Privacy & Cookies Policy (Customer Promise)

We understand that your privacy and the security of your personally identifiable information is extremely important. At Booths we only seek to process your Personal Information where necessary, either to serve our legitimate business interests or to provide you with a service that you’ve expressly requested.

This Privacy Policy discloses how we at Booths collect, process, share and secure information gathered from you.

© 2024 E.H.Booth & Co Ltd. All rights reserved.

What this Policy covers

The data controller is E H Booths Ltd (referred to in this policy as “we” or “us”).

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That is why we have developed this Privacy Policy (“Policy”), which:

• sets out the types of personal data that we collect
• explains how and why we collect and use your personal data
• explains when and why we will share personal data within Booths and with other organisations
• explains the rights and choices you have when it comes to your personal data.

This Policy applies to you if you use our services (referred to in this Policy as “our Services”).

Using our Services means:

• shopping with us over the phone, in store or online
• using any of our websites or applications where this Policy is posted
• being a member of the Booths Card loyalty scheme
• completing our customer satisfaction survey including entering the associated prize draw
• contacting us (or if we contact you) about our Services
• booking and attending an event organised by Booths that took place either within a Booths store or external to a Booths store.
• Following us on any of our social media platforms

Our websites may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal data on a website as we do not accept any responsibility or liability for websites of other organisations.

Information We Collect and Process

When you register for our Services, you may provide us with:

• Your personal details, including title, full name, postal / billing address, email address, phone number(s), date of birth and gender.
• Your account login details, such as your username, email address and the password that you have chosen.
• Your personal preferences, including how and if you wish to receive marketing. communications, paperless receipts and donate any accrued loyalty reward balance to our nominated charity.

When you shop with us online or browse our websites, we may collect:

• Your personal details, including title, full name, postal / billing address, email address, phone number(s), date of birth, company name (if applicable) and local Booths store.
• Your account login details, such as your email address and the password that you have chosen.
• Information about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it).
• Information about your online browsing behaviour (including those shown on other organisations’ websites).
• Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers).

When you use Booths Card to shop with us, we may collect:

• Transaction information (for example, what you have bought, when and where you bought it and how you paid for it – used to record your transactions and provide you with an electronic receipt).
• Booths Card identification number – used as a reference number to identify your transactions and provide you with electronic receipts and to provide you with Booths card benefits.
• Other Personal Information that you provide whilst communicating with us from time to time.

When you contact us or we contact you or you take part in promotions, competitions, surveys, or questionnaires about our Services, we may collect:

• Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email, online forms, post or when you speak with us through social media.
• Details of the emails and other digital communications we send to you that you open, including any links in them that you click on.
• Your feedback and contributions to customer surveys and questionnaires.

When you register your interest in taking part in customer research at Booths we will collect:

• Personal data you provide when registering (for example, your name, contact details, Booths Card number).
• Your feedback and contributions to customer research through focus groups, assisted shops, online communities, surveys, mystery shops and questionnaires.
• We will use your personal data to contact you and invite you to participate in customer research projects that may be of interest to you based on the profile.

When you book and attend events organised by Booths that took place at a Booths store or external to a Booths store:

• Personal data you provide when registering (for example, your name, contact details, Booths Card number).
• Photography and/or film from the event. If you do not wish to appear in any images or film captured, please let a Booths colleague know before the event starts, so we can take the appropriate steps to ensure you are not included. The photos and/or film may also be shared with third party suppliers where necessary. 
• Please note that we may not be able to retrospectively delete photos and/or film posted on social media, digital communications, or printed communications.

Other sources of personal data:

• We may also use personal data from other sources, such as specialist companies that supply information, online media channels, our Retail Partners, and public registers. For example, this other personal data helps us to review and improve the accuracy of the data we hold and improve and measure the effectiveness of our marketing communications, including online advertising.

YOUR DATA RIGHTS

Applicable European data protection law affords you certain rights in regard to the Personal Information that we hold about you. Namely, you have the right to:

• ask us to cease marketing communications at any time (opt out)
• ask us not to process your Personal Information for marketing purposes at any time
• have any inaccuracies in the Personal Information held about you corrected
• ask us to stop processing any of your Personal Information that we process on the basis of our legitimate interests
• Ask us to restrict the processing of your Personal Information. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • 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
• ask us to delete your account(s) permanently
• access a copy of the information we hold about you.

We will make all reasonable efforts to comply with your requests except where we are not permitted or required to do so under applicable law.  Requests are free of charge; however, we reserve the right to charge a minimal fee to cover administrative costs should we consider any request to be excessive, unfounded, or unreasonable. We may ask you to complete a formal Subject Access Request document to support us in compiling the requested information. This is not a legal requirement but will allow these requests to be dealt with in a timely manner.

