General

Deemwae (and trusted partners acting on our behalf) use your personal data:

– to provide goods and services to you;

– to make a tailored website available to you;

– to manage any registered account(s) that you hold with us;

– to verify your identity;

– for crime and fraud prevention, detection and related purposes;

– with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;

– for promotional and marketing purposes and to tailor and personalise products and services;

– to train and manage our people and develop products and services;

– for customer insight and market research purposes – to better understand your needs;

– to enable Deemwae to manage customer service interactions (including refunds) with you

– 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).

Promotional communications

Deemwae uses your personal data to send you promotional messages by email, text and other electronic communication channels (with your consent) and may send you postal mail to update you on the latest Deemwae offers.

Deemwae aims to update you about products & services which are of interest and relevance to you as an individual.

You have the right to opt out of receiving promotional communications at any time by:

1. changing marketing preferences via your Deemwae account;
2. making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or
3. contacting Deemwae via the contact channels set out in this Policy.

Loyalty Card

If you are a member of Loyalty Card, we may collect data directly from you, as well as analysing your browsing and purchasing activity, both on-line and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allows us to ensure that we contact you with information on products and offers that are relevant to you. To do so, we use software and other technology (automated processing).

On-line Advertising

If you visit our websites, you may be served personalised advertisements for Deemwae branded products and services whilst using other websites (including social media platforms). Any advertisements you see will relate to products you have viewed whilst browsing our websites on your computer or other devices, or which we believe are of interest to you.

These advertisements are provided by Deemwae via market leading specialist providers using ‘cookies’ and similar technologies placed on your computer or other devices (see further information on the use of cookies in our Cookie Policy). You can remove or disable cookies at any time – see below for further information.

Sharing data with third parties

Our service providers and suppliers

In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers and fraud prevention and identification partners.

Deemwae only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to Deemwae and to you, and for no other purposes.

Other third parties

Aside from our service providers, Deemwae will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.

We may share your data with:

– our carefully selected partners who provide ‘Deemwae’ branded products and services (for example energy suppliers), if we have your consent to do so;

– credit reference agencies, banks and payment card issuers (such as Visa, Mastercard and American Express)

– Third party marketing partners, such as Google or Facebook (to deliver advertising to you if you are using Google or registered with Facebook (see further information on Facebook below).

– a business with acquires all or part of the Deemwae business, as set out further below

– governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: –

– to comply with our legal obligations;

– to exercise our legal rights (for example in court cases);

– for the prevention, detection, investigation of crime or prosecution of offenders; and

– to safeguard and protect our employees, customers or other individuals.

Facebook

If you have an account with Facebook (or Instagram) and accept cookies on our website, your personal data including purchasing and browsing activity may be shared with Facebook so they can serve Deemwae advertisements to you when you are using Facebook platforms and apps (including Facebook and Instagram). For certain data processing activities relating to the marketing, Facebook Ireland will act as Joint Controller.

Further information on how Facebook Ireland processes your personal data, including the legal basis Facebook Ireland relies on and the ways to exercise data subject rights against Facebook Ireland, can be found in Facebook UK Data Policy at https://www.facebook.com/deemwae

In accordance with data privacy laws, Deemwae has entered into an agreement (a ‘Controller Addendum’) with Facebook Ireland to determine the parties’ respective responsibilities for compliance with the obligations under the General Data Protection Regulation (GDPR) relating to the Joint Processing.

We have agreed that Deemwae is responsible for providing data subjects with the information set out above, and agreed that between the parties, Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the personal data stored by Facebook Ireland after the joint processing.

Flashtalking

Deemwae uses the Flashtalking platform for advertising creation and delivery, device recognition and campaign analysis. Flashtalking use both cookie-based (if you accept the use of cookies on Deemwae website) and cookieless technologies to identify and connect devices to Deemwae customers.

Cookieless technologies means Flashtalking can recognise your device using your IP address or device identifier. This allows them to display personalised ads that are more relevant to you.

