Privacy Policy & Cookies

Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.

When you are using the Lulu Francis website, Curtains by Design (Warwickshire) Limited is the data controller.

Lulu Francis is a UK based company and therefore, when visiting our website, personal data that we may collect through cookies or online forms will leave the EU for the UK.

Explaining the legal bases we rely on

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

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive email newsletters.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

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

For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.

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 the company to law enforcement .

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might 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 will also send you direct marketing emails when you shop with us and do not
choose to opt out – this is often called a ‘soft opt in’

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

We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

We may contact you regarding market research

With your consent, or when you shop with us and do not choose to opt out from receiving our emails (‘soft opt in’) 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 and so on. This is only applicable in the UK.

When do we collect your personal data?

When you visit any of our websites, and use your account to buy products and services.
When you create an account with us.
When you shop online, we capture information through cookies and similar technologies, you can manage these when you visit our site.
When you engage with us on social media.
When you contact us by any means with queries, complaints etc.
When you ask us to email you information about a product or service.
When you enter prize draws or competitions.
When you choose to complete any surveys we send you.
When you comment on or review our products and services.
When you’ve given a third party permission to share with us the information they hold about you.

What sort of personal data do we collect?

If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
Details of your interactions with us via phone or email.

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us.

Details of your visits to our websites or apps, and which site you came from to ours.
Information gathered by the use of cookies in your web browser. See below for further details about Cookies.
Your comments and product reviews.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

To process any orders that you make by using our websites, apps or in store. If we don’t collect your personal data during checkout, we won’t be able 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, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.

To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we 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 send you email notifications when you place a product in your basket and you abandon your browsing before completing your checkout. We do this based on our legitimate interest. To provide you with tracking information so that you can follow your order. We do this under legitimate interest to enhance your customer experience and give you more information around where your delivery is and when your order will arrive.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.

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

To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
With your consent, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK.

Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.

You are free to opt out of hearing from us by post at any time.

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, 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 or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. If not through the use of cookies or similar technology, then on the basis of our legitimate interest.

For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law

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.
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

When you purchase a product from us that is delivered by the manufacturer or supplier of said product, we will pass on your contact details so that they can deliver your purchased product. The same with regard to warranties provided by the manufacturer or supplier of the product you bought.

If the manufacturers or suppliers wish to pass your details to other third parties, or use it for other purposes, they must provide you with sufficient information about whom they share your personal data with, and for what purposes they intend to use it, and in some cases they may be required to ask for your consent to do so. If they do not provide you with that information or collect your consent, and you are worried that they may have shared your personal data with someone else, you are entitled to contact them directly for clarification.

How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

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

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

How long will we keep your personal data?

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

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

Some examples of customer data retention periods:

Orders

When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.

Warranties

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

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, delivery couriers, technicians visiting your home, for fraud management, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe 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 are:

IT companies who support our website and other business systems.
Operational companies such as delivery couriers to contact you about your order delivery & occasionally service review messages

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

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.
We may, from time to time, expand, reduce or sell the company 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 Notice.
For further information please contact our Data Protection Officer.

Where your personal data may be processed

Lulu Francis is a UK based company and so we will transfer your data to the UK, which is outside of the EU. We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

Protecting your data outside the UK

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK.

For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.

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

What are your rights over your personal data?

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
The deletion of the data we hold about you, in specific circumstances; 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).
A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by the company of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time by emailing privacy@lulufrancis.com
If we choose not to action your request, we will explain 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, such as administration of an extended warranty.

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 Notice.

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.

How can you stop the use of your personal data for direct marketing?

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

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails.
If you have an account, log in into your account and change your preferences.
Email us privacy@lulufrancis.com

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

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/concerns (opens in a new window; please note we can’t 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.

Any questions?

We hope this Privacy Notice 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 haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us at privacy@lulufrancis.com

How do I manage my cookies?

You can use this link to manage your cookie preferences for our website at any time. Alternatively, you can set your browser to block cookies. Please check your browser for instructions on how to do this.

How do you use cookies?

We use cookies, which are small text files, to improve your experience on our website and to show you personalised content.

What happens if I disable cookies?

If you disable cookies, that will mean that your experience of using our website won’t be to its full potential, as some of the cookies help us to identify and resolve errors or
display relevant content.

Most browsers have cookies enabled, but see the ‘How do I manage my cookies?’ section to turn them on or off should you need to.

What are cookies?

Cookies are tiny text files stored on your computer when you visit certain web pages. At johnlewis.com we use cookies to keep track of what you have in your basket, and to remember you when you return to our site.

To find out more, please check What are cookies (opens in a new window; please note that we can’t be responsible for the content of external websites).

If you don’t wish to enable cookies on your computer, that will mean that your experience of using our website site will be impaired – as some of the cookies help us to identify and resolve errors for example, or determine relevant related products to show you when you’re browsing. Most web browsers have cookies enabled, but see the Managing cookies section for help to turn them on should you need to.

We do have relationships with third parties who may also set cookies during your visit to be used for remarketing purposes – in other words to show you different products and services based on what you appear to be interested in. If you’d like to opt out, please go to the Network Advertising Initiative website (opens in a new window – please note that we’re not responsible for the content of external websites).

Can I enable ‘Do not track’?

Do not track (DNT) is a feature offered by some browsers, with some newer browsers offering it as default. It sends a signal to websites to request that your browsing isn’t tracked by third party ad, social networks or analytic companies.

You can opt out of tracking and analytics on this website by changing your settings in the ‘How do I manage my cookies? section.

Our website doesn’t currently respond to DNT requests as there’s no industry-wide uniform standard to how DNT requests are managed. We’ll continue to review DNT and other new technologies, but won’t respond to DNT requests.

We’re giving you this information as part of our initiative to both comply with legislation, and make sure we’re honest and clear about your privacy when using our website. We know you’d expect nothing less from us, and please be
assured that we’re working on a number of other privacy and
cookie-related improvements to the website.

What happens when I share on Social Media platforms?

If you ‘share’ lulufrancis.com content on social networks, such as Facebook and Twitter, you may be sent cookies from these websites. We don’t control the setting of these cookies, so please check the third-party websites for more information about how to manage them.

Any further information about cookies?

If you’d like to learn more about cookies in general and how to manage them, aboutcookies.org. If you’d like to opt out of cookies, please go to the Network Advertising Initiative website (opens in a new window, we aren’t responsible for the content of external websites)

This notice was last updated on 27/7/22