Privacy Policy

1. About out privacy policy

Our privacy policy explains in detail the types of personal data we may gather from you when you interact with Rug Couture. It also explains how we store and handle your data, and keep it secure. We hope that the following information will answer any questions you have. This privacy policy will be updated occasionally - you are welcome to return and check it at anytime.

When you are using the Rug Couture website (www.rugcouture.com.au), Rug Couture is the data controller.

2. What is Rug Couture?

Rug Couture Ltd – which we will refer to as ‘Rug Couture’ in this document – is a business registered in England / Company number 05728357

This website (www.rugcouture.com.au) is owned and operated by Rug Couture.

For simplicity throughout this notice, ‘we’ and ‘us’ means Rug Couture Ltd.

3. Explanation of the legal bases relied upon

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Your consent

In specific situations, we will collect and process your personal data with your consent. For example, when you tick a box to subscribe to our email newsletter.

When gathering your personal data, we will make it clear to you which data is required in connection with a particular service.

Contractual obligations

In certain circumstances, we will need your personal data to comply with our contractual obligations.

For example, when you order an item from us that is to be delivered to your location. We will collect your address details to deliver your purchase, and pass them to our courier.

Legitimate interest

In specific situations, we require your personal data to pursue our legitimate interests in a way which may reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your purchase history to send you or make available personalised offers.

We also combine the purchasing history of customers to identify trends and ensure we can keep up with demand, or develop new products/services.

We may also use your address to send you direct marketing information by post, informing you of products and services that we think may interest you.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Rug Couture to law enforcement.

4. When we collect your personal data

• When you visit our website, and use your account to order products and services.
• When you make an online purchase and checkout as a guest (in which case we just collect transaction-based data such as order details, name, address).
• When you request colour samples, or samples of rugs.
• When you create any type of account with us.
• When you engage with us on third party social media channels such as Facebook, Twitter or Instagram.
• When you contact us by any means with queries, complaints etc.
• When you request that a member of our team email you information about a product or service.
• When you book an appointment with us, or book to attend an event.
• When you enter competitions or take part in promotions.
• When you fill in any forms on our website.
• When you choose to complete any surveys we send you.
• When you have given a third party permission to share with us the information they hold about you.

5. Types of personal data we collect

• If you have an account with us: order information such as your name, address, email address, telephone number, and details of any products you have ordered.
• Details of key interactions with us offline/online. For example, we collect relevant information from our conversations with you, details of purchases you made, use of discount codes, pages you visit on our website, and how and when you contact us.
• Copies of documents you have provided to prove trade client eligibility. This might include details of your full name and address. If you provide a driving license or passport, the data will also include your date of birth.
• Details of your purchasing preferences.
• Information gathered by the use of cookies in your web browser. Find out more about how we use cookies on our website, below.
• Personal details which help us to recommend items of interest. For example, you might tell us your room colour or size, which we may use to guide us when suggesting items to you. We will only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us.
• Any comments and product reviews you provide.
• To deliver an optimal web experience, we gather technical information about your internet connection and web browser as well as the country where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and the search term you used to find our website.
• If you interact with us through social media channels such as Facebook or Twitter, we store your social media username to help us respond to your comments or questions.

6. How and why we collect and use your personal data

We wish to provide an optimal customer experience. One way for us to achieve this is to combine the data we have about you. We use this to offer you promotions, products and services that may be of interest to you.

Data privacy law allows this as part of our legitimate interest in understanding our customers and providing an effective service.

If you wish to change how we use your data, you can find details in the ‘Your rights over your personal data’ section below.

If you have chosen not to share your personal data with us, or refuse certain contact permissions, we may not be able to provide the services you have asked for. For example, if you have requested that we contact you when certain products are available, we cannot do that if you have withdrawn your consent to hear from us.

Cookies

By using our website (through any device) you agree that this use of cookies applies to that use in addition to any other terms and conditions which may apply.

This website uses cookies and may be subject to change. Any changes will appear here and become effective immediately. Your continued use of our websites and apps is taken as meaning that you agree to any changes.

What is a Cookie?

Cookies are small files that are sent to and stored on your computer, smartphone, tablet or other device for accessing the internet, whenever you visit a website or use our apps.

Cookies are used to maintain the integrity of your browsing activities when you visit a website and can also be used to customise and so improve the individual customer experience.