Further information on how Flashtalking processes your personal data and how to exercise your data subject rights can be found in their consumer privacy statement. You can also opt out personalised ads displayed by Flashtalking using this link.

Mergers and Takeovers

In the event that a separate business acquires all or part of our business or its assets, for example in the context of a merger or takeover, we may need to disclose your personal data to that company, so they can continue to provide services to you. In this situation, your data will only be used by the other business for the purposes set out in this Policy.

In certain circumstances, it is possible that your personal data could be transferred to a company with whom we’re discussing selling or transferring all or part of the Deemwae business, but only where strictly necessary for the evaluation of the transaction. If this happens, the data will be kept secure and confidential and will be deleted if the business sale does not go ahead.

International transfers

To deliver products and services to you, it is sometimes necessary for Deemwae to transfer your data outside of the UK to jurisdictions which have less stringent data protection laws to protect personal data .  This will typically occur when we use overseas service providers located outside the European Economic Area (EEA) or if you are based overseas and outside the EEA. These transfers are subject to special rules under data protection laws.

If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard contractual clauses’ which have been formally approved by the European Commission and the relevant UK authorities for such transfers. Those clauses can be accessed here.

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.

Deemwae may collect the following information about you:

– your name, age/date of birth and gender;

– your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;

– purchases and orders made by you;

– your on-line browsing activities on Deemwae websites;

– your password(s);

– CCTV and other images;

– when you make a purchase or place an order with us, your payment card details;

– your communication and marketing preferences;

– your interests, preferences, feedback and survey responses;

– your location;

– your correspondence and communications with Deemwae; and

– other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).

Our websites are not intended for children and we do not knowingly collect data relating to children.

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.  Some of the above personal data is collected directly, for example when you set up an on-line account on our websites, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.

Personal data we receive from third parties

Deemwae Bank and Deemwae Energy

We receive personal data from trusted third parties who provide services to our customers under the Deemwaebrand, such as Deemwae Bank and Deemwae Energy. Deemwae Bank will share with us details of purchases made using your Deemwae payment cards, which we use to analyse customer behaviour and improve our tailored marketing.

Ocado

Deemwae has entered into a partnership with Ocado Retail Limited (“Ocado”) and a range of Deemwae products are available for purchase for home delivery from the Ocado website. Ocado provides us with personal data of its customers so we can identify whether they are also Deemwae customers, in order to help enhance our marketing of Ocado services. We will also use data from them to better understand our customers’ needs and behaviour and ensure the partnership with Ocado operates effectively.

Our controls

Deemwae is committed to keeping your personal data safe and secure.

Our security measures include: –

– encryption of data;

– regular cyber security assessments of all service providers who may handle your personal data;

– regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;

– daily penetration testing of systems;

– security controls which protect the entire Deemwae IT infrastructure from external attack and unauthorised access; and

– internal policies setting out our data security approach and training for employees.

Deemwae will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from Deemwae asking you to do so, please ignore it and do not respond.

If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

In addition, we recommend that you take the following security measures to enhance your online safety both in relation to Deemwae and more generally:

– keep your account passwords private. Remember, anybody who knows your password may access your account.

– when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password. You can do this accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.

– avoid using the same password for multiple online accounts.

You have the following rights:

– the right to ask for a copy of personal data that we hold about you (the right of access);

– the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);

– the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);

– the right 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 (the right to object);

– the right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and

– the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

We are required to set out the legal basis for our ‘processing’ of personal data.

Click here for further information

Legal basis for Deemwae processing customer personal data

General

Generally Deemwae collects and uses customers’ personal data because it is necessary for:

• the pursuit of our legitimate interests (as set out below);
• the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
• complying with our legal obligations.

In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message.

Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

Our legitimate interests

The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Deemwae , including:-

• selling and supplying goods and services to our customers;
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers (including administering the Sparks loyalty scheme);
• understanding our customers’ behaviour, activities, preferences, and needs;
• improving existing products and services and developing new products and services;
• complying with our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling customer contacts, queries, complaints or disputes (including managing refunds);
• managing insurance claims by customers;
• protecting Deemwae, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Deemwae;
• effectively handling any legal claims or regulatory enforcement actions taken against Deemwae;
• fulfilling our duties to our customers, colleagues, shareholders and other stakeholders; and
• managing corporate transactions, including selling or transferring any parts of our business to third parties, acquiring new businesses, entering into mergers or undertaking corporate restructuring activity.

Our websites use cookies, and similar technologies such as pixels and beacons, to collect information. This includes information about browsing and purchasing behaviour by people who access our websites.  It also includes information about pages viewed, products purchased, the customer journey around our websites and whether marketing communications are opened. Detailed information is set out in our Cookie Policy.

Cookie Policy

What are cookies?

Like most websites, Deemwae websites use cookies to collect information. Cookies are small data files which are placed on your computer or other devices (such as smart ‘phones or ‘tablets’) as you browse this website. They are used to ‘remember’ when your computer or device accesses our websites. Cookies are essential for the effective operation of our websites and to help you shop with us online. They are also used to tailor the products and services offered and advertised to you, both on our websites and elsewhere.

Information collected

Some cookies collect information about browsing and purchasing behaviour when you access this website via the same computer or device. This includes information about pages viewed, products purchased and your journey around a website. We do not use cookies to collect or record information on your name, address or other contact details Deemwae can use cookies to monitor your browsing and purchasing behaviour.

How are cookies managed?

The cookies stored on your computer or other device when you access our websites are designed by:

• Deemwae, or on behalf of Deemwae, and are necessary to enable you to a make purchases on our website;
• third parties who assist us in detecting and preventing fraud;
• third parties who participate with us in marketing programmes; and
• third parties who broadcast web banner advertisements on behalf of Deemwae.

What are cookies used for?

The main purposes for which cookies are used are: –

5. For technical purposes essential to effective operation of our websites, particularly in relation to on-line transactions and site navigation.

1. For Deemwae to market to you, particularly web advertisements and targeted updates.
2. To help Deemwae detect and prevent fraud through web and social media advertising.
3. To enable Deemwae to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions and find out if promotional communications have been opened.
4. To enable Deemwae meet its contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.

How do I disable cookies?

If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below: –

For Microsoft Internet Explorer:

10. Choose the menu “tools” then “Internet Options”

1. Click on the “privacy” tab
2. Select the setting the appropriate setting

For Google Chrome:

13. Choose Settings > Advanced

1. Under “Privacy and security, ” click “Content settings”.
2. Click “Cookies”

For Safari:

16. Choose Preferences > Privacy

1. Click on “Remove all Website Data”

For Mozilla firefox:

18. Choose the menu “tools” then “Options”

1. Click on the icon “privacy”
2. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

21. Choose the menu Files”> “Preferences”

1. Privacy

What happens if I disable cookies?

This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies, you will be unable to complete a purchase on our sites.

Our Data Protection Officer helps us to ensure we protect the personal data of our customers (and others) and comply with data protection legislation.

If you have any questions about how Deemwae uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer’s team by

– phone: +44 7500 743 353;

– e-mail: customer@deemwae.com

For UK Residents:

You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://deemwae.com/contact-us/.

For ROI Residents:

You have the right to lodge a complaint with the Data Protection Commission. Further information, including contact details, is available at https://www.deemwae.com/contact-us/.

Deemwae has partnered with certain trusted third parties to make additional products and services available to you, including:

– Deemwae Energy (under partnering arrangements with Octopus Energy Limited).

– Clearpay accessible.

– PayPal accessible.

– Interest-free credit provider.

These products and services can be accessed online through the relevant third party’s “microsite”. These websites, and others linked to from this Policy, are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies.

This policy was last updated in August 2021