Easylife Holding Limited's Privacy Policy

1. Introduction and Scope

Easylife Holdings Limited ("Easylife Holdings") recognises that the privacy of the personal information that our customers provide to us is critically important. We take the privacy and security of your personal information very seriously. We are committed to complying with our legal obligations under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other data protection laws.

This Privacy Policy explains what types of personal information we collect about you, what we do with that personal information, the legal basis for our processing of your personal information, what rights you have in relation to your personal information and how you can exercise those rights. It also explains how we keep your personal information safe and secure.

This privacy policy also applies to Easylife Holdings' subsidiary companies, including in particular the following companies:-

• Easylife Limited (company No. 05221840)
• The Rewards Club Limited (company No. 13048087)

We shall refer to all such companies hereafter as "Associated Companies" and to Easylife Holdings Limited and such companies as "Easylife Holdings and Associated Companies".

In this privacy policy the terms "we", "us" or "our" may refer to Easylife Holdings or to any of the Associated Companies.

2. Who are Easylife Holdings Limited?

Easylife Holdings Limited is the parent company for the Associated Companies and their sub brands, listed below:-

- Book Club
- Easylife
- Evergreen
- Gardening Club
- Good Ideas
- Maison Maison
- Motor Club
- Perx
- Positive Health
- Puzzle Book
- Rewards Club
- My Top Rewards

Each of these brands and associated companies may use your personal data and contact you.

Easylife Holdings is registered with the Information Commissioner's office under Registration No. ZB063888.

Easylife Limited is registered with the Information Commissioner's office under Registration No. ZB537735.

The Rewards Club Limited is registered with the Information Commissioner's office under Registration No. ZB063883.

Easylife Limited
For the purposes of day to day contact Easylife Limited operates from 94 Orchard Gate, Greenford, Middlesex, UB6 0QP and its business is the retail sale, via catalogues and websites, of a broad range of items, which are intended to make life easier and to solve common problems around the home and garden. The items we sell include household goods, gadgets, motoring accessories, health and mobility items and a wide range of miscellaneous goods. Easylife and its predecessor businesses have been trading since 1992.

Easylife Holdings along with its sub brands is the Data Controller for the purposes of the Data Protection Act 2018 and the UK GDPR.

The Rewards Club Limited
The Rewards Club Limited operates a number of discount schemes, including the following:-

- Book Club
- Gardening Club
- Motor Club
- Perx
- Puzzle Book
- Rewards Club
- My Top Rewards

The operation of these schemes involves the use of various telemarketing companies, as described in more detail in section 11 below.

The Rewards Club operates a website, which provides more information about who it is, which can be viewed at https://therewardsclub.co.uk

3. Contacting us

There are three ways to contact Easylife Holdings and Associated Companies to discuss any data protection issues you may have:-

In writing

The Data Protection Officer
Easylife Holdings Limited
94 Orchard Gate,
Greenford, Middlesex, UB6 0QP

By email

DPO@easylife.co.uk

By phone

0333 030 0777

4. Who is responsible for the management of data protection at Easylife Holdings and the Associated Companies

We have appointed a Data Protection Officer for Easylife Holdings and Associated Companies. The Data Protection Officer is responsible for managing data protection at Easylife Holdings and Associated Companies and for ensuring that we comply with our legal obligations relating to personal information. The Data Protection Officer can be contacted using the contact details given in section 3. above.

5. What personal data do we collect?

Under data protection laws, personal data is any information relating to an individual from which that person can be identified. It does not include data from which the identity of an individual cannot be identified (which is anonymous data).

When you create an account with us or buy something from us, we collect personal data about you. The personal data we collect may include:

• Your first name, surname, title, address, post code, email address, contact telephone number(s), account user names and passwords ("Contact Data").
• Your payment information (your billing address, your delivery address, payment method details and payment card details, ("Billing Data").
• Information about orders we are fulfilling for you ("Order Data")
• Information about your previous purchase transactions ("Purchase History").
• Information about your marketing preferences ("Marketing Preferences").
• Information about your other interactions with us.

We refer to all this personal data hereafter as "Customer Personal Data".

In order to improve the Easylife Website, Easylife may also collect anonymous data about how users navigate through and use the Easylife Website.

We do not collect or process personal data about children. All people who register with us or who otherwise provide their personal data to us or must be aged 18 or over.

6. Updating or changing your personal data

Please do help us keep your personal data up to date by notifying us of any changes relating to for example your name or address or Marketing Preferences.

You can update any information we hold about you by contacting our customer services team on 0333 030 0777. They will be delighted to help you.

You may also update your information by using this link.