Cookies do not in any way compromise the security of your computer. You can continue to use this website with no loss of functionality if you choose to disable cookies on your computer. However, use of our website and applications requires cookies to be enabled in order for our services to function securely and correctly.

More general information on cookies can be found on aboutcookies.org. This includes information on how to disable cookies.

Guidelines from the Office of the Data Protection Commissioner for the contents and use of Privacy Statements on websites, including expected standards for cookies can be found at http://www.dataprotection.ie/docs/PrivStatements/290.htm

How we use Cookies

This website uses cookies to monitor our website traffic, to ensure better service levels, and to enable us provide you with additional features such as customised delivery of service to you.

To achieve this, there are different types of cookies in use. They all work in the same way, but have minor differences which are explained below.

Session Cookies

Session cookies last only for the duration of your visit and are deleted when you close your browser. They are essential for secure user navigation through the site and enable the delivery of basic functionality.

Specifically they ensure the security and integrity of your session, preventing fraudulent use and keeping you signed in while you move between pages and service your account.

Persistent Cookies

Persistent cookies last after you have closed your browser, and allow us to remember your actions and website preferences.

This website uses persistent cookies to analyse customer visits to our sites. These cookies help us to understand how customers arrive at and use our sites so we can improve the overall on-line experience.

Analytics Cookies

Finally, we use analytics cookies to help us make our websites even better for those who visit them regularly. This type of cookie helps us to further understand how individual visitors use our on-line services and allows us to improve the overall service and products offered to you.

How we use your data and why

• To process orders that you make when using our website, or over the telephone with one of our representatives. If we cannot collect your personal data during checkout, we're unable to process your order and comply with our legal obligations.

• For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, for example a 'courier', and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees etc.

• To respond to your queries, refund requests or complaints. Holding the information you have provided enables us to respond. We may also keep a log of these interactions to inform any future communication with us and to demonstrate how we have communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and your account from illegal activities. This includes using your personal data to maintain, update and safeguard your account. We may also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website. We do all of this as part of our legitimate interest.

• For example, by checking your password when you login to our website and using software based monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

• If we discover any criminal activity or alleged criminal activity through our use of security monitoring software we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions etc.
• To send you relevant and personalised communications by post in relation to updates, offers, services and products. We do this on the basis of our legitimate business interest.

• You can opt out of hearing from us by any of these channels at any time.

• To send you communications required by law or that are necessary to inform you about our changes to the services we provide you with. For example, updates to this privacy policy, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To display the most interesting content to you on our websites, we may use data we hold about your favourite products and/or for our website to place cookies or similar technology on your device.

• For example, we may show a list of items you have recently looked at, or offer you recommendations based on your purchase history and any other data you have shared with us.

• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
• To develop, test and improve the systems, services and products we provide to you. we will do this on the basis of our legitimate business interests.

• For example, we will record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you are experiencing.

• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

• You can opt out of receiving these requests from us at any time.

• To construct a broader picture of who you are, what you like, and to inform our business decisions, we combine data captured from across Rug Couture, third parties and data from publicly-available lists as we have described in the section 'Types of personal data we collect'. We do this on the basis of our legitimate business interest.

• For example, by combining this data, will help us personalise your experience and decide which content to share with you. We also use anonymised data from customer purchase histories to identify trends.

7. How we combine your personal data for direct marketing

We wish to bring you offers and promotions that are relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Rug Couture as described above, for example your Rug Couture online shopping history. For this purpose we may combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.

8. How we secure your personal data

We know how much the security of your data means to our customers, therefore we will treat their data with care and take appropriate steps to protect it.

We secure access to all areas of our website via secure socket layers (SSL) which displays as ‘https’ in your web browser.

Access to your personal data is password protected, and sensitive data such as payment card information) is also secured and tokenised to ensure it is protected.

We frequently monitor our systems for potential vulnerabilities and attacks, and carry out regular testing to offer the maximum level of security.

9. How long we retain your personal data

Whenever we collect or process your personal data, we will only retain it for as long as is necessary for the purpose for which it was collected.

At the end of the retention period, your personal data will be erased completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for analysis.

Some examples of customer data retention periods:

Orders

When you place an order, we will keep the personal data you provide us with indefinitely so we can comply with our legal and contractual obligations. See section 12 below 'Your rights over your personal data' for more information.

