For the purpose of the Data Protection Act 2018 (the Act), the data controller is MP Moran & Sons Ltd, 293-301 Kilburn High Road, London NW6 7JR.
Information we may collect from you
We may collect and process the following data about you:
- Location (IP address)
- Contact details (email address and phone number)
- Your correspondence and communication history with us
- Transactional history
- Marketing preferences
- Payment card
- Shopping habits with us
- CCTV imagery (in-store)
How we use your data
MP Moran & Sons Ltd will use the information:
- in order to provide you with the goods and services
- to manage your online/credit accounts with us
- to verify your identity
- for fraud prevention detection
- to tailor our website for an enhanced shopping experience
- in Customer services related enquiries
- in sending you related marketing emails (with your consent)
- for marketing purposes, to better understand your shopping behaviour (assuming you accept cookies)
- to notify you about changes to our service (with your consent)
- in circumstances where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
Please refer to our separate Cookies Policy at: https://www.mpmoran.co.uk/cookie-policy
Cookies themselves contain no personally identifiable information. Depending on the publisher’s and user’s settings, information associated with cookies used in advertising may be added to the user’s Google Account.
If a user opts out of ads personalisation using Google’s Ads Settings, they will no longer receive personalised advertising from Google.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where you have chosen an account password, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to best prevent unauthorised account access.
You have the following rights:
- right of access (to ask for a copy of personal data that we hold about you)
- right of erasure or to be forgotten the (to request that we delete personal data held on you in circumstances where we no longer have any legal reason to retain it)
- right of rectification (to ask us to update and correct any out-of-date or incorrect personal data that we hold about you)
- right to object (to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so)
- right to restrict processing (under certain circumstances you may ask us to secure and retain the data for your benefit but not otherwise use it
If you wish to exercise any of the above rights, please contact us at MP Moran & Sons Ltd, 293-301 Kilburn High Road, London or email us at email@example.com
Third party links
Our site may, from time to time, contain links to and from third party websites, namely the websites of our partner networks, informational videos and affiliates. If you follow a link to any of these websites, please note that these websites have their own terms and privacy policies and that we do not accept any responsibility or liability for these policies.
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 7 years.
To register with us you must be 18-years of age or older.
We understand that your privacy and the security of your personal information is extremely important. This notice sets out what we do with your personal information, what we do to keep it secure, from where and how we collect it, as well as your rights in relation to the personal information we hold about you.
This policy applies if you interact with us through our stores, over the phone, online or otherwise by using our website or interacting with us on social media.
If you don’t want to read all the detail, here are the things we think you’d really want to know:
- You have a number of rights over your personal information. How you can exercise these rights is set out in this notice.
- We do send direct marketing, if we’re allowed to. And we do this to encourage you to buy our products and services by sending you offers and ideas that we feel will be of benefit to you. If you want us to stop then email us at firstname.lastname@example.org.
What sorts of personal information do we hold?
- Information that you provide to us such as your name, address, date of birth, telephone number, email address, bank account and payment card details and any feedback you give to us, including by phone, email, post, or when you communicate with us via social media
- Information about the services that we provide to you (including for example, the things we have provided to you, when and where, what you paid, the way you use our products and services, and so on)
- Information required to make decisions about your application for credit such as your employment details, financial position, information taken from identification documents such as your passport or driving licence
- Your account login details for our website or customer portal, including your user name and chosen password
- Information about whether or not you want to receive marketing communications from us
- Information about any device you have used to access our Services (such as your device’s browser or IP address) and also how you use our Services. For example if you use our website, we try to identify when and how you use it
- Your contact details and details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We want to make sure that our communications are useful for you, so if you don’t open them or don’t click on any links in them, we know we need to improve our Services and
- Information from other sources such as specialist companies that provide customer information like credit reference agencies such as Experian.
Whenever we process your personal information we have to have something called a “legal basis” for what we do. The different legal bases we rely on are:
- Consent: You have told us you are happy for us to process your personal information for a specific purpose;
- Legitimate interests: The processing is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights.
- Performance of a contract: We must process your personal information in order to be able to provide you with one of our products or services
- Prevention of fraud: Where we are required to process your data in order to protect us and our customers from fraud or money laundering
- Public information: Where we process personal information which you have already made public
- Legal claims: The processing of your personal information is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity and
- Legal obligation: We are required to process your personal information by law.
