Privacy Policy

General

Wren Kitchens Limited (“Wren Kitchens”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) describes our privacy practices relating to your use of the Wren Kitchens website, www.wrenkitchens.com (“Website”), your purchase of our offerings and related services, and other online and offline activities. This Policy is incorporated into our Terms of Use, which also apply when you access or use the Website. For the purposes of European data protection legislation, we are a data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Personal data we collect from you

  1. We may collect and process personal data about you in the following circumstances:

    1. when you complete forms on our Website or otherwise send us information. This includes where you complete our 'Book a free showroom appointment', 'Book a free home measure' and 'Request a brochure' forms. We will collect details such as your name, email address and telephone number so we can contact you about the services you have requested and respond to your inquiry;

    2. when you register for an account on our Website, we collect your name, email, password, phone number, and address. We will use your number to send important updates about your kitchen inquiry or order, as well as use your address for any orders you have made;

    3. when you submit comments in response to our blog posts, we collect any information you voluntarily provide. Before you can leave a comment, you may be prompted to log in to your Google, Twitter, Facebook, or Disqus account for authentication purposes. These third-party services may share your authentication information with us as well as information available on or through your accounts with these services. Please visit Google, Twitter, Facebook, or Disqus’s privacy policies for more information on their privacy practices;

    4. when you voluntarily sign up to receive one of our newsletters or to be added to one of our mailing lists, we may collect your name, e-mail address, zip code, and organization. For more information, please see section 5 below;

    5. whenever you provide information to us when seeking customer service, reporting a problem with our Website, making a complaint, making an inquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;

    6. when you upload photos and other information via our Website, or when uploading certain photos and other information via social media. This would include photo submissions made for Wren Kitchens promotional competitions, such as finished kitchen installation pictures uploaded to our Website or uploaded to Instagram using the competition hashtag;

    7. whenever you disclose your information to us, or we collect information from you in any other way, through our Website; and

    8. whenever you recommend a friend or accept a recommendation as part of our referral scheme. Please note that it is your responsibility to obtain any necessary consents for any personal data you provide to us from friends or other third parties, and to provide them a copy of this Policy so they understand how their personal data will be collected and used.

  2. We also may combine the personal data that we have collected about you with other data about you obtained from other sources (both online and offline), such as from third parties and public sources. For example, if you post a review of your kitchen installation using the review hosting site Trustpilot, we may combine any personal data from the review with other information about you. If you post a picture on Instagram with a Wren Kitchens hashtag as part of a promotion, we may combine that personal data with other information about you. Additionally, if you connect with us on social media, we may use the social media platforms’ data analytics and advertising tools to obtain personal data about you, such as your demographics, interests, and other characteristics, to use for research and analytical purposes, as well as for targeted or online behavioral advertising on other websites.

  3. When navigating our Website or using our services, we may also collect data in the following ways:

    1. Automated Tracking
      We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may collect details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access) to help us build a profile of our users. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertizers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We also use automated tracking technologies, like web beacons, Google Analytics, and social media plug-ins, to collect other information about your website session, browsing, and device information for our legitimate business purposes. For more information on how and why we uses these technologies, please see our Cookie Policy.

    2. Cookies
      We place cookies on your machine with an ID that allows us to track how you use our Website now and in the future. We may also join this website behavioral data with other data sources. We use this to help us improve our website, service and advertising efforts. You can disable cookies at any time by adjusting your browser settings. Browsers are different, so please refer to the instructions in your browser to learn about cookies and other privacy and security settings that may be available. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

  4. Cross-Device Tracking
    We use data analytics companies, advertising networks, or social media companies, and features offered by Google Analytics services or the Facebook Pixel to engage in “cross-device tracking,” which occurs when platforms, publishers, and advertising technology companies try to connect a consumer’s activity across smartphones, tablets, desktop computers, and other connected devices. The goal of cross-device tracking is to enable companies to link a consumer’s behavior across devices.

  5. We will only use your personal data when the law allows to. Most commonly we will use your personal data:

    1. Where we need to perform a contract we are about to enter into or have entered into with you.

    2. 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.

    3. Where we need to comply with a legal obligation.

  6. These uses of your personal data may include use to:

    1. provide you with information, or provide other services that you requested from us;

    2. perform the terms of a promotional competition we are hosting;

    3. allow you to participate in interactive features of our Website, when you choose to do so;

    4. ensure that content from our Website is presented in the most effective manner for you and for your device;

    5. improve our Website and services; and

    6. process and deal with any complaints or inquiries made by you.

  7. Situations where processing your personal data may be necessary for our legitimate interests include:

    1. The sale of all or part of Wren Kitchens or its business.

    2. Notifying you about changes to our terms and/or this privacy policy.

    3. The situations set out in section 5.3.

  8. We also may use your personal data where we have your consent to do so, including to provide you marketing communications and other materials you have signed up for (see section 5 for further details).

