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Debenhams Privacy Policy

This Privacy Policy explains how we use any personal information you provide to Debenhams in the Republic of Ireland when you use our services in our Stores, our Websites, our Reward Club and any contact you have with our Customer Contact Centre.


"Debenhams/We" means Debenhams Retail (Ireland) Limited (as the operator of the Stores and Websites), Debenhams plc or other subsidiaries within the Debenhams plc group of companies as appropriate.


We respect your right to privacy and are committed to maintaining it. We only collect, store and process your personal information in accordance with the relevant laws and regulations.


By accessing, browsing or otherwise using the Websites you confirm that you have read and understood this Privacy Policy. Please ensure you have read it carefully, and particularly the section detailing your rights in relation to the personal information that we collect about you.


To help you navigate this policy we've split this up into the following sections:

What information we collect about you?

Personal information that we collect from you - this will depend upon the services you are using:

• Name and Title
• Home, Billing and Delivery Address(es)
• Email Address(es) (home, mobile, work - customer dependant)
• Phone Number(s) (home, mobile, work - customer dependant)
• Purchase information
• Payment card information
• Account Password and Login details
• Debenhams Reward Club Card number(s)
• Date of Birth
• Gender
• Social media account details
• Your comments, product reviews and responses on surveys you complete
• Appointment booking and information given during an appointment
• Any shopping preferences or details to help us suggest items for you
• Details of your interactions with our Customer Contact Centre
• Your images on CCTV
• Your car number plate if recorded to manage parking at our Stores
• IP Address
• Device information
• Website / Browsing History, including location data
• Cookie information (please see our Cookie Policy for details)


Personal Finance products

In addition to the above, we may also receive the following in connection with any purchase from our Personal Finance products range, depending on the type of product you purchase:

• Copies of documents you provide to prove your age or identity where required (for example, your passport and driver's licence or National ID Card (EU issued) for Travel Money ID checks). If you provide a passport, this will include your place of birth and nationality.
• For Travel Money we may also require proof of address where the transactions are over a certain amount. This can be a bank statement, recent household/utility bill or official letter.
• Proof of funds and evidence of what the funds are required for which we may request for Travel Money anti-money laundering purposes. This may include a bank withdrawal slip or account statement.


In some circumstances we may collect special category data such as details of medical conditions, nationality, racial or ethnic origin from you. Please section 5 for full details.


We collect personal information when you:

• Purchase products or services or buy or redeem vouchers through the Websites, including the mobile sites, over the phone, through store kiosks and/or store till points
• Register for My Account
• Register for Debenhams Reward Club Card
• Purchase Travel Money in store
• Sign up to receiving e-receipts
• Subscribe to our newsletters
• Submit reviews or choose to complete surveys we have sent you
• Engage with us via social media
• Register or use our in-store WIFI (in any of our stores)
• Enter our competitions, prize draws or promotions
• Use our customer services team or contact us for any reason, e.g. order queries, complaints, website issues via our web-chat facility, phone, email and postal correspondence
• Complete a form, such as for a transaction or employment purpose or for accident or incidents in stores or for other health and safety or security purposes
• Book an appointment with us, such as bra fit and personal shopper, or to attend an event we’ve organised
• Use our car parks and stores which usually have CCTV systems operated for the security of both customers and colleagues
• Browse the website - please see the section on cookies for more information


Personal information that we collect from Third Parties

We may collect personal information from third party databases (for example for our fraud checks) or as provided to us by other companies who have obtained your permission to share this information with us, or who need to share information with us in relation to goods and/or services you have purchased - such as our Microsite partners (see section 9 below).

If you link your Google, Facebook or Twitter accounts or any accounts from other third party services (like shopping research panels or public forums such as blogging sites) to Debenhams then we also receive information from those accounts to the extent you’ve agreed to this as part of your settings and that third party’s privacy policy.


Personal Information collected by other parties

Debenhams works with many third parties to provide goods and services, such as our store and food concessions and beauty brands. These companies may, from time to time, collect personal information directly from you to organise appointments or book their services, or for their own marketing and tracking purposes.

If they do collect your personal information in this way, these companies will be acting as Data Controllers in their own right, separately from Debenhams. Any use of your personal information will therefore be subject to that company’s own privacy policy which should be made available to you at the time that they collect your personal information.