How do we use your personal information?
There are a number of ways in which we use your personal information, depending on how you interact with us. If you do not provide your information to us, then we will be unable to interact with you in that way – for example, if you do not provide your name, address and account details when purchasing one of our products online, we will not be able to sell you that product as we would be unable to process your payment or deliver the product to you.
We may use your information in the following ways:
- To provide our products and services - we need to use your personal information to make our products and services available to you. If you then decide to order any of our products or services then we’re delighted. After that, we need to provide them to you and process your payment. And we need to use your details to do this.
- To personalise your shopping experience - we try to understand our customers so we can provide you with a great shopping experience, relevant marketing, personalised offers, shopping ideas and online advertising. Understanding the products and services you buy and how you use and browse our website helps us to do this.
- For safety and security - we use your personal information to help provide safe and secure environments for our colleagues to work in, our customers to shop in and for our businesses to be conducted. To enable this we use CCTV monitor in store behaviour and carry out checks to help us ensure that our customers are genuine to prevent fraud and to help customers use our services appropriately.
- Analytics and profiling - we use your personal information for statistical analysis and to help us understand more about our customers. That includes understanding the products and services you buy. This helps us to serve you better and to find ways to improve our services, stores, apps and websites. These profiles help us to send you offers that are more relevant to you.
- Contacting you - we use your personal information to contact you: either to conduct market research or to contact you about products and services from us. We may also contact you in relation to any questions you have raised with us or to discuss the status of your account with us.
Cookies and similar technologies
Who might we share your personal information with?
Our service providers
We work with partners such as credit reference agencies so that they can help us provide the products and services you require from us. These third parties process your personal information on our behalf and are required to meet our high standards of security before doing so. We only share information that allows them to provide their services to us or to facilitate them providing their services to you.
We may monitor and record information relating to your trade performance and such records will be made available to credit reference agencies, who will share that information with other businesses in assessing applications for credit and fraud prevention.
- Our agents, advisers or others involved in running accounts and services for you and your business or collecting what you or your business owe Group companies.
- Credit reference agencies
- Market research partners, who help us to analyse customer behaviour;
- Social media providers – such as Facebook, Instagram, Linked in and Twitter – where we interact with you on social media;
- Third party vendors who help us to manage and maintain the IT infrastructure;
- Logistics and delivery providers who enable us to deliver products you order on our websites;
- Providers of temporary staff, who need access to certain personal information to carry out their role within the business;
- Where relevant, our professional advisors, such as lawyers and consultants;
- Companies that deploy our email campaigns for us because they need to know your email address to carry out these services;
- Companies that provide insights and analytics services for us so we can stock the right products, send the right marketing campaigns and understand our business and customers better;
- Security and fraud prevention companies to ensure the safety and security of our customers, colleagues and business;
- Companies who assess faults and repair products on our behalf;
- Companies that enable us to collect your reviews and comments, both online and offline
Other organisations and individuals - we may share your personal information in certain scenarios. For example:
- If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide the Services to you.
- If we are required to by law, under any code of practice by which we are bound or where we are asked to do so by a public or regulatory authority such as the police.
- If we need to do so in order to exercise or protect our legal rights, users, systems and services; or
- In response to requests from individuals (or their representatives) seeking to protect their rights or the rights of others. We will only share your personal information in response to requests which do not override your privacy interests. For example, we will not share your personal information with individuals who are merely curious about you, but we will share your personal information to e.g. insurers, solicitors, employers etc. which have a legitimate interest in your personal information.
What we do with the information you supply to us as part of the application:
- Information that is supplied to us will be sent to the credit reference agencies;
- If you tell us that you have a spouse or (personal) partner, we will:
- Search, link and/or record information at credit reference agencies about you both;
- Link joint applicants and/or any individual identified as your spouse or partner, in our own records;
- Take both your personal information and your personal partner’s personal information (if you have one) into account in future applications by either or both of you; and
- Continue this linking until the account closes, or is changed to a sole account and one of you notifies us that you are no longer linked,
So you must be sure that they are aware you are disclosing personal information about them to us for this purpose.
- If you give us false or inaccurate information and we suspect fraud, we will record this and may also pass this information to financial and other organisations involved in fraud prevention to protect us, them and our respective customers from theft and fraud.
