This Policy explains how we collect your personal information, how it is used, processed and stored, as well as informing you what your individual data protection and privacy rights are.

This policy was updated on 4th July 2018.

Afibel SAS (registered on the Lille Trade Register under the number 314 360 041) is the Data Controller and the legal entity who is responsible for the personal information that is collected, processed and stored.

Personal information (or 'personal data') means any information that can personally identify you, such as your name, address and contact details.

AFIBEL, head office is located at 129 rue Colbert 59493 VILLENEUVE D’ASCQ - FRANCE.

Afibel is a sister company of Damartex UK Limited.

Please rest reassured that we only collect information that is necessary to provide our products and services, as described in this policy.

• Like many retailers, we collect your name, address, email address, date of birth, telephone number and your order details when you shop by phone, post, or online.
• When you browse our website, we gather information about the pages you visit. This includes technical information such as your IP address, browser type and cookie information (unless you have disabled cookies on your device).

For a copy of the cookie policy, visit afibel.com/uk/cookies or see the How to contact us section for further information.

We collect your personal information directly from you, for example through our order forms, from our website or through conversations we have with you.

We collect and use your personal information for a number of reasons, including:

When you place an order

• To process and deliver your order.
• To communicate with you, for example, to provide delivery updates.

When you apply for an Afibel Personal Account

• To process your credit application including verifying your identity and credit record, and to identify and prevent fraud and money laundering
• To communicate with you regarding your application.
• To administer your account, for example to process payments, make collections, trace debts, provide you with notices and statements, update and maintain our records.
• Should your application be unsuccessful we may need to store your personal information and will do so in accordance with our record retention policy.

On our website

• To personalise and improve your online shopping experience, making your future website visits easy, enjoyable and secure.

For other purposes

• To provide reports to our regulatory authority or law enforcement agencies.

Please note that if you do not provide us with certain information this may affect the service we are able to provide to you. For example, we require your personal information to be able to deliver the goods you have ordered and to be able to assess your application for an Afibel Personal Account.

We rely upon different legal bases to process your personal information depending on the reason for which we have collected or obtained it:

• The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject;
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

When you apply for an Afibel Personal Account, Damartex UK Limited uses an automated decision making software tool to underwrite your application. The use of the software is a requirement to enter into a regulated credit agreement with us. You have the right to request that we do a manual review of the results of the automated decision rendered.

The personal information that you provide to us is stored and processed on secure servers in the UK and France.

Where it is processed outside of the European Economic Area (EEA), we have appropriate agreements, measures and safeguards in place to ensure your personal information is secure. Your information will only be used in line with this Privacy Policy.

We have robust data retention and deletion procedures in place. How long we keep your personal information will depend on the purposes for which we process it. We delete information on a semester basis.

Your data will be kept for:

• 10 years after the placing of your last order in the case of customers;
• 4 years after the last contact for prospects having requested a catalogue or a gift or having taken part in a draw or having created a web account or subscribed to the newsletter;

Cookies will be kept for a maximum of 24 months after having been installed on your computer and consultable on the website https://www.afibel.com/uk/cookies.

The opinions of customers will be kept throughout the marketing period of the product and for a maximum of 5 years.

Records of telephone calls will be kept for a maximum of six months.

We keep personal information relating to any Afibel Personal Account that you have for at least seven years since your last transaction. We may keep your personal information for longer than the period shown above if we have a legal obligation to do so.

Yes, if you would like to. You have the right to access the personal information we hold about you and this is known as the ‘right of access’. You can make the request by phone, email or by writing to us – see the How to contact us section for further information.

Right to rectify
We want to make sure that the personal information we hold about you is accurate and up to date. You can ask us to update your personal information if you think it is out of date or incorrect.

Right to be forgotten
In certain circumstances, you can ask for the information we hold on you to be deleted, should there be a legal or contractual obligation to hold your personal details we may not be able to carry out your request, however, we will explain this fully to you.

Right to restriction of processing
You can ask us to limit how we use your details in certain circumstances. For example, if you have challenged the accuracy of your personal details, you can request that we do not use it until it has been rectified.

Right to object to processing
You have the right to object to the processing of your personal information in certain circumstances. These include where processing is based upon our legitimate interest and where we process your personal information or undertake profiling for direct marketing purposes.

Right to data portability
You have this right if we process your personal information by automated means and processing is based upon consent or performance of a contract. In such cases, you can obtain the information we hold on you and reuse it for your own purposes, including to move, copy or transfer your personal information to another controller. Note that the information you can access under the right to data portability is different from the right of access.

You also have the right to be told which Credit Reference Agencies we have used and obtain a copy of your file from these agencies (please see below for further information about how we use CRAs).

If you want to exercise any of these rights, or have any queries in relation to them, you can make the request by phone, email or by writing to us – see the How to contact us section for further information.

We will respond to your request as soon as possible and always within statutory timeframes. Note that it may be necessary for us to contact you to verify your identity before we can deal with your request.

