Customer Privacy Notice
Purpose of this Privacy Notice
Euphoria Lifestyle Limited, a company registered in England and Wales with company number (Company Number:05773059) having its registered office at Delta House C/O Cja Accounting Limited, 16 Bridge Road, Haywards Heath, United Kingdom, RH16 1UA (referred to as “Euphoria Lifestyle Limited“, “we“, “us” or “our” in this Privacy Notice), respects your privacy and is committed to protecting your personal data. This Privacy Notice will tell you what to expect when we process personal information through your use of this website or where you otherwise contact us, including any personal information you may provide where you purchase a product or service from us (whether through this website or otherwise).
This website is not intended for children and we do not knowingly collect data relating to children.
Euphoria Lifestyle Limited is the data controller and responsible for your personal data. If you have any requests about this Privacy Notice, including any request to exercise your legal rights, please contact us on the below:
Phone: 01903 892 555
Address: FAO Privacy Manager, Euphoria Lifestyle Limited, Squire’s Washington, London Road, Washington, West Sussex, RH20 3BP
- Why do we collect and store personal information?
Personal data, or personal information means any information about an individual from which a person can be identified.
We may ask you for certain personal information to provide you with the products and services you request. For example, when you make a purchase, contact our customer care team regarding in-warranty or out warranty issues or request relevant product information or updates. We may also process our personal information where providing you with details of special offers and promotions, events or other relevant marketing content.
We may collect, use, store, and transfer different kinds of personal data about you which we have categorised below:
Identity Data – Marital status, First Name, Last Name;
Contact Data – Billing Address, Delivery Address, Email Addresses, Phone Numbers;
Transaction Data – details about payments to and from you and other details of products and services you have purchased from us; and
Marketing and Communications Data – your preferences in receiving marketing from us and our third parties and your communication preferences.
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). Nor do we collect any information about criminal convictions and offences.
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 that 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 products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- How is your personal data collected?
You may give us your personal data by filling in web forms or by corresponding with us directly by post, phone, email, through our website, or otherwise. This includes personal information you provide when you:
- Complete and submit an order for our products or services (including where we act as credit broker for a product you are to purchase);
- When you send email to our teams, including where making enquiries or providing feedback;
- When you request a repair under warranty; or
- When you attend any of our events or shows or request marketing communications to be sent to you.
- Information we may hold about you and how we use it
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- 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 have your consent; or
- Where we need to comply with a legal obligation.
The information we hold on our records concerns our relationship with you. The below table sets out the activities we carry out, the type of personal data we collect (as per the above categorisations), and the lawful reason for us processing this personal data:
Type of Data
Lawful Basis for Processing
To manage our relationship with you, including:
· Responding to enquiries or feedback;
· Asking you to complete a survey.
Identity & Contact
Necessary for our legitimate interest (to respond to your queries and to enable us to develop our products and services)
To assist with your third-party finance applications.
Identity and Contact
Performance of a contract with you
To process orders and delivery and to provide services including:
· Manage payment;
· Collect and recover money owed to us;
· Deliver products and services;
· Deal with any customer care issues regarding your order.
Identity, Contact, Financial, Transactional
Performance of a contract with you
To process any after sales request including:
· Warranty repair;
· Product technical support.
Identity, Contact, Financial, Transactional
Performance of a contract with you
To communicate information about:
· Our products and services;
· Or other promotional purposes.
Identity, Contact and Marketing and Communications Data
· Performance of a contract with you
· Necessary for our legitimate interest (to enhance our business)
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- How we manage your personal information
We process your personal information in accordance with the principles of applicable data protection laws.
We will treat your personal information fairly and lawfully and we will ensure that information is:
- Processed for limited purposes;
- Kept up-to-date, accurate, relevant and not excessive;
- Not kept longer than is necessary;
- Kept secure.
Access to personal information is restricted to authorised individuals within our organisation on a strictly need to know basis.
We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate.
To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent in some cases, including before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- Data Retention – How long will we hold your personal data?
We will only hold your personal data for as long as necessary to fulfil the purpose we collected it for.
For us to decide how long we hold your personal data for we review sensitivity, amount, potential risk from unauthorised use, the purpose we are processing and the legal basis.
The details of our full retention periods of your personal data can be found in our data retention policy. You can request this by contacting our Privacy Manager at the contact stated at the start of this Privacy Notice.
- Sharing your personal information
Where necessary or required, we may share information as follows:
- With our authorised supplier network where group discussions are requested or required;
- With third party service providers, in order to complete deliveries and repair work as part of our ordering and warranty program;
- With third party finance providers where we have your consent;
- With third parties providing warranties on purchased products, including for the purpose of registering a warranty;
- With third party IT software providers and support (including chat functionality on our website and other technical support);
- With external agencies who support us on marketing campaigns and events; or
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice;
When sharing personal information, we will comply with all aspects of applicable data protection laws.
- International Transfers
We do not routinely share personal data outside the UK or EEA. We will only transfer your personal data out of the UK or EEA, where an exemption applies or where we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- We will only transfer your personal data where appropriate safeguards are in place, for example we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
- Data Security
We have set security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We also limit access to personal data to employees and third parties who have a business requirement to know.
We have procedures in place to manage any potential data breach and will notify you and any relevant regulator where legally required.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Including:
- Access to personal information. You have a right to ask us what personal information we hold about you, and to request a copy of your information. This is known as a ‘subject access request’ (SAR). SARs need to be made in writing to our Privacy Manager. We have a subject access form you can use for this purpose which we will provide upon request, and we ask that your written request is accompanied by proof of identify.
- Rectification. If you require us to correct any mistakes contained in the information we hold about you, you can let us know by contacting our Privacy Manager.
- Requesting 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.
- Objecting 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.
- Requesting 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:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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;
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Requesting 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.
- Withdrawing 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.
If you wish to exercise any of the rights set out above, please contact our Privacy Manager.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
- Changes to this Privacy Notice
We reserve the right to update this Privacy Notice from time to time and we keep this Privacy Notice under regular review. This Privacy Notice was last updated on August 15th, 2022.
- Contact Us
If you have any questions about this Privacy Notice, please contact the Privacy Manager.
Please do not hesitate to contact us regarding any matter relating to this Privacy notice via email to email@example.com or in writing to:
Privacy Control Manager
Euphoria Lifestyle Limited
Squires of Washington
Washington, West Sussex