- With the information that we obtain we will:
- Assess this application for credit;
- Verify your identity and the identity of your spouse/partner;
- Undertake checks for the prevention and detection of fraud and/or money laundering;
- Manage your personal account with us; and
- Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future Services, any or all of these processes may be automated.
What we do when you have an account:
- Where you borrow or may borrow from us, we will give details of your personal account including names and parties to the account and how you manage it to credit reference agencies
- If you fail to repay in full or on time, we will tell credit reference agencies
- We may make periodic searches of our records, credit reference and fraud prevention agencies to manage your account with us, to take decisions regarding your identity and also credit, including whether to make credit available or to continue or extend existing credit, or to close your account if it is dormant or you are no longer resident in the UK
- If you have a credit account with MP Moran and do not make payments that you owe us, we will trace your whereabouts to recover payment (where appropriate, this may be carried out by third party debt collection and recovery agencies on behalf of MP Moran) – this may result in us sending notices to an address that our tracing agents tell us you have moved to
- In order to comply with money laundering regulations, there are times when we need to confirm (or reconfirm) the name and address of our customers.
If you apply for a credit account with MP Moran & Sons Ltd, we will perform searches with credit reference agencies. We may give details of your account and how you conduct it to credit reference agencies. If you fail to repay your account in full and on time, we may inform credit reference agencies who will record the outstanding debt.
The information below provides further details about how credit reference agencies, us and other lenders use your information.
- Q: What is a credit reference agency?
- A: Credit reference agencies (“CRAs”) collect and maintain information on consumers’ and businesses’ credit behaviour, on behalf of lenders in the UK (e.g. Experian).
- Q: What is CRAIN?
- A: The UK’s three Credit Reference Agencies (i.e. Experian, Equifax & Call Credit) have made changes to their Fair Processing Notices and created the Credit Reference Agency Information Notice (“CRAIN”). CRAIN will ensure that the financial industry delivers standardised, clear and consistent information to consumers to explain how CRAs use and share personal information, the type of information they hold, where it comes from and the legalities of handling personal information.
- Q: What is a fraud prevention agency?
- A: Fraud Prevention Agencies (“FPAs”) collect, maintain and share information on known and suspected fraudulent activity (e.g. Cifas). Some CRAs also act as FPAs.
- Q: Why do you use them when I have applied to your organisation?
- A: Although you have applied to us and we will check our own records, we will also contact CRAs to get information on your credit behaviour with other organisations. This will help us make the best possible assessment of your overall situation before we make a decision.
- Q: Where do they get the information?
- A: The information is usually publicly available, and comes from the following sources:
- The Electoral Register at Local Authorities;
- County Court Judgments from Registry Trust;
- Bankruptcy information from the Insolvency Service;
- Fraud information from fraud prevention agencies; and
- Credit information comes from information on applications to banks, building societies, credit card companies etc and also from the conduct of those accounts.
- Q: How will I know if my information is to be sent to a CRA or FPA?
- A: When you apply for a product, where relevant, we will notify you if your information may be sent to a CRA or FPA
- Q: Why is my personal information used in this way?
- A: We and other organisations want to make the best possible decisions we can, in order to make sure that you will be able to repay us. Some organisations may also use the information to check your identity. In this way we can ensure that we all make responsible decisions. At the same time we also want to make decisions quickly and easily and, by using up to date information, provided electronically, we are able to make the most reliable and fair decisions possible.
- Q: Who controls what credit reference agencies are allowed to do with my personal information?
- A: All organisations that collect and process personal information are regulated by the Data Protection Act 1998 or (from 25 May 2018) the General Data Protection Regulation (2016/679) and the Data Protection Act 2018, overseen by the Information Commissioner’s Office. All credit reference agencies are in regular dialogue with the Commissioner. Use of the Electoral Register is controlled under the Representation of the People Act 2000.
- Q: Can anyone look at my personal information held at credit reference agencies?
- A: No, access to your information is very strictly controlled and only those that are entitled to do so may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement.
- Q: What do Credit Reference Agencies do and how do they use personal information?
