Privacy Policy  

Introduction
William WIlson Limited (“William Wilson”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we collect, use and look after your personal data. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
Wolseley UK Limited is the controller and responsible for your personal data (collectively referred to as ”William Wilson”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.

Contact Details
Our full details are: William Wilson, Hareness Road, Altens Industrial Estate, Aberdeen AB12 3QA (Company Number 14691)

Data Privacy Officer: dataprivacyofficer@wolseley.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.   If you notify us of any changes to your personal information we will correct, update or remove your data as speedily as possible.   If you would like us to, correct, amend or update your information please e-mail us at dataprivacyofficer@wolseley.co.uk.

Information We Collect From You
We may collect, use store and transfer the following different kinds of personal data about you:

• Name and contact details – this includes your name, title, billing address, delivery address, email address and telephone numbers
• Date of birth information
• Payment and Financial information – this may include your bank account and/or payment card
• Purchase history – this includes details about products you have purchased from us.
• Profile information – this includes your username and password for any systems or websites you have access to (for example Vaults)
• Marketing information – this includes your interests, your preferences in receiving marketing from us and your communication preferences
• Survey responses and competition entries
• Customer service history – this includes interactions with us over the phone, by email or letter, via the website or on social media
• Record of any complaints and related communications
• Information about your device and how you use our website and apps – this includes information you give us when you browse our websites or apps, including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as how you use our websites and apps.

Unless we have told you otherwise in a specific privacy notice, we do not collect any special categories of personal data about you.   This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

How We Collect Your Personal Data
We use different methods to collect data from and about you including through:

• Direction interactions: you may give us your name and contact details and payment information when purchasing a product from us or by corresponding with us by post, phone, email or otherwise.   This includes personal data you provide when you:
  • Create an account with us;
  • Register on our website;
  • Purchase a product from us;
  • Subscribe to our mailing lists or newsletters;
  • Request marketing to be sent to you;
  • Take part in a competition, promotion or survey;
  • Trade in a branch via CCTV records; and
  • Give us some feedback.
• Automated technologies or interactions: As you interact with our website and our apps, we may automatically collection information about your device and how you use our website and apps.   We collect this personal data by using cookies, server logs and similar technologies.   For more information on cookies, please see our cookie policy.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as:
  •  Information about your device and how you use our websites and apps from analytics providers such Google based outside the EU

Name and contact details, payment information and purchase history from providers of technical, payment and delivery services.

Uses Made of the Information
We (and our trusted partners acting on our behalf) use information held about you in the following ways:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation;
• For certain processing purposes, we may request your consent to authorise the processing. 

Our legitimate interests include:

• 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;
• Performing market research;
• 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;
• Use of CCTV to record in branch trading. Our CCTV records are typically held for between 28 – 32 days only determined by the type of CCTV equipment, when it is then automatically overwritten. Copies of CCTV footage should be requested via our data protection officer. 
• Managing claims by customers;
• Protecting William Wilson Limited, 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 William Wilson Limited;
• Effectively handling any legal claims or regulatory enforcement actions taken against William Wilson Limited; and
• Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

Who We Share Your Data With
We will share your personal information with the following bodies.  Please note that we will never sell or rent our customer data to other organisations for marketing purposes:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Selected third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
  • market research companies that require the data to fulfil marketing and research activities;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Wolseley or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• 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
  • for the protection of our employees and customers.
     
• Other companies and organisations for the purposes of fraud protection and credit risk reduction.
• 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.

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. Please contact us if you require further details.

Security
We’re committed to keeping your personal data secure and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

To help us keep your personal information secure you should:

• Keep your password and any account details secret;
• Never distribute the URL’s for pages that you have looked at while logged in as a registered customer.

International Transfers
To deliver products and services to you, it is sometimes necessary for William Wilson Limited to share your data outside the European Economic Area ("EEA"). It will be processed by staff operating outside the EEA who work for us or for one of our suppliers.   We will only do this if there are appropriate safeguards in place to make sure your personal data receives the same protection as when it is being processed inside the EEA.  By submitting your personal data, you agree to this transfer, storing or processing.

Internet
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 to us over the internet or to our website; 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.

Your Rights
You have legal rights relating to your personal data. You can get more information on each of the rights we’ve summarised below by taking a look at the glossary in the bottom section of this privacy notice:

• The right to request access to your personal data.
• The right to request correction of your personal data.
• The right to request erasure of your personal data.
• The right to object to processing of your personal data or to withdraw consent. Remember, you can always stop direct marketing messages by clicking on an unsubscribe link in any of our emails or getting in touch via email, phone or post.
• The right to request restriction of processing your personal data.
• The right to request a transfer of your personal data to another service provider.

If you wish to exercise any of the rights set out above or if you have any questions or a complaint, please contact us at:

Data Privacy Officer
Wolseley UK Limited
2 Kingmaker Court
Warwick Technology Park
Gallow Hill
Warwick
CV34 6DY
E-mail: dataprivacyofficer@wolseley.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We will do our best to respond to legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary
We recognise that some of the privacy law terminology can be a bit complicated, so we have set out below some further detail on some of the terms used in this policy:

Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. For example, where we are sending you a product you have purchased from us or where you have entered a competition on our website, we will be processing your personal data on the basis that it is necessary for us to do so in order to perform a contract between us.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your Legal Rights
You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Also, please note that in some of our systems we may not be able to completely erase your data due to technical limitations.  However, in this case we will obfuscate/scramble your data, so it cannot be read or restored.  In this instance we will notify you where this occurs.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.