  9. Website Links
    Our Website may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. When you leave our Website, we encourage you to read the privacy notice/policy of every website you visit.

Personal data we collect about you when you are a Customer

  1. We may collect details such as your name, address, telephone number and email address when you order goods or services from us in one of our showrooms, online, or over the phone. We will use this information to process your order, comply with our contractual obligations and, where you have set up an online account with us, to help manage your account. Additionally, when you place an order, we may collect your name and payment information, like banking details or check information. We may also collect contact details from you relating to a third party we may contact (with your consent) to discuss an order which you have placed. We may also use your information including your address and the type of product purchased from us to help inform the sale of our products to future customers. We may also use your name and contact details for customer service and dispute resolution purposes.

  2. In order to perform our contract with you, we may also need to share personal data with third parties such as payment providers, suppliers, postal service or other delivery organizations and installers, in order to assist in the delivery and performance of the goods and services you have ordered.

  3. We may also instruct third parties to conduct customer experience and other surveys on our behalf to improve our services and for customer research and marketing purposes.

  4. We may also publish your feedback on our Website and in other marketing materials (subject to obtaining your prior consent where necessary).

  5. We will also use your personal data in the ways described in sections 6, 7 and 10 of this policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our goods or services). In this case, we may have to cancel the order you have placed with us, and we will notify you if this is the case at that time.

Marketing

  1. In addition to the uses described in sections 2 and 3 above, where you have purchased our products or services, indicated that you would like to receive marketing correspondence from us, subscribed to our mailing lists or newsletters, entered into any of our competitions or provided us with your details at networking events, we may use your personal data where you have given your consent or where this is necessary for our legitimate interests and these are not overridden by your rights and freedoms in order to provide you with details about our goods and services which we think may be of interest.

  2. You have the right to opt-out of receiving marketing correspondence from us at any time. To opt-out of receiving such information you can:

    1. log onto your online account and amend your preferences;

    2. click the unsubscribe button contained in any marketing email which we send you; or

    3. email us at privacy@wrenkitchens.com or call (+44) 1652 247831 providing us with your name and contact details.

  3. We may contact you in order to obtain the contact details of any third parties including contractors who have provided you with installation or other related services in order to perform a contract or where we have a legitimate interest to do so in connection with the provision of services. If you are a third party which has provided a related service to our customer, you may be contacted by Wren.

Monitoring and recording

  1. We may monitor and record communications with you (such as telephone communications) for the purpose of quality assurance, training, fraud prevention and compliance.

  2. We have CCTV cameras installed in our premises and in our delivery vehicles for the purpose of crime prevention and for health and safety reasons.

  3. We have a vision camera installed in several of our showrooms, the purposes of which is to track footfall in our stores. The camera converts a non-audio video still of an individual into anonymized information. Gender and age are estimated by the system and converted into data. The image does not leave the local system and within a few minutes is deleted, leaving anonymized data behind. This anonymized data is stored separately and kept indefinitely.

  4. We may also take photos of the products delivered and/or installed at your property in order to demonstrate the delivery and performance of products and services to you.

Personal data collected from prospective customers who apply for our customer finance options

  1. We offer credit broker services for financing kitchen offerings. Barclays Partner Finance acts as the lender. Where prospective customers want to benefit from our customer finance options to purchase our goods and/or services, we will carry out credit checks via Barclays. By obtaining such a consumer report from Barclay’s, we may collect your name, age, salary, address history, and loan amount.

  2. We require credit checks to be undertaken:

    1. so that we can make credit decisions about you; and

    2. to prevent fraud and money laundering.

  3. Our search will be recorded on the files of the credit reference agency.

  4. Other credit businesses may use your information to:

    1. make credit decisions about you and the people with who you are financially associated;

    2. trace debtors; and

    3. prepare and detect fraud and money laundering.

  5. If you receive a low credit score, we reserve the right not to supply you with goods or services on credit and to require a different form of payment for the goods or services you wish to purchase.

  6. If you provide false or inaccurate information and we suspect fraud, we will record this.

In-person visitors to The Nest and our manufacturing sites

  1. Visitors to our registered office at The Nest and our manufacturing sites will be required to register their details on a third-party visitor management system. The system will record personal data and a photograph will also be taken before access to site is granted. This data will be stored on a cloud platform and deleted after a period of time, in line with our data retention policy. We require these details to give us visibility of who is onsite to ensure site security and safety.

Legal basis for processing your personal data

  1. We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    1. for performance of a contract we enter into with you;

    2. where necessary for compliance with a legal or regulatory obligation we are subject to; and

    3. for our legitimate interests (as described within this Policy) (but only if your interests and fundamental rights do not override these interests).

