Who we are
Morgan’s Direct we are committed to protecting and respecting your privacy.
For the purpose of and thereafter the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) as amended, supplemented or replaced from time to time (“Data Protection Law”), the data controller is Morgan’s Direct Limited, with registered number GB173310731 and registered address Morgan’s Direct Limited, Morgan’s Direct, Unit 12, Kingsbury Trading Estate, Church Lane, London, NW9 8AU.
1. Information we collect from you
We will collect and process the following data about you:
1.1. Information you give us.
This is information about you that you give us by filling in forms on our website (“our site”) or any forms hosted by third-party partners or by corresponding with us by phone, e-mail or otherwise, and while you are in-store. It includes information you provide when you register to use our site, open an account, sign up for a Morgan’s Direct account, subscribe to our service, subscribe to our mailing list, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information. If you provide any information about any other individuals such as friends, family or colleagues, you warrant to us that you are entitled to provide that information to us and to authorise us to process it on the same basis as we will process the rest of the data you provide about yourself.
1.2. Information we collect about you.
With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, language setting.
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products and categories you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
- We collect this personal data by using cookies, server logs and other similar technologies.
- The tracking technologies we or our selected third parties use for automated data collection may include:
- Cookies (or browser cookies): Like many other sites, we use “cookies,” which are small files placed on the hard drive of your computer. Cookies help us to identify account holders and to optimize their shopping experience. (See Section 2 Cookies).
- For our website – Our Cookies and other tracking technologies (above) also allow us to hold selections in a shopping cart when a user leaves the Web Site without checking out, track an order, track an order number/value or track purchases through the website.
- Within our emails – help us to understand a little bit about how you interact with our emails and are used to improve our future email communications. If you have configured your computer to automatically display images, or if you have added us to your email “address book” (or “safe senders” list), or if you have configured your computer to have “weak” security, cookies might be set at the same time as you download, open or read an email from us. If you would prefer for this not to happen, you should disable the automatic displaying of images, or remove us from your address book or strengthen your security settings.
- Web Beacons: Pages of the Web Site and our emails may contain small electronic files known as web beacons (also referred but not limited to clear gifs. pixel tags and single-pixel gifs).
- For our website – that permit us, for example, to count users who have visited those pages or opened an email and for other related Web Site statistics (for example, recording the popularity of certain Web Site content and verifying system and server integrity).
- Within our emails – that tells us whether you have opened an email, how often you have opened it, how you interacted with the email (such as the time you spent reading the email), which email software and web browser you used, which device you used and your IP address. We also use web beacons to help us display emails in the best format for your device.
- We utilize web beacons to help us better manage the content on the Web Site and the Email we send to you by informing us what content is effective.
- Link Tracking: Our emails contain a number of hyperlinks, each of which has a unique tag. When you click on one of these links you will be automatically redirected to the server of our mailing company which logs the click. From there you will be redirected to the relevant page on our website. This process enables us to understand who has clicked through from an email to visit our website. We use this information to tailor future messages to you.
Regarding newsletter emails you sign up to receive from us, each email collects:
- Information about you, using industry-standard technologies including pixels which will track email opens (if you have images enabled in your email client/mailbox). This is the standard approach for measuring open and click rates and is used by all email platforms in the market.
- All links in emails are proxied through a link redirection service that records data for each link clicked. This leads to a set of events which includes:
- Event type (delivery, bounce, open, click, spam complaint, unsubscribe)
- Email address of the recipient (which you will have provided)
- IP address of the recipient (in the case of open and click)
- GEO location based on IP address (city-level) (in the case of open and click)
- Device type (mobile/computer/tablet) and browser (i.e/firefox/chrome/safari).
If you do not want this information to be collectable, you should disable and not open images in your email application.
1.3. Information we receive from other sources.
We receive information from other sources in order that we can fulfil your order. This will include courier and payment card services.