7. How do we collect your personal data?

We collect your personal data when you provide it to us. This could be when you create an account with us, register with us to receive our catalogue, when you place an order with us either by completing an order form in one of our catalogues or online or when you contact us with an enquiry. Your personal data may also be collected over the telephone via our call centre, by post or online through the Easylife Website.

We also collect some data through the data alliances, more details of which are set out in section 11 below.

8. How do we use the personal data we collect about you?

We will use your Customer Personal Data in the following ways:

• Contact Data: to create your account and register you as a returning customer, if you have chosen to create an account with us and to send you information relating to your account.
• Contact Data, Order Data, Billing Data: to fulfil any order, you place with us or subsequent orders or to provide any services you request and to process payments and deal with after sales enquiries.
• Contact Data, Order Data, Billing Data: to keep you informed about the status of your order, to deal with any queries or issues that might arise and to send you the products you have ordered.
• Contact Data, Order Data, Billing Data, Purchase History, Marketing Preferences: to send you our catalogues and other mailings.
• Contact Data, Order Data, Billing Data, Purchase History, Marketing Preferences: to enable The Rewards Club Limited (and those authorised by it), to market to you its products, services, special offers and promotions including but not limited to the Book Club, Gardening Club, the Motor Club, Perx, Puzzle Book, the Rewards Club and My Top Rewards, products and services and to enable it to fulfil your orders for any such products or services and to process payments and deal with after sales enquiries for such products and services.
• Contact Data, Order Data, Purchase History, Marketing Preferences: to notify you about any product recalls or provide other information about products you have purchased.
• Contact Data, Order Data, Purchase History, Marketing Preferences: to maintain a record of your orders and other interactions with Easylife, in order to manage and enhance its relationship with you.
• Contact Data, Order Data, Purchase History: to improve and develop the products and services that we offer by analysing your information, to train our staff and to carry out performance monitoring.
• Contact Data, Order Data, Billing Data, Purchase History, Marketing Preferences: to comply with any legal obligations upon us.

We may also use your Billing Data to enable you to purchase other items or services from us in the future, either online or during phone calls, which may be initiated either by you or by us.

9. What is the legal basis on which we process your personal data?

Data protection law provides that a company, such as Easylife Holdings, can only lawfully process personal data if it has at least one legally defined reason for doing so. The legally defined reasons we rely on are as follows:-

You have consented to our using your personal data

We can collect and process your personal data with your consent. This will be the case if you have provided your personal data to us when ordering products or services from us, creating an account with us, registering to go on our mailing list or requesting a catalogue. We rely on this ground to send you products, catalogues and other information and materials that you have requested or agreed to receive.

Our Contractual Obligations

We may process your personal data to comply with and perform our contractual obligations under a contract or potential contract with you. We rely on this basis to fulfil your orders.

Legitimate Interests

We may process personal data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on the rights, freedoms and interests of our customers.

We have a legitimate interest in carrying out marketing activities in order to offer you products and services that we think might be of interest to you. If you are an existing customer, or a prospective customer who has shown an interest in our products or services or in the mail order sector, we may rely on this basis to contact you by post and by telephone with marketing material and information about products and services offered by us.

10. Marketing

If you have registered to be on our mailing list or if you are an existing customer, we may use your Contact Data to send you our catalogues and other marketing materials by post. We may also contact you by telephone about our products, services and promotions.

We may also use your Contact Data to send you emails and text messages, from time to time, about products, services and promotions which are similar to products and services that you have previously purchased from us and containing news, updates, special offers and bulletins. However, we won't send you any such marketing emails or text messages if, when you first provided your details to us or subsequently, you indicated that you didn't want to receive or no longer want to receive such marketing emails or text messages from us. In addition, all our promotional emails and text messages will contain an opt out option, which you can use to tell us to stop sending emails or text messages to you.

We regularly check (or ensure third parties appointed by us to run certain of our business services regularly check) our customer databases against lists maintained by the Telephone Preference Service ( https://www.tpsonline.org.uk/tps ) and the Mail Preference Service ( https://www.mpsonline.org.uk ) to ensure that we don't call or post items to customers who have registered with these services not to receive marketing calls or mailings.

We try to use the most popular and convenient forms of electronic communication. This could include, in addition to email and text messages, new and emerging forms of communication such as Facebook messenger or WhatsApp.

You can tell us at any time to stop marketing to you by using any of the methods set out in section 3 above or by submitting a request via this link.

Each time you receive a marketing email or text message from us, you will be given the opportunity to opt-out of receiving further marketing emails or texts.

We will try to implement any change to your marketing preferences as soon as reasonably possible, usually within 30 days. Sometimes however there can be a delay between you changing your marketing preferences and us acting on those changes as mailings are printed several weeks before being sent out.