Warranties

If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

10. Who we share your personal data with

We sometimes share your personal data with trusted third parties.

For example, delivery couriers, installers visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you etc.

Here is the policy we apply to those organisations to keep your data secure and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

• Examples of the kind of third parties we work with:

• Operational companies such as delivery couriers.
• Direct marketing companies such as Mailchimp where we manage our electronic communications with you.
• Google to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. You can read about cookies in section 6 for more details.
• Data insight companies to ensure your details are up to date and accurate.
• Upon placing an order online using a credit card or debit card, we will securely pass transactional details including product information and personal data such as your card number, name and address to our third party payment processors - Worldpay and Paypal for the sole purposes of securely processing your transaction.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity on our systems. This may include sharing data about individuals with law enforcement bodies.
• We may also be required to disclose your personal data to the police or other law enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and we take the privacy of our customers into consideration.
• We may, from time to time, expand, reduce or sell Rug Couture and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this privacy policy.

To enhance your experience and personalise your journey through the Rug Couture website we use third party services, who may process your personal data as part of their contracts with us, these include:

Worldpay
Paypal
Mailchimp
Google
Twitter
Instagram
YouTube
Pinterest
Facebook

11. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA. For example, 'couriers'.

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to Rug Couture in the UK.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this privacy policy.

12. Your rights over your personal data

An overview of your different rights.

You have the right to request the following:

• Access to the personal data we hold about you, which is free of charge in most cases.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• To correct your personal data when incorrect, out of date or incomplete.

• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).

• That we cease any consent-based processing of your personal data after you have withdrawn your consent.
• Review by a sales person of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that Rug Couture holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection, Rug Couture, Unit 1, Gregston Estate, Birmingham Road, Oldbury, West Midlands, B69 4EX, UK or email data@rugcouture.com.au to ask for your information to be amended, please update your online account, or contact our customer service team.

If we choose not to action your request we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this privacy policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

13. How you can stop the use of your personal data for marketing use

There are a few ways you can stop direct marketing communications from us:

• Clicking the ‘unsubscribe’ link in any automated email communication that we send you. We will stop any further marketing emails.
• Write to: Data Protection, Rug Couture, Unit 1, Gregston Estate, Birmingham Road, Oldbury, West Midlands, B69 4EX, UK.
• Email data@rugcouture.com.au to ask for your information to be amended

• Please note that you may continue to receive communications for a short time after modifying your preferences while our systems are updated.

14. How to contact the regulator

If you believe that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling +44 (0)303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we cannot be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 15 below

15. If you reside outside of the United Kingdom

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. You still have the right to ask us not to process your data in certain ways, and if you do so, we will comply.

Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.

By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.

This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.

We will ensure that adequate steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this privacy policy. We will also make sure we adequately protect the confidentiality and privacy of your personal data.

USA

To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see cookies information above in section 6, 'How and why we collect and use your personal data'

Canada

As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.

The personal data we process may be accessed by people within Rug Couture, or by our third-party service providers, who require access for the purposes indicated in this privacy policy, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada or in some Canadian provinces, your local Privacy Commissioner.

Australia

For the purposes of this privacy policy, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.

If you are in Australia you may submit any questions, comments or complaints to our UK-based Data Protection team who will come back to you within 30 days.

If you are contacting us to complain about an alleged breach of this privacy policy or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.

We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.

If we have not come back to you within 30 days, or you are not happy with the response that you have received, you may submit a complaint to the Office of the Australian Information Commissioner.

We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.

Nothing in this privacy policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

Hong Kong

When you agree to receive direct marketing emails from us, we will send you promotions on products we sell at Rug Couture.

If you are in Hong Kong you may submit a complaint to our UK-based Data Protection team who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive, you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.

South Korea, Malaysia, Singapore, Qatar

Terms used in this privacy policy shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).

By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this privacy policy and our popup cookies notice, including for analytics and research into website use.

16. Additional questions

We hope that our privacy policy has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that have not been covered here, please contact our Data protection controller who will be pleased to help you:

• Email us at data@rugcouture.com.au
• Write to us at: Data Protection, Rug Couture, Unit 1, Gregston Estate, Birmingham Road, Oldbury, West Midlands, B69 4EX, UK.