2. Cookies and Similar Tracking Technologies
3. Purposes for which we may process the information.
We use information held about you in the following ways:
3.1. Information you give to us.
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to update you with regard to the progress of orders that you have placed;
- to resolve any queries you may have regarding orders that you have placed;
- to initiate any product recalls or provide any important information to you relating to products that we supply;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you with information about our goods or services we feel may interest you. If you are an existing consumer customer, we will only contact you by electronic means (e.g. e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you unless you have consented to receive wider communications. If you are a consumer and are not an existing customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for our marketing purposes, please tick the relevant boxes situated on the form on which we collect your data or notify our in-store staff accordingly when they attempt to collect your information;
- to notify you about changes to our products or services;
- for fraud prevention;
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- to make decisions as to whether and on what terms to offer credit;
Please note that where you are asked to provide information to us which is of a sort that is necessary to enable us to perform a contract or fulfil a request that you make (e.g. contact, delivery or payment information) it is a requirement for us to enter and perform such a contract or fulfil your request that you provide that information – if you do not do so, we may not be able to perform your contract or fulfil your request.
3.2. Information we collect about you.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
4. Disclosure of your information
4.1. You agree that we have the right to share your personal information with:
4.1.1. Selected third parties including:
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- marketing partners to send emails on our behalf, and/or for co-branded and/or co-sponsored marketing and promotional events (such as conference events) offered in conjunction with another company or companies. If you register for or participate in such marketing and promotional events, we and the relevant partner companies may receive information collected in conjunction with the co-branded and/or co-sponsored marketing and promotional events. Our Privacy Notice will apply to our use of your personal information. We have no control over any other companies’ privacy practices, so please read their applicable privacy.
- to our third-party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Online Properties), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- Verified by VISA and Mastercard® SecureCode™ are new services from VISA and Mastercard in association with your card issuer to provide added protection when you buy online. There is no need to get a new card, you just need to choose your own personal code for your existing card. This information is never shared with any of the retailers or merchants. It is a private code that means added protection against unauthorised use of your credit or debit card when you shop online. This should not be confused with your normal pin number that you use when shopping in the high street or when using cash machines. To choose your new code, you will need to register by following the website links provided below.
4.2. Additionally, we may disclose your personal information to third parties:
4.2.1. If we outsource any aspect of our business or systems, then we may disclose your personal data to our service provider(s).
4.2.2. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
4.2.3. If we or a substantial part of our assets are acquired by a third party, in which case personal data held by us about our customers may be one of the transferred assets.
4.2.4. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the terms of any agreement or policy to which we are a party, or to protect the rights, property, or safety of our business, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Legal basis of processing
5.1. Data Protection Law requires us to meet at least one “legal ground” for processing, currently set out in Article 6 of the General Data Protection Regulation. The grounds applicable to the personal data to which this notice relates are:
5.1.1. Where the processing is necessary for us to perform a contract that you are party to, or to take steps at your request prior to entering a contract, that is the ground on which we are processing that data;
5.1.2. Where the processing is necessary for compliance with a legal obligation to which we are subject, that is the ground on which we are processing that data;
5.1.3. Where processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, that is the ground on which we are processing that data, provided that your fundamental rights and freedoms which require protection of your data override those legitimate interests (our legitimate interests comprise the management, marketing and promotion of our business, products and services, and the supply of our products and services);
5.1.4. If you have given your consent to our processing the data, that is the basis on which we are processing that data. If more than one of the above grounds apply to the processing of data in question, the applicable ground will be the one that is set out first above.
6. Where we store your personal data
6.1. The data that we collect from you will be stored on our servers or those of our service providers. It will not be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”) unless:
6.1.1. to one of our group undertakings to which section 4.1.1 above applies; or
6.1.2. to a processor acting on our behalf which is either (i) within the EEA, or (ii) in a country that the European Union has decided has adequate data protection laws in place, or (iii) has provided appropriate data protection safeguards of the sort approved by the European Union and provide effective rights and remedies for you.
6.2. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential, and for all use made of your account with such password. We ask you not to share a password with anyone.
Payment services providers for the purposes of authorising funding of the orders you place. We do not store your payment (debit or credit) card data in our systems, all data is securely transmitted to our service providers, after which we store limited transactional data such as authorisation codes which we keep along with your order information. If you use PayPal or the PayPal Pay in 3 service your browsing session is securely passed over to PayPal, who provide us with authorisation code when you return to our site to complete your order. We have no visibility of your PayPal account or your interaction with PayPal.
Verified by VISA and Mastercard® SecureCode™ are new services from VISA and Mastercard in association with your card issuer to provide added protection when you buy online. There is no need to get a new card, you just need to choose your own personal code for your existing card. This information is never shared with any of the retailers or merchants. It is a private code that means added protection against unauthorised use of your credit or debit card when you shop online. This should not be confused with your normal pin number that you use when shopping in the high street or when using cash machines. To choose your new code, you will need to register by following the website links provided below.