We want to make sure the communications we send you are of interest to you. We therefore use information about you to tailor our messages. We analyse, where it is lawful for us to do so, different pieces of information such as age, transaction history, demographics, preferences and buying habits, along with the pages you may have visited on our website to make sure we send you relevant product offers. This commonly used marketing technique is known as profiling and we believe it makes our dialogue with you more personal and accurate.

11. Who do we share personal data with?

Easylife Holdings may share Customer Personal Data with the Associated Companies. We may share Customer Personal Data with other businesses so that they can market and sell their products and services to their customers.

We provide Customer Personal Data to businesses which enable us to provide our products or services to you, including for example payment processors and delivery companies. We work with a PCI compliant payment processor to arrange your payments and we share your personal payments data with sub processors when necessary under strict data processing contracts.

We also outsource certain business functions (such as telemarketing, order fulfilment and certain CRM functions) to trusted third parties. To enable those third parties to carry out those business functions we either provide them with, or they receive from our customers, Customer Personal Data. Such third parties are data processors in relation to Customer Personal Data, which they acquire from us and we remain the data controller in relation to such Customer Personal Data. We have detailed contracts in place with such third parties which oblige them to fully comply with UK data protection laws.

We also share Customer Personal Data where necessary with organisations for the purposes of detecting and preventing fraud or other criminal conduct and/or in order to comply with our legal obligations.

We are members of a number of data alliances. Data alliances collect customer information from their members, including details of customer names and addresses (but not email addresses) and transactional history. That pooled information is then used by alliance members to better target customers with products and services that are more likely to be of interest to them. Alliance members are active in the charity, clothing, food and drink, finance, leisure, travel, gifts and gadgets, health and beauty, household goods, gardening, home interior, entertainment and mail order sectors. The data alliances we are members of include:-

- Abacus Alliance, a data sharing alliance run by Epsilon International UK Limited. A copy of Epsilon Abacus's privacy policy can be viewed here: https://www.epsilon.com/abacus/services-privacy-policy

We also work with a number of trusted partners, operating in the charity, financial, leisure, travel, gifts and gadget, health and beauty, household goods, gardening, home interior, entertainment and mail order sectors, who offer products or services that we may think might be of interest to you. We would also like to pass on to them your Contact Data. When you register with us, set up an account with us or purchase items from us, you can opt-out of our sharing your Contact Data with these trusted partners. You can tell any of our trusted partners to stop sending you marketing material at any time by using the opt-out option provided in the marketing materials they may send to you.

Retailers/Mail Order

• Automotive
• Fashion/clothing
• Household
• Gardening
• Gifts
• Beauty
• Collectibles
• Food & Wine
• Gadgets

Charities

• Animal
• Arts & Culture
• Community
• Environmental
• Elderly
• Disability
• Housing
• Medical
• Overseas Aid
• Public Service & Military

Lifestyle

• Health & Wellbeing
• Leisure
• Outdoor activities
• Entertainment
• Home interiors
• Travel

Finance

• Insurance - home, car, pet, personal
• Banking
• Pensions
• Investments
• Claims/Legal services
• Planning for your/your families' future

Please note that Epsilon Abacus may transfer data outside the EEA. The transfer will take place in the presence of appropriate safeguards, including standard data protection clauses adopted by the EU Commission. If you would like more information, please call us on 0333 030 0777, write to us at our address below or email us at DPO@easylife.co.uk.

12. What are your legal rights in relation to your personal data?

You have a number of legal rights in relation to the personal data we hold about you. These include:

• The right to be informed about how we process and manage your personal data. We comply with your rights in this regard by the publication of this privacy policy.
• The right to obtain a copy of any personal data about you which we hold at any time and to obtain certain information about how we process that data. This is called a Subject Access Request and you can submit such a request by using this link.
• The right to request that any inaccurate or incomplete personal data that we hold about you is corrected. You can update your personal data by using this link.
• In certain circumstances, the right to request that we erase or restrict our processing of personal data that we hold about you.
• The right to request the transfer of your personal data to you or to a third party.
• The right to request that we stop using your personal data for direct marketing or for purposes based on legitimate interests. You can tell us at any time to stop marketing to you by using any of the methods set out in section 3 above or by using this link.
• The right to require us to stop processing your personal data where you contest the accuracy of the information we hold about you.
• Where our processing of your data is based on your consent, the right to withdraw your consent at any time so that we then stop processing your personal data based on that consent.
• The right to have any decision, made solely on the basis of automatic processing of your personal data, reviewed by a human being, express your point of view on the decision, obtain an explanation of the decision and challenge it.
• The right to compensation in certain circumstances where we breach your rights relating to your information in a way that causes you damage.

