We understand how important it is that we keep your personal data safe and only use it in appropriate ways. Your personal data includes all the information we hold that identifies you or is about you. More information about the types of personal data we process about you is set out below.
2. Who are we?
We are Berens Group Limited. We are registered in England with registered company number 11303433 and our address is 62 Albion Street, Leeds, West Yorkshire LS1 6AD. We trade as Berry’s Jewellers and include Jeffrey Walton Jewellery personnel within this Policy.
We have appointed Simon Oxby as privacy officer and he will have day to day responsibility for ensuring we comply with the Data Protection Laws and dealing with any requests we receive from individuals exercising their rights under the Data Protection Laws.
3. What laws apply to our processing of your personal data
When we process your personal data, we are required to comply with the UK GDPR and the Data Protection Act 2018, together with any other applicable data protection and privacy legislation (together referred to as the “Data Protection Laws”).
4. What type of information do we process?
Your personal data includes all the information we hold that identifies you or is about you, including but not limited to:
your name, email address, postal address, date of birth, location data, records of enquiries you have made;
details of transactions you carry out in a shop or through our websites and of the fulfilment of your orders;
any personal data included in reviews that you leave for us, whether online or otherwise.
We do not process any of your payment information. When you provide your credit or debit card details to us, it is encrypted so that Berens is unable to access the data and is then passed to secure third-party payment gateway providers.
We process most of your information on the grounds of fulfilment of our contract with you, namely to confirm your order, contact you about delivery, arrange for your payment to be processed and provide you with the products you have purchased. We may also use your personal data for our legitimate interests, including for the purposes of fraud prevention and for customer service training and quality.
b. Website Visitors
Where you have provided your consent for us to do so, we use the following tools on our website:
Email Pixels – tracking pixels will record your interactions with our emails and website, including whether you have opened a particular email, or which pages you visit on our website. We use this information to personalise emails and to ensure they are relevant to the recipient as well as for website analytics purposes;
Meta Pixel -
Most pages of our website contain a pixel from Meta, aka Facebook. These pixels record website activity and allow us to show adverts to browsers who have visited a specific page or taken a desired action on our website. They can also help us to measure the impact and success rate of our adverts.
you may see advertisements for Berens’ products on other websites including Facebook and Google; and
we may use Google’s customer match process to help us reach and re-engage with you and or other customers
c. Suppliers, Business Contacts and Visitors to our Premises
If you work for one of our suppliers or are one of our business contacts, we usually process your name and business contact details, such as your business email address and phone number and the address of your organisation. We process the information on the grounds of our legitimate interests in maintaining our relationship with you.
We use CCTV in and around our premises for the purposes of crime prevention, detection and security. We retain CCTV images for up to 31 days from the date the footage is captured, unless it is relevant to an accident, crime or other incident in which case we retain it for as long as is necessary in relation to the accident, crime or incident.
If you apply for a job vacancy with us, or speculatively send us your CV, the personal data that we are likely to process about you includes:
identity data such as your first name, middle names, last name, marital status, title, date of birth and gender;
contact data such as your postal address, email address and telephone numbers;
background data such as your education, career background and work experience;
personal information such as your skills and qualities; and
any other information that you include on any CV, application or covering letter you send to us.
We process your information on the grounds of our legitimate interests to determine whether or not we have a suitable vacancy for you. To the extent we need to process special categories of data about you (for example, to ensure our premises are suitably equipped for you if you attend for an interview), we will do so in accordance with our legal obligations. If you provide special categories of data to us which we have not requested, we will process it on the grounds of your consent because you have voluntarily provided the information to us.
5. Our collection of your personal data
a. Customers, Suppliers and Business Contacts
We use different methods to collect data from and about you including through:
You may give us your personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: place an order for our products or services; submit a query about our products or service whether on our website or by email or phone; request for marketing to be sent to you; or give us feedback or contact us.
Automated technologies or interactions
We receive personal data directly from you when you contact us in respect of a specific vacancy or with a speculative approach. We may also receive information about you from recruiters and agencies that provide temporary workers.