Please also see our section on Microsites below for how we work with other partners to provide you additional goods and services.


Personal Information of Children

Debenhams does not knowingly solicit personal information from children or send them requests for personal information. Although visitors of all ages may navigate through our website, we do not intentionally collect personal information from those under the age of 16. If, following a notification by a parent or guardian, or discovery by other means, a child under 16 has been improperly registered on our site by using false information, we will cancel the child's account and delete the child's personal information from our records.


How we will use the information about you?

We use your personal information in a number of different ways, depending on the type of information provided. You do not have to provide this personal information but if you don’t, you may not be able to purchase goods from us, we may not be able to provide certain services and you are unlikely to receive our optimal overall customer experience.

The tables below set this out in detail, showing what we do, and why we do it:


In some circumstances we also need to provide your information to enable us to comply with legal or regulatory requirements, such as criminal or whistleblowing investigations. We will do this where Debenhams has a legal obligations to provide such personal information to the authorities and regulators to comply with the law.

We may also use publicly available information (such as from the electoral register) to ensure that our database is kept accurate and relevant. Debenhams has a legitimate interest to ensure our database is kept up to date.


Personal information shared with Third Parties

In order to provide our services to you, we share your data with the following categories of companies:

• Companies in the Debenhams group - all Debenhams companies within the group adhere to the same standards of data protection.
• Companies that help get your purchases to you, such as payment service providers, warehouses, order packers, and delivery companies or as part of the standard customer journey for the purposes of taking payment, managing your order, monitoring site performance and stability, improving customer experience, tracking revenue, delivery and returns.
• Concession and cosmetics partners who are responsible for delivering their products directly to you or providing services, such as makeovers, in our stores.
• Companies who help administer your account and handle any customer complaints and correspondence, such as our Customer Contact Centre.
• Companies who help us arrange any services you have asked for, such as appointment bookings for our personal shopper or bra fit services.
• Professional service providers, such as IT providers, marketing agencies, advertising partners and website hosts who help us run our business and deliver our marketing and advertising to you, including third party print companies for mailing purposes.
• Data insight companies and other business systems providers who ensure the information we hold is up to date and accurate.
• Credit reference agencies, law enforcement and fraud prevention agencies and payment card providers. All credit/debit card holders are subject to validation checks and authorisation by the card issuer and we may share your personal information with such third parties as are necessary to enable us to do such checks. The third parties may keep a record of the information provided.
• Companies approved by you, such as social media sites (if you choose to link your accounts to us), and PayPal where you choose to use their payment service.
• If we sell or buy any business or assets or transfer an area of the business to a new provider, we will disclose your personal data to the prospective seller or buyer of such business or assets or any third party who acquires our assets or who the business is transferred to.


Debenhams only transfers your personal information to those third parties where we can be sure that we can protect your privacy and your rights. We only transfer the information which is needed to provide the goods and services and if we stop using a third party, we require them to remove or anonymise your information. We have contracts in place with all of our business partners and audit them regularly to ensure data security. We do not, and will not, sell any of your personal data to any third party.


Security of your information

We want you to have confidence in how we use and hold your personal information. We have in place a range of organisational, procedural and technical security measures designed to protect your personal information from unauthorised use or disclosure, including password protection on My Account. We regularly conduct security assessments against our web platforms and applications in order to provide you with the necessary trust and protection you expect when interacting with Debenhams online services.

How long we will store your information?

We’ll hold on to your information for as long as you have your account with Debenhams, or as long as is needed for us to be able to provide the relevant goods or services to you. Debenhams’ general retention policy is to retain information for 6 years.

In some circumstances, such as to meet our legal or regulatory obligations, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may hold on to your personal information after we’ve finished providing services to you, or for longer than our general retention policy.

Your rights over your information

You have many rights over your personal information and how it is used. The table below sets out the rights which are available to you (depending on how we collected your personal data) and how to make use of those rights.

If you would like to make a request for any of the rights detailed below, please click here.

Please be aware that we will need to verify your identity before providing any personal data to you. We do this to protection your information. We may also ask you to provide us some additional voluntary information to help us process your request more efficiently.