We want to make sure that the personal information we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend them.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or unlawful disclosure, we have put in place suitable physical, electronic (firewalls and data encryption) and managerial procedures to safeguard and secure the information we collect.

• We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
• We enforce physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal information with you.
• We will reveal only the last four digits of your credit card number when confirming an order.

However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer to us over the internet.

The personal data that we collect from you may be transferred to, and stored at, a destination outside of the Booths network. It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. We will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this policy.

We restrict access to your Personal Information, only providing access to individuals that require it to operate, process, develop or improve Booths Website and Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

HOW AND WHY, WE USE YOUR PERSONAL DATA

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.

We do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a Booths cardholder	Identity Contact Marketing Communications	Contractual Consent Legitimate Interests – to provide additional loyalty benefits, inform you about our products and services, study how customers shop
To manage our relationship with you	Identity Contact Marketing Communications	Consent Legal Obligation – keep our records updated, notify you about changes to our loyalty scheme, terms and privacy policy
To provide customer support	Identity Contact Usage (interactional and behavioural)	Consent Legal Obligation – to investigate queries and complaints to provide a resolution Legitimate reasons
To register you for our newsletter	Contact Marketing Communications	Consent Legitimate Interests – to inform you about our products and services
To process and deliver and online order	Identity Contact Transactional Marketing Communications Usage (interactional and behavioural)	Contractual – to deliver items ordered Consent Legitimate Interests – to inform you about our products and services.
To enable you to enter prize draws, competitions, and surveys (customer research)	Identity Contact Marketing Communications Usage (interactional and behavioural)	Consent Legitimate Interests – to gather valuable information so that we can improve our product range and services
To manage and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Legal Obligation Legitimate Interests – running our business, provision of administration and IT services, network security, to prevent fraud
To deliver our websites, content and advertisements, and use data analytics to measure and understand the effectiveness advertising	Identity Contact Marketing Communications Usage (interactional and behavioural) Technical	Legitimate Interests – gather valuable information so that we can improve our product range and services, grow our business, and inform our marketing strategy
To use photography/film from events organised by Booths that took place at a Booths store or external to a Booths store to advertise our business	Identity	Legitimate interests – to gather valuable marketing material so that we can promote, market and grow our business.
To use Live Facial Recognition Technology within stores	Identity	Legitimate Interests – to protect colleagues, customers, the local community and the business.
To use CCTV Technology	Identity	Legitimate Interests – to protect colleagues, customers, the local community and the business.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, and Usage 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).

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

Personalisation and Communication

• At Booths, we love to keep you up to date with the latest news, offers, products and services. We do this in several ways, including but not limited to email, post, SMS, phone, and advertising.
• When you opt in to receive marketing communications from Booths, you give your consent for Booths or a chosen third party (under our explicit instruction) to contact you about products and services from Booths which we consider may be of interest to you.
• If you wish to opt out of marketing communications from Booths simply follow the details and links provided, alternatively change your opt in preferences in your Booths Card account or Booths Food to Order account, alternatively contact our customer service team on 0370 774 9506.
• Please note unsubscribing from Booths marketing does not unsubscribe you from any transactional based communications, such as an online sales receipt or a Booths Card update.

Your Booths Card

• If you are a Booths Cardholder, you give your consent for Booths to analyse your customer records and purchase history. The information we collect and store relating to you is primarily used to help us provide and improve our services for you.
• We may use your data, or permit chosen third parties (under our explicit instruction) to use your data, so that you can be provided with information about products and services which we consider may be of interest to you. See ‘External Service Providers’ to learn more.
• If you wish to opt out of marketing communications from Booths simply follow the details and links provided, alternatively change your opt in preference on your Booths account page or contact our customer service team on 0370 774 9506.
• We may share aggregated, non-personally identifiable information with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Our websites

• Whilst using our website(s), you are provided with a web portal to access Booths as described above. You are also able to communicate with us via email. When doing so, we will collect and process your email address in order to process your enquiries, respond to your requests and improve our services.
• Booths may store or process personal data submitted voluntarily by visitors. By submitting personal data, the visitor consents to the use of that data for the purpose of sending the visitor answers, news messages and/or other information, whether or not on a regular basis. If you do not want your personal data to be stored or processed, please do not submit it to us.
• Any communication or material of this kind that you transmit will be treated as non-confidential and non-proprietary. Included without limitation in the non-confidential and non-proprietary materials transmitted to this website are reviews, suggestions, ideas and comments. Booths is entitled to unrestricted use of any communication or material transmitted to this website, for any purpose whatsoever, commercial or otherwise, without compensation to the provider of the submission.

BOOTHS CUSTOMER ACCOUNT

You are entitled to register for the following Booths accounts. The data for these accounts is stored and processed independently of each other.