If you would like to exercise any of your legal rights in relation to the personal data we hold about you, you can submit a request through our Website using this link.

Generally you will not have to pay a fee to exercise any of your legal rights. However, we are entitled to charge a reasonable fee if any request is clearly unfounded, repetitive or excessive. We can also refuse to comply with an unfounded or excessive request. We may need to request information from you to confirm your identity, in order to make sure that personal data is not disclosed to someone who is not entitled to have it. We may also need to ask you for additional information to help us respond to your request. We will try to respond to your request within one month but, if the request is very complex or if you have made a number of requests, it could take longer. In such circumstances, we will explain to you why it will take longer to respond and we will keep you updated.

13. How long will we keep your personal data?

We retain your personal data for as long as reasonably necessary to fulfil the purposes it was collected for and to enable us to comply with our legal obligations. Generally, we will keep Customer Personal Data for so long as the customer holds an account with us or if longer for up to six years after the last recorded transaction or interaction with the customer. Six years is the limitation period for a customer bringing a contract claim against us in relation to an order. At the end of this period, your personal data will be irretrievably deleted. In some circumstances, you can ask us to delete or anonymise your personal data earlier.

We don't hold customer payment card data; this is encrypted and tokenised to ensure total security as soon as the customer payment transaction is completed.

14. How do we protect your personal data?

We take the security of your personal data very seriously. We use appropriate security measures to protect your personal data from unauthorised access, disclosure, alteration or loss.

All personal information you provide to us, which we store electronically, is stored on our private, secure network of computers. Access to our IT systems is password protected. Our IT provider regularly monitors our computer and network systems for possible vulnerabilities and attacks and use state of the art firewalls and anti-virus software, which is regularly updated.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

15. Where is your personal data processed?

We only process personal data in the UK or the EEA.

16. Personal Data of international customers

We are based in the UK and are committed to complying with data protection laws that apply in the UK. We do not take responsibility in relation to any other laws or regulations that may apply to personal data submitted from outside the UK and any person submitting any personal data to us from outside the UK is responsible for that personal data. Please contact us in any of the ways set out in section 3 above if you would like us to remove any personal data.

17. Changes to our privacy policy and updating your information

It is important that you update your personal data that we hold about you so that it is current and accurate. You can do this through this link.

As we continue to develop our business and Website and take advantage of advances in technology, our privacy policy may change. This version was last updated on [date]. Any changes we may make to our privacy policy will be posted on this page and, if appropriate, we will notify any significant changes to you by email or in some other manner. Please refer to this page frequently for updates and changes to our privacy policy.

18. How do you make a complaint to the regulator?

You also have the right to make a complaint to the Information Commissioner's Office (ICO), which is the UK data protection supervisory authority, if you feel that your personal data has not been handled properly or if you are not happy with the way that we have responded to any request you have made relating to the personal data we hold about you. The ICO can be contacted by telephone on 0303 123 1113 or online at www.ico.org.uk/concerns. We would appreciate the opportunity to resolve any data protections issues with you, so please contact us in any of the ways set out in section 3 above, in the first instance.

Cookie Policy

Cookies and How We Use Them

What are cookies?

Computer cookies are small text files that a website transfers to your computer. Cookies cannot harm your computer and are anonymous. They do not contain any information that could be used to identify you, nor do they contain any confidential information such as your email address or credit card details.

Using cookies helps us to make our Website easier for you to use and helps us to give you a more personalised web experience, such as enabling us to present information about products and promotions, which we believe will be of more interest to you. Examples of our use of cookies include:

• Storing the content of your shopping basket as you proceed through 'Checkout' and so that it is available to you when you return to the Website.
• To record the areas of the site that you have visited and for how long, as well as the products that you viewed and those that you purchased. We use this information to help us improve the effectiveness of our Website design, to make it more accessible to our users and to improve the quality of service that we provide. We also use this information to inform the product recommendations you see while you are on our Website, in communications that we send to you, and in adverts that you see while on other Websites.

Are cookies safe?

Yes. The information stored in cookies is anonymous and secure. It cannot be used to identify you personally and cannot harm your computer.

Can I switch cookies off?

Easylife uses these cookies to make the Easylife Website easier to use and to allow it to provide the best possible standard of service. Cookies are an essential part of how our Website works. However we require your consent to use them. To withdraw your consent, or if you want to be notified each time a cookie is about to be used, you should use the settings provided in your Website browser to prevent us from storing cookies on your computer. However if you choose not to consent to the use of cookies your experience of our Website could be impaired and it's possible many important aspects of the site will not work at all.