Consent

Where Debenhams is using your personal information based on your express consent to this, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at DebenhamsGDPR@Debenhams.com

You can also update your consent settings for cookies on the website using your browser settings. Please see the section on cookies for more information.

Legitimate Interests

If Debenhams are relying on our legitimate interests to process your information, you have the right to object to us doing this in light of your individual circumstances. We will review this objection and, unless we consider that our legitimate interests override your rights, we will stop processing your information in this way. Please see the "Right to object to, or restrict, Debenhams using your information" in the table above.

Complain to the Regulator

If you believe that we have not handled your personal information correctly or are not happy with how we have dealt with your request, you have the right to lodge a complaint with your relevant regulatory authority. In the Republic of Ireland this is the Data Protection Commissioner (see: www.dataprotection.ie for details).

Special category data

Certain categories of personal information have additional protection under the GDPR. The categories include information about your health, racial or ethnic origin.

Debenhams processes special category data where this is provided by you during the course of correspondence with us to inform us of any delivery/assistance requirements or as part of a complaint or grievance procedure or in relation to an accident or incident which has occurred on our premises. Debenhams will process this information to provide you with the assistance you have requested or to deal with your complaint. Where you have asked us to provide assistance or special delivery instructions, we will do this on the basis of your consent to us using it in this way. Where we are processing this information in order to deal with a complaint, this processing will be necessary for the establishment, exercise or defence of legal claims made by or against us.

Special category data may also be required as part of your negotiations for a Personal Finance product, including Travel Money transactions. For Travel Money transactions, it is necessary for us to process this information for the purposes of preventing fraud and in order to comply with our legal obligations. For our other Personal Finance products (where applicable), our third party providers will process your special category data in accordance with their own privacy policies. Please see our Microsites section for further information.

Marketing

If you have given us your contact details, we may use these (in accordance with any preferences you have expressed) to send you marketing messages by email, post, phone and social media to keep you aware of what we’re up to and to help you see and find our products. This includes sending details of special offers, services (including our financial services) and promotions from Debenhams.

As part of running our business, Debenhams has a legitimate interest to promote our products using marketing messages to existing customers of Debenhams and/or those in a negotiation with us for a sale or service, unless you have asked us not to.

When we collect your personal data, we give you the opportunity to opt-out of receiving those marketing messages by simply ticking the box. We also have lots of other ways you can stop marketing messages in the future, which we've set out below.

If you are currently opted-out of our marketing, you can always choose to opt-in to receive our emails by ticking the box at checkout or by amending your My Account preferences.

If you are logged-in, then your current email marketing preferences (which you can find in your My Account) will be displayed at checkout. You can change these preferences in My Account or using the options detailed below at any time.


How to stop marketing messages from Debenhams

You can stop receiving marketing messages from us at any time.

For email marketing, the best way to do this is to click on the 'unsubscribe' link in any email you receive. You can also do this through your My Account settings on our websites.

You can opt out of other marketing as follows:

• For phone and direct mail - you can contact our Customer Contact Centre (see Contact Us section below)
• For targeted or personalised adverts - you can update your Cookie preferences at any time (see Cookie section below and our Cookie Policy for how to do this).


It might take some time for all our systems to be updated, so you might get messages from us while we fully process your request, but we will ensure that we mark you as having opted out on our database as soon as we receive your request.

We are working on improving our customer experience to allow you to opt-out easily of our communications and cookies and we will update this policy and our Cookies policy as soon as we have this in place.

Please be aware that stopping marketing messages will not stop our service communications (such as order updates).


Banner messages and personalised adverts on other websites

Like other retailers, we also target Debenhams banners and ads to you when you are on other websites, apps and social media. We do this using a range of advertising technologies such as ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook, Twitter and Pinterest.

The recommendations will be based on information we hold about you, or your previous use of our services (for example, your Debenhams search history, and the content you read on Debenhams) or on Debenhams banners or ads you have previously clicked on.

If you don't want to see these ads, then you can either disable cookies in your browser, or reject cookies from the site you’re visiting. Please see our Cookies Policy for further details.

Automated decision-making

Debenhams might make some decisions about you using your personal information which is based on profiling without our staff intervention (known as automated decision making).