6. Who will receive your personal data?
We only transfer or make your personal data available to the extent we need to. The recipient of your personal data will depend upon what we are doing (for example, if you wish to take advantage of a credit plan, we will need to contact financial institutions and credit reference agencies to authorise your application). Recipients of your personal data may include:
third party e-commerce platform providers including Shopify;
third party payment processors;
third party software providers, including the provision of online forms used on our website and stock notification providers;
third party email distribution providers and market research companies. Please note your personal data will only be processed for marketing purposes in accordance with the section below headed “Marketing”;
third parties that assist with our customer satisfaction surveys and reviews;
third parties that assist with updating our customer databases;
banks and other financial institutions;
credit reference agencies;
personal finance companies and organisations that assist with the integration between Berens and external personal finance companies;
business partners, suppliers and sub-contractors that are necessary for us to provide the services that you have requested;
Google, Facebook and other websites if we have your consent to the transfer – more information is set out above in the section entitled “Website Visitors”;
legal, financial and other professional advisors to the extent they need access to your personal data to provide us with advice; and
We don’t transfer your personal data outside of the EEA.
7. How long will we keep your personal data?
Please note that if we send you marketing communications and you unsubscribe from those communications we will retain your details on our suppression list indefinitely to ensure we do not re-commence sending you marketing unless you ask us to do so.
We will retain details of any purchases you make from us for 7 years after the date of purchase. We retain your information for this period to enable us to deal with returns, repairs and warranties and in case any issues arise or in case you have any queries. Your information will be kept securely at all times.
Following the end of the relevant period, your files and personal data we hold about you will be permanently deleted or destroyed or anonymised so that it is no longer personally identifiable.
b. Suppliers and Business Contacts
Your personal data is retained for the duration of our relationship with you or the organisation for which you work. Please let us know if you leave the organisation or if your details change. If we receive notification from you or your organisation that you no longer work at that organisation, or if we no longer maintain a working relationship with your organisation, we will delete your information from our system.
If we are corresponding with you as a potential supplier, we will retain your details until we receive notification from you or your organisation that you no longer work at that organisation or until we no longer correspond with the organisation for which you work.
We particularly want to draw your attention to our use of your personal data to send you information about promotional offers, new products and events at our shops.
If you have made a purchase from us, we may send marketing communications to you on the basis of our legitimate interests. We will also send marketing communications to you if you have indicated that you would like to receive updates from us, irrespective of whether you have purchased products from us. You may opt out at any time, either by clicking on the unsubscribe option in one of our emails, speaking to a member of our staff in one of our stores, by writing to us at 62 Albion Street, Leeds, West Yorkshire LS1 6AD (FAO The Privacy Officer), or by emailing us at email@example.com. We will cease sending you online marketing communications no later than 24 months after your last interaction with us.
Our marketing communications may promote products and services offered by our group companies (detailed above) if we have received your consent to do so, however, we never provide your personal data to any other third parties for them to market to you.
We may also send you service related emails if, for example, you have tried to purchase a product from our website but your payment has failed, as well as receipts and updates on your order.
9. What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data. There are certain caveats and exemptions to those rights which mean that in some circumstances you may not be entitled to exercise them. If we believe that is the case upon receipt of a request from you we will let you know.
a. Access to your data
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
b. Rectification of your data
If you believe personal data, we hold about you is inaccurate or incomplete, you can ask us to rectify that information.
We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case, we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
c. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you.
This right is available to you:
where we no longer need your personal data for the purpose for which we collected it;
where we have collected your personal data on the grounds of consent and you withdraw that consent;
where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
where we have unlawfully processed your personal data (i.e., we have failed to comply with GDPR); and
where the personal data has to be deleted to comply with a legal obligation.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
d. Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it.
This right is available to you:
if you believe the personal data, we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
if the processing is unlawful; or
if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
e. Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller.
This right only applies to personal data you provide to us:
where processing is based on your consent or for performance of a contract (i.e., the right does not apply if we process your personal data on the grounds of legitimate interests); and
where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
f. Right to object
You are entitled to object to us processing your personal data:
if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
for direct marketing purposes (including profiling); and/or
for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
10. Automated decision making
Automated decision-making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).
We don’t carry out any automated decision making using your personal data.
11. Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, please get in touch with us so we can help. You can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.
12. Any questions?
If you have any questions or would like more information about the ways in which we process your data, please contact firstname.lastname@example.org.