
  6. Credit Reference Agencies –  When you apply for credit with us we will make searches about you with credit reference agencies. We do this to make sure customers who apply for credit accounts are able to manage the level of credit offered and not committing fraud by providing false or inaccurate information.

In order to process your application we will supply your personal information to credit reference agencies (CRA’s) and they will give us information about you, such as your financial history. We do this to assess your creditworthiness and product suitability, check your identity, manage your account, trace, recover debts, and prevent criminal activity.

We will also continue to exchange information about you with the CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will be linked to the data of your spouse, any joint applicants or other financial associates.

 

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

  1. Experian Credit Reference Agency Information Notice
  2. CallCredit Credit Reference Agency Information Notice
  3. Equifax Credit Reference Agency Information Notice

We will use automated credit-scoring methods to assess your application and to confirm your identity. We will automatically check your credit history against our lending criteria and if you don’t meet our requirements you will be declined for credit. For more information see the CRAIN notices above. There is also an automated decision section below with further detail. Should you wish to object to the use of automated credit scoring, please contact the Data Protection Officer.

 

Debt recovery and fraud prevention services

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

We process your personal data on the basis that it is necessary in the public interest or in exercising official authority for us to prevent fraud and money laundering, and to verify identity, in order to protect ourselves and to comply with laws that apply to us.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

 

Automated Decisions

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision-making: if you want to know more please contact us using the details above.

 

Consequences of Processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

 

Data Transfers

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

 

Your Rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the contact details above. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.

 

Transfers to third countries

Some of the information you provide to us may be transferred outside the European Economic Area to countries such as India and the US. This is a transfer to a “third country”. 

Badulino.com also works with suppliers and partners who may make use of cloud and/or hosted technologies. We undertake data security due diligence on our partners and ensure that that these partners conform to appropriate accreditations.

Wherever transfers of data to third counties occurs Badulino.com will put in place an appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information. To find out more please contact us at [email protected]

 

Keeping in touch with you

We want to keep you up to date with information about new ranges, special offers and improvements to our website. When you set your account up, we will ask you if you want to receive this type of marketing information.

Badulino.com will not share your information with companies outside of Badulino.com Retail Ltd for their marketing purposes. Badulino.com Retail Ltd includes Badulino.com Stores, Badulino.com Directory and Badulino.com.

If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer via My Account online or the unsubscribe link within the email.

You may continue to receive mailings for a short period while your request is dealt with.

 

How long we keep your information

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:

the law requires us to hold your personal information for a longer period, or delete it sooner;

you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;

we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or

in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

 

What are your rights

You are entitled to request the following from Badulino.com, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk

  1. Right of access –to request access to your personal information and information about how we process it
  2. Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
  3. Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. 
  4. Right to restriction of processing – to restrict processing of your personal information
  5. Right to data portability – to electronically move, copy or transfer your personal information in a standard form
  6. Right to object – to object to processing of your personal information
  7. Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling

 

If you have any general questions about your rights or want to exercise your rights please contact [email protected]

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

 

 

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