When shopping on our website, if you card is eligible for these schemes (currently only available on credit cards but not debit cards), you may see a pop-up window appear when you are at the checkout. This pop up will be provided by the bank that issued the card you are making payment with. If you have not already registered your card, you can use this pop up and follow the instructions to register securely. Once registered, you will be taken back to the Morgan’s Direct website to complete your order. If you are at all concerned or confused, simply close the pop-up window, and complete your order as normal, then contact your bank to find out more about the schemes. Once registered, you will then be required to use your personal code on all subsequent online transactions.
These services are effectively the online equivalent of chip & pin, which is the only secure way to shop in the high street. By replicating this high street security, Morgan’s Direct is providing you with a secure and safe online shopping service.
If you would like to learn more about these services, please click on the links to the relevant websites:
- If you use Mastercard: mastercardsecurecode.com.
- If you have a VISA debit or credit card: visa.co.uk/how-you-pay-matters.html.
6.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Length of data storage
Our policy is to ensure that personal data is only stored for as long as is necessary for the purposes set out at section 3 above. This may vary according to the type of information and the specific applicable purpose(s). We have a detailed data retention and destruction policy which governs the length of time for which we hold your data in personally identifiable form. The timing of our retention, anonymisation and/or destruction of your personal data is determined according to the criteria set out in that policy. We can provide you with relevant details applicable to your data on request – please see section 8.2 below as to how to request this information.
8. Your rights
8.1. You have various rights under Data Protection Law. These include:
8.1.1. The right to ask us not to process your personal data for direct marketing purposes (electronic and postal), even if you have given consent;
8.1.2. If our processing is based on your consent, the right to withdraw any consent you may have given for our processing of your data – if you exercise this right, we will be required to stop such processing if consent is the sole lawful ground on which we are processing that data;
8.1.3. The right to ask us for access to the data we hold about you (see section 9 below for further details);
8.1.4. The right to ask us to rectify any data that we hold about you that is inaccurate or incomplete;
8.1.5. The right to ask us to delete your data in certain circumstances;
8.1.6. The right to ask us to restrict our processing of your data in certain circumstances;
8.1.7. The right to object to our processing of your data in certain circumstances;
8.1.8. In certain circumstances, the right to require us to give you the data we hold about you in a structured, commonly used and machine-readable format so that you can provide the data to another data controller.
8.1.9. You have the right not to be subject to a decision based solely on automated processing. This includes decisions based on profiling. If you choose to exercise this right, then you will no longer receive offers from us as we base our mailing list on our customers’ purchase history.
8.2. You can exercise any of the rights set out above, free of charge. In respect of certain of the rights referred to above, your right may be qualified by the GDPR (which we will discuss with you following your request) or we may need more information from you, which we will ask you for following your request. We may ask you to provide further information in order to confirm your identity. Please also note that if you submit unfounded or excessive (for example repetitive) requests to exercise any of these rights, we reserve the right to make a reasonable charge for providing the requested information or taking the requested action, or to decline your request.
8.3. You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you are concerned that we are not respecting your rights under Data Protection Law. The Information Commissioner’s Office is the authority in the UK which is responsible for overseeing the application of and enforcing, Data Protection Law.
9. Accessing your data
You have the right to obtain from us:
9.1. Confirmation as to whether we are processing (including holding) personal data about you; and
9.2. If we are processing personal data about you, you are entitled to be provided with:
9.2.1. Information as to the purposes for which we process the data;
9.2.2. Information as to the categories of the data that we are processing;
9.2.3. Information as to the recipients or categories of recipients to whom the data has or will be disclosed;
9.2.4. Information as to the envisaged period for which we will store the data, or the basis on which that period will be determined;
9.2.5. A copy of the data (further copies are available at a reasonable charge, which we will inform you of should you request further copies). Please note that this right is subject to the rights of others in relation to their own personal data, meaning that we cannot disclose data to you if it would involve disclosing data about someone else.
9.3. Please see section 8.2 above as to how to exercise your rights under this section 9. Section 8.2 applies in full to the exercise of these rights.
10. Other websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
11. Changes to this privacy notice
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org.