You have the right not to be subject to a decision based solely on automated decision making which produces a legal or other similarly significant effect. However, this will not apply if the decision is necessary for a contract, authorised by law, or has your express consent.

In most cases, we use automated decision making in order for you to enter into a contract with us (such as automatic fraud screening), or in ways which won’t have a significant effect on you as an individual (such as our general analysis of data to gain insights into behaviours and characteristics of our customers).

We use profiling to tailor adverts for you, such as displaying Debenhams adverts based on your previous website interactions and purchase behaviours, how you access our services and where you access our services from. We do this to serve you ads that we believe you will be most interested in and prevent you from seeing ads that are unlikely to be of interest to you, or for products that aren’t available in your area. You can choose not to be profiled in this way by opting out of marketing and by updating your cookies preferences.


You can request a manual review of the accuracy of an automated decision if you are unhappy with it.

Cookies

Cookies are small encrypted text files that are stored on your device by a website. Our Websites use cookies to enable you to shop, enhance your shopping experience and to analyse our traffic.

For further information visit http://aboutcookies.org.uk/


Please note that we're not responsible for the content of external websites.


You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our Website features may not function as a result.


Our Cookie Policy is set out here

Other websites

Our Website contains links to other websites. This Privacy Policy only applies to the Debenhams Websites so when you link to another website, we advise you to read that website's privacy notice.


Microsites

We have partnered with various trusted third parties to provide goods and services to you. Such goods and services can be accessed through links on the Website to the third-party company's microsite. A microsite is a website which is operated by a third-party company but is Debenhams branded. These third parties may pass your personal information to Debenhams in order to provide the goods and services to you and, where you have agreed, for Debenhams to send you details of our promotions and products.

These microsites are governed by their own terms and conditions and privacy policies. When you apply for a product or service from one of our chosen providers by going to their microsite, your personal information will be collected and used by the provider under the terms of their privacy policy.

We receive information from certain microsite partners in connection with the products or services you have purchased from them. This includes information provided for your appointments with our Personal Shopper and Bra fit services, details of gift card purchases or promotions that we require to manage and fulfil these gift cards. We will process any information we receive from these microsite partners in accordance with our privacy policy.


Please see the list below for all our microsite partnerships:


Debenhams goods and services


Other sites


Transferring data internationally

In order to provide our goods and services we may need to transfer your information from your country of residence to another country in the usual course of our business. By dealing with us and submitting your personal information, you agree to the transfer, storage, and/or processing of your personal information outside of your country of residence as set out below.


International orders

If you are based outside the Republic of Ireland and place an order with us, then we will transfer the personal data that we collect from you to Debenhams in the Republic of Ireland.

Transferring outside of the EEA

We may transfer your personal information to a third party data processors located in countries outside of the European Economic Area ('EEA').

Debenhams only transfers your personal information to those third parties where we can be sure that we can protect your privacy and your rights, for example the third party is located in a country which the EU has deemed to have adequate data protection laws in place, where that third party is certified on the EU-US Privacy Shield (see https://www.privacyshield.gov) or where we have a contract in place with that third party which includes the European Commission’s standard data protection clauses.

Changes to our privacy policy

We may change this Privacy Policy from time to time, to reflect how we are processing your personal information. If we make significant changes, we will highlight the sections of the privacy policy that have been updated to allow you to review the changes.

This Privacy Policy was last updated on 31 August 2018.

How to contact us

Please feel free to contact us if you have any questions about our Privacy Policy or the personal information we hold about you.

You can contact us by:

Email:DebenhamsGDPR@Debenhams.com

Telephone:0818 784 877

Post:

Debenhams Customer Services - GDPR
54-62 Henry Street
Dublin 1

Or if you prefer you can contact our Data Protection Officer at: DPO@Debenhams.com


Debenhams Data Protection Officer
Debenhams Retail plc
10 Brock St,
Regents Place,
London
NW1 3FG


Unless we've said otherwise in this Privacy Policy, Debenhams will be the "data controller" of your personal information. We determine the means and purposes for processing your personal information.

Debenhams Retail (Ireland) Limited is a company registered in the Republic of Ireland (registration number 239481) with registered office at 54-62 Henry Street, Dublin 1