Disclosure of personal data to third parties

  1. As well as set out elsewhere in this Policy, we may disclose your information to the following parties, because we have a legitimate interest in doing so:

    1. our group companies (including our subsidiaries, our holding companies and any subsidiaries of our holding companies as defined in Section 1159 of the Companies Act 2006) for purposes described in this Policy;

    2. staff members and third party suppliers in order to facilitate the provision of goods or services to you;

    3. our affiliated entities to support internal administration;

    4. IT software providers that host our Website and store data on our behalf and service providers and suppliers to Wren Kitchens;

    5. our professional advisers including consultants, legal advisers, bankers and insurers for our everyday business needs, such as auditing, administration of our services, analytics, and enforcement of any corporate reporting obligations, Terms & Conditions, or other policies;

    6. HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;

    7. third party companies like Trustpilot that collect and assess customer feedback;

    8. to third-party organizations who provide us with information on an anonymized basis about customer demographics and expenditure; and

    9. to third parties with whom we may in the future negotiate a sale, transfer or merger of our business.

  2. We may also disclose personal data to the police, regulatory bodies, legal advisers or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements, or to protect our rights, property, or safety of our customers, or others.

  3. We may share your personal data, like e-mail address or other data, with ad networks for online behavioral advertising purposes with your consent.

  4. We will not sell or distribute personal data to other organizations without your approval.

Cross-border data transfers

  1. Your personal data may be stored and processed in any country where we have Wren Kitchens facilities or service providers, including the United States, which may not have protections for personal data what are equivalent to those of your jurisdiction and/or which may not be considered adequate by the European Union (“EU”). By using our Website, you acknowledge that we may transfer your personal data to countries outside your country of residence, and that these may provide different data protection rules than in your country and such rules may not be equivalent to those of the EU.

  2. Where we transfer data from the EU and other jurisdictions outside the European Economic Area (“EEA”), we will implement appropriate safeguards approved by the European Commission for the security of the processing of your personal data outside the EEA

Data security

  1. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

  2. 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 information transmitted to our Website; any transmission is at your own risk.

  3. Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organizational measures designed to secure your information against accidental loss and unauthorized access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

Access to, updating, deleting and restricting use of personal data

  1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

  2. Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances, and to withdraw your consent to the processing of your personal data where this has been provided, although we may have the right to process your data without your consent in certain circumstances, as set out elsewhere in this policy. You also have the right to access information held about you and for this to be provided in an intelligible form. If you would like a copy of some or all of your personal information, please send an email to our Data Protection Officer at privacy@wrenkitchens.com specifying your name and the details of your request. We will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time. We reserve the right to charge a reasonable fee for the administrative costs of complying with your request if your request is manifestly unfounded or excessive, or if you request further copies of your data following a request.

  3. You can also ask us to do the following (although please see section 12.4, which might apply to your request):

    1. update or amend your personal data if you feel this is inaccurate;

    2. remove your personal data from our records entirely;

    3. send you copies of your personal data in a commonly used format, and transfer your information to another entity; or

    4. restrict the use of your personal data.

  4. If you make this type of request we may request specific information from you to help us confirm your identity and verify your request. Data protection legislation may allow or require us to refuse your request. If we refuse your request we will inform you of the reasons why, subject to any legal or regulatory restrictions.

  5. Please send any requests relating to the above in writing to our Data Protection Officer at privacy@wrenkitchens.com specifying your name and the details of your request.

Retention of personal data

  1. We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, unless a longer retention period is required by law or to fulfill a legal obligation or for accounting purposes.

  2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  3. Details of retention periods for different aspects of your personal data are available upon request by contacting us on privacy@wrenkitchens.com.

Right to withdraw consent

Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact us at privacy@wrenkitchens.com.

Age Restrictions

  1. The Website is not intended for use by individuals under the age of sixteen, and we request that these individuals not provide personal data through the Website.

  2. If you are a parent or guardian of a child under the age of sixteen and believe that he or she has disclosed his or her personal data to us, please contact us using the information provided under “Contact Us.”

Changes to our privacy policy and the effective date

  1. We reserve the right to update this privacy policy at any time. Please check the “Last Updated” legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Privacy Statement on the Website.

  2. Any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact us

Your personal data will be held by Wren Kitchens.

Our Data Protection Officer oversees our compliance with this privacy policy. If you have any questions, comments or requests regarding this Policy including any requests to exercise your legal rights, or how we use your personal data please contact our Data Protection Officer at privacy@wrenkitchens.com.

We appreciate the chance to deal with your concerns in the first instance. However, you may also have the right to contact the Information Commissioners Office (“ICO”) if you are unsatisfied with our response to any issues you raise. The contact details for the ICO can be found here: ico.org.


Last updated: November 19th 2019