Privacy Policy

1 ABOUT THIS NOTICE

1.1 34 St John Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.

1.2 Data protection law says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely

1.3 If you have any questions about this notice or how we collect and use personal information about you please contact us.

2 INFORMATION ABOUT US

2.1 We are 34 St John Limited. Our registered office is at 12a Fleet Business Park, Sandy Lane, Fleet, England, GU52 8BF. Our registered company number is 14474879 (referred to “we”, “us”, “our” throughout this private notice).

2.2 If you have any questions, our contact details are:

2.2.1 34 St John Limited, 12a Fleet Business Park, Sandy Lane, Fleet, England, GU52 8BF

2.2.2 0330 221 34 34

2.2.3 dataprotection@34stjohn.com

3 DATA WE COLLECT ABOUT YOU

Personal Data

3.1 We will collect personal data about you.

3.2 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, which is anonymous data.

3.3 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a) Identity Data includes title, first name, maiden name, last name, username or similar identifier, date of birth and gender.

(b) Contact Data includes billing address, delivery address, email address and telephone numbers.

(c) Transaction Data includes details about transactions (completed or in process), payment amounts/dates to and from you and other details of products and services you have purchased from us.

(d) 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.

(e) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(f) Usage Data includes information about how you use our website, products and services.

(g) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data

3.4 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.

3.5 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.

Special Categories of Personal Data

3.6 We do not collect any Special Categories of Personal Data.

3.7 Special Categories of Personal Data 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

3.8 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.

4 HOW IS YOUR PERSONAL DATA COLLECTED?

4.1 We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact by making purchases on our website or by telephone or by corresponding with us by email, telephone, post or otherwise. This includes personal data you provide when you:

• purchase our products or services;
• create an account on our website;
• subscribe or request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

• Showrooms/Distributors. You may purchase our products from our showroom distribution network, who may pass on some of your personal details to us to facilitate your order.

• 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 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 [LINK] for further details.

• Third parties or publicly available sources. We will not receive personal data about you third parties or public sources unless stated otherwise in this privacy notice.

• Technical Data from the following parties:

• our analytics provider (being Google Analytics);
• advertising networks (such as Meta, Google, Pinterest, based inside and outside the UK); and
• search information providers (such as Google Adwords based inside and outside the UK).

5 HOW WE USE YOUR PERSONAL DATA

5.1 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 (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.

5.2 Please see Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

5.3 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 via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

6 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

6.1 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.

6.2 Please 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.

 7 SHOPIFY

7.1 We use Shopify Inc to host and operate our website, including website design, customer journey, product transactions and payments.

7.2 When you make payments for one of our products you will be using Shopify and their payment providers.

7.3 Shopify Inc use payment card compliant protection measures to ensure your payment information is kept secure, which is known as Payment Card Industry Data Security Standard (PCI-DSS).

7.4 We do not process any payments or receive payment card details. These are all processed by Shopify Inc or the payment providers they work with.

7.5 We are not responsible for Shopify’s processing of transactions for your purchase or their use of your personal information. Shopify’s provision of their services is subject to their the terms and conditions and privacy policies of these payment providers.

7.6 Please see details of how Shopify will use your personal information in the Privacy Policy, which is available at https://www.shopify.com/legal/privacy

8 MARKETING

Marketing

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

Promotional offers from us

8.2 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).

8.3 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.

Uncompleted Purchases

8.4 We may contact you via email (directly or through [INSERT][INSERT]) to discuss an uncompleted purchase you have started but not completed on our website. We will only phone you once and leave a message if you are not available. We will only phone again if you contact us. We will check to see whether you have opted out of telephone marketing calls by notifying us directly or through a third party organisation (e.g. The Telephone Preference Service).

Third-party marketing

8.6 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. This does not apply to our use of marketing organisations operating directly on our behalf.

Opting out

8.7 You can ask us or third parties to stop sending you marketing messages at any time by:
• following the opt-out links on any marketing message sent to you;
• contacting us at any time via email; or
• logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

8.8 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.

9 CHANGE OF PURPOSE

9.1 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.

9.2 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.

9.3 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.

10 DISCLOSURES OF YOUR PERSONAL DATA

Disclosure of your personal data

10.1 We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Group Companies

• External Third Parties.

• 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.

Group Companies

10.2 We may share your personal data within our group of companies to Farmiloe & Farmiloe (W.B.S.) Limited for strategic direction and operational management purposes.
External Third Parties

10.3 We may share your personal data with the following external third parties:

• Service providers - who provide IT and system administration services.
• Third party payment providers – we don’t use third party payment providers (e.g. Paypal, Klarna etc). Instead, we use Shopify to manage and operate our website, including management of payments. Please see our Shopify section in this privacy notice above for further details.
• Suppliers - in relation to resolving a product issue you have raised or in the event of a product recall.
• Professional advisers - including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities - who require reporting of processing activities in certain circumstances.

Disclosure requirements for their parties

10.4 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.

11 WEBSITE INFORMATION

Cookies

11.1 Please see our Cookies Policy regarding the use of cookies on our website.

11.2 You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Third Party Links

11.3 This 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

12 INTERNATIONAL TRANSFERS

12.1 Our office headquarters are based in England and our main data centre is located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the European Economic Area (EEA). It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers.

12.2 We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.

12.3 Some countries or organisations outside of the UK which we may transfer your information to will have an "adequacy decision" in place, meaning the UK considers them to have an adequate data protection regime in place. These are set out on the Information Commissioner’s website - adequacy decisions.

12.4 Where we transfer data to countries or organisations outside of the UK and the EEA which is not considered to have an adequate data protection regime in place, we will ensure that appropriate safeguards. For example, ensuring UK government approved standard international data transfer clauses are put in place where required.

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

13 DATA SECURITY

13.1 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.

13.2 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.

14 DATA RETENTION

14.1 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.

14.2 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.

14.3 By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax and other regulatory purposes.

14.4 In some circumstances you can ask us to delete your data. Please see “Your Rights” section below for further information.

14.5 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.

15 YOUR RIGHTS

Your Rights

15.1 Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner's Office (ICO). Under certain circumstances, by law you have the right to:

• Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.

• 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.

• 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.

• Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).

15.2 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

No fee usually required

15.3 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.

What we may need from you

15.4 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.

Time limit to respond

15.5 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.

16 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

16.1 We keep our privacy policy under regular review. This version was last updated in April 2023. Historic versions can be obtained by contacting us.

16.2 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.

17 GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Version 1.0 (April 2023)