• To receive additional benefits from shopping instore at Booths, you may register for a Booths Card account at booths.co.uk. Using your username or email address and a password, you may access your account online at any time to add, delete and update your personal information and change your preferences. You may also request an additional card, request a replacement card and view your paperless receipts.
• To make online shopping faster and easier, you may register for an online Food to Order account at orders.booths.co.uk. As a registered customer, you only have to enter your name, contact and billing address details once; your information will then be securely stored with us for future use. Using your email address and a password, you may access your account online at any time to add, delete and update your personal information and change your preferences. You may also view your order history and wish list.
• To fulfil our online flower shopping offer, you will need to enter certain information at flowers.booths.co.uk when you place an order. As a customer, you will have to enter your name, contact and billing address details as well as payment information; your information will not be stored as there is no requirement to create an account to use this service. For more information, the privacy policy for the flowers.booths website can be found at flowers.booths.co.uk/policies/privacy-policy.
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Accuracy of personal Information

• You confirm that on registration of a Booths account, the information provided by you is true, complete, and accurate. You agree to notify us or update your personal information on one or both websites (as applicable) should the information about you become inaccurate. We cannot be held responsible for any inaccuracy of data should you fail to update or notify us of such changes.

Retention of personal data

• Booths will retain your personal information only for as long as necessary to fulfil the notified purpose(s) for which it was collected and to comply with applicable laws.
• Your consent to the use of your Personal Information for such purposes(s) remains valid after termination of Booths relationship with you to the extent permitted by applicable law so long as you do not request otherwise.

Security of personal Information

• Please take care to keep any username, password, and/or other identification information confidential, and do not disclose or share this information with anyone. Where you do disclose such information, you are solely responsible for all activities undertaken on your account. If you are using a public computer, we strongly encourage you to sign out when you’ve finished. 

WEBSITE USE

Booths may store or process personal data submitted voluntarily by visitors on our websites. By submitting personal information, the visitor consents to the use of that data for the purpose of processing enquiries, responding to requests, improving our services, sending answers, news messages and/or other information, whether or not on a regular basis. If you do not want your personal data to be stored or processed, please do not submit it to us.

Any communication or material you transmit via our websites, or the webmaster will be treated as non-confidential and non-proprietary. Included without limitation in the non-confidential and non-proprietary materials transmitted to our websites are suggestions, ideas and comments. Booths is entitled to unrestricted use of any communication or material transmitted to our websites, for any purpose whatsoever, commercial, or otherwise, without compensation to the provider of the submission.

EXTERNAL SERVICE PROVIDERS

We sometimes employ and share your personal data with trusted third-party companies and individuals.

These third parties may be given access to your Personal Information to perform tasks on our behalf. They are obligated through contract not to use your Personal Information for any other purpose or to disclose your Personal Information to any additional third party without our express consent.

To keep your data safe and protect your privacy:

• We provide only the relevant 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 always protected.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

The kind of third parties we may work with:

• IT, hosting and infrastructure companies who support our website and other business systems.
• Operational companies such as delivery couriers and fulfilment centres.
• Marketing companies who help us manage our electronic communications with you and print, process and distribute your Booths card materials and vouchers
• Search engines and social media network to show you products that might interest you whilst browsing the internet.
• Data insight companies to support customer research projects and ensure your details are up to date and accurate.
• Professional advisers including lawyers, bakers, auditors and insurers who provide services to us.

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or 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 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 take the privacy of our customers into consideration.

In the event that we buy or sell any business and/or assets we may disclose your personal information to the prospective buyer or seller of the business and/or assets.

LIVE FACIAL RECOGNITION TECHNOLOGY

Live facial recognition technology is in operation within our stores. Booths takes the safety and security of colleagues and customers very seriously. Our primary aim for introducing this technology is to enhance the safety and security of our colleagues and customers along with reducing the overall level of crime within Booths’ locations. The system scans every face that visits store and makes a comparison against a Person of Interest (POI) Watchlist. The system instantly deletes the image where no match is found. The system does not store this image and this image cannot be stored, retrieved or reverse engineered. Only those who have committed criminal activity (i.e. physical violence, threats of violence, theft, fraud, property damage) on a Booths site will be added to the POI Watchlist. No images will be added to the POI Watchlist from any other external source (i.e. Police, other retailers etc). Those added to the watchlist are done so for 12 months from the date of their last offence committed on a Booths site. After this time has elapsed, and there have been no further incidents then they will be removed from the POI Watchlist. Please contact centralservices@booths.co.uk for further questions.

PRIVACY POLICY CHANGES

This Privacy Policy, together with our Terms & Conditions may change from time to time. We will update any changes to this Privacy Policy here, and, if the changes are deemed significant, we will provide a more prominent notice to you by email, post or similar.

CONTACTING THE REGULATOR

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 data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concern

This Privacy Policy was last updated in August 2024.