- A: When credit reference agencies receive a search from us they will:
- Place a search “footprint” on your credit file whether or not this application proceeds. If the search was for a credit application, the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future. This may affect your ability to obtain credit elsewhere in the near future;
- Link together the records of you and anyone that you have advised is your financial associate including previous and subsequent names of parties to the account. Links between financial associates will remain on your and their files until such time as you or your partner successfully files for a disassociation with the credit reference agencies;
- Supply to us:
- Credit information such as previous applications for financial products and the conduct of the accounts in your name and of your financial associate(s) (if there is a link between you);
- Public information such as County Court Judgments (CCJs) and bankruptcies;
- Electoral Register information; and
- Fraud prevention information;
- When information is supplied by us, to them, about you:
- the details that are supplied on your personal account(s) including previous and subsequent names of parties to the account and how you manage it/them;
- that you have not satisfied a debt to us, or do not repay it in full or on time; and
- keep your records on file for a period of time (as defined by law) after your account is closed, whether settled by you or defaulted.
- Credit reference agencies will NOT use your personal information:
- to create a blacklist; or
- to make a decision.
- Credit reference agencies may also use this information to:
- Trace your whereabouts and help us (and other creditors) to recover payments if you do not make payments you owe;
- Conduct checks for the prevention and detection of crime including fraud and/or money laundering;
If you would like to find out more, you can contact the agencies directly using the details below.
- Equifax Ltd Customer Service Centre, PO Box 10036, Leicester, LE3 4FS or call 0800 014 2955 or log on to www.equifax.co.uk
- Experian Ltd Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0344 481 8000 or log on to experian.co.uk
If you have been refused credit you can get advice from your local Trading Standards Department, Citizens Advice Bureau and/or the agencies’ web sites. The Information Commissioner also produces a useful leaflet entitled ‘Credit Explained’. You can obtain a free copy on the Information Commissioner’s website or by telephoning 0870 600 8100.
Fraud Prevention Agencies (or “FPAs”)
We have systems that protect our customers and ourselves against fraud and other crime. Personal information can be used to prevent crime and trace those responsible. If false or inaccurate information is provided and fraud is identified, details will be passed to FPAs.
Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
- Checking details on applications for credit or other facilities
- Managing credit and credit related accounts or facilities;
- Recovering debt;
- Checking details of job applicants and employees.
Keeping you informed about our products and services
We would like to tell you about the great offers, ideas, products and services available at MP Moran from time to time that we think you might be interested in. Where we have your consent or it is in our legitimate interests to do so, we may do this through the post, by email, text message or by any other electronic means.
We won't send you marketing messages if you tell us not to, but if you receive a service from us we will still need to send you occasional service-related messages. If you wish to amend your marketing preferences, you can do so by emailing us at email@example.com
Please note that it can take up a little while for all marketing to stop once you either withdraw your consent or tell us you’d like to opt out of marketing. This is because some marketing may already be in transit.
You have a number of rights under data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal information we process about you
- the right to access a copy of the personal information we hold about you;
- the right to correction of inaccurate personal information we hold about you;
- the right to restrict our use of your personal information;
- the right to be forgotten;
- the right of data portability; and
- the right to object to our use of your personal information.
Where we rely on consent as the legal basis on which we process your personal information, you may also withdraw that consent at any time.
If you are seeking to exercise any of these rights, please contact us using the details in the “Contact Us” section below. Please note that we will need to verify your identity before we can fulfil any of your rights under data protection law. This helps us to protect the personal information belonging to our customer against fraudulent requests.
How long will we keep your personal information for?
We take protecting your personal information seriously and are continuously developing our security systems and processes. Some of the controls we have in place are:
- We limit physical access to our buildings and user access to our systems to only those that we believe are entitled to be there;
- We use technology controls for our information systems, such as firewalls, user verification, strong data encryption, and separation of roles, systems & data;
- Systems are proactively monitored through a “detect and respond” information security function;
- We utilize industry “good practice” standards to support the maintenance of a robust information security management system; and
- We enforce a “need to know” policy, for access to any data or systems.
If you would like to exercise one of your rights as set out in the “Your rights” or “Automated decision making and profiling” sections above, or you have a question or a complaint about this policy, or the way your personal information is processed, please contact us by one of the following means:
By email: firstname.lastname@example.org
By post: Data Protection Officer, MP Moran & Sons Ltd, 293/301 Kilburn High Road, London NW6 7JR
You also have the right to lodge a complaint with the UK regulator, the Information Commissioner. Go to ico.org.uk/concerns to find out more.