Yes of course. You can choose how you want to be contacted by us, whether by post or email.

If you do not wish to receive our mailings you can opt out at any time by changing your preferences on your order form, via the telephone or online. We print up to six weeks in advance, so it may take up to this time for you to stop receiving mailings if you decide to opt out.

When you provide your email address you can unsubscribe from our email list at any point simply by clicking the unsubscribe link at the bottom of your email. After a week, you won’t receive any more marketing emails.

There are some circumstances where we may share your name, address and email address with others. We do this when it is necessary to fulfil our legitimate interest of upholding customer service, better understanding our customer base and keeping you informed of offers and promotions that we believe you may be interested in.

On this basis, your personal information may be shared with:

• Companies who provide services to you on our behalf, like delivery companies.
• Our provider for customer relationship: Afibel use the services of Whistl Fulfilment (Farnborough) Limited to administer its’ UK operations and is situated at 1 Apollo Rise, Southwood, Farnborough, GU14 0GT.
• Afibel is a sister company of Damartex UK Limited and if you use the personal account facility the credit is provided by them and they will supply your personal data to a Credit Reference Agency (CRA) for credit assessment, for information about your financial associates, to check your identity and to manage your account. Damartex UK Limited will also regularly share your account and payment history with CRA’s who will provide this to other organisations. For more information about data sharing with CRA’s you can contact us at 0330 1234084 to request a paper copy of a Credit Reference Agency Information Notice (CRAIN).
• Our UK sister brands (Damartex UK Limited, Coopers of Stortford and Sedagyl) who may contact you about their products and for the purposes of improving the quality and the accuracy of our customer files.
• Research companies whom we may ask to contact you directly for your opinions on our products and services.
• We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. They share information on what their customers buy. Epsilon Abacus analyses this pooled information to help the retailers understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.
• Other trusted partners that we may share your data with where we think they offer a product or service that may be of interest to you, but are not limited to, one of the following categories:
  • Retailers/ Mail Order (Automotive, Fashion/clothing, Household, Gardening, Gifts)
  • Charities (Animal, Arts & Culture, Community, Environmental, Elderly, Disability, Housing, Medical, Overseas Aid, Public Service & Military)
  • Lifestyle
  • Finance
  • Utility

In addition to the companies above, we may also share your personal information with Credit Reference Agencies (CRAs), debt collection agencies and fraud prevention agencies to comply with our legal obligations and fulfil our legitimate interests of responsible lending.

In order to process your application for an Afibel Personal Account, we will perform credit and identity checks with a Credit Reference Agency.

To do this, we will supply your personal information to the CRA and they will give us information about you. This will include information from your credit application, your financial situation and financial history. The CRA will supply to us both public (including the electoral register) and shared credit, financial situation, financial history information and fraud prevention information.

We will use this information to:

• Assess your credit status and whether you can afford to take credit.
• Verify the accuracy of the information you have provided to us.
• Prevent criminal activity, fraud and money laundering.
• Manage your account(s).
• Trace and recover debts.
• Ensure any offers provided to you are appropriate to your circumstances

We will continue to exchange information about you with CRAs while you have a Personal Account with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When the CRA receives a search from us they will place a search footprint on your credit file that may be seen by other lenders.

Information held about you by the CRAs may already be linked to records relating to people with whom you are linked financially. For the purposes of credit searching you may be treated as financially linked and you will be assessed with reference to any ‘associated’ records.

CRAs will also link your records together and these will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the Credit Reference Agency Information Notice (CRAIN).

The CRAIN is accessible from each of the three CRAs online:

Call Credit: www.callcredit.co.uk/crain
Equifax: www.equifax.co.uk/crain
Experian: www.experian.co.uk/crain

To request a printed copy of the CRAIN simply get in touch by writing to us with your query at: The Credit Team, Damart, Bowling Green Mills, Bingley, BD97 1AD or phone 0330 123 4083 (open 8.30am – 5pm, Monday-Friday)

We obtain information from the data alliances that we work with, as detailed in the section Do you share my personal information with other companies? or from our UK sister brand Damartex UK Limited.

You can change your contact preferences at any time, see Can I choose how to be contacted by Afibel?

If you would like to contact us regarding your personal information, as detailed in this policy, or wish to amend your contact preferences, then simply get in touch using one of the following options:

• Email us at: service@afibel.co.uk
• Write to us with your query at: Afibel Customer Service, 1 Apollo Rise, Southwood, Farnborough, GU14 0GT
• Call us for free on 0330 123 1293 (standard rate numbers)

For any question pertaining to personal data, you can contact the data protection officer (DPO) by letter at: AFIBEL – For the attention of the DPO - 11 rue du Grand Ruage CS 70255 59655 Villeneuve d'Ascq CEDEX – FRANCE and by e-mail at the following address: dpo@afibel.net.

We hope that we can resolve any query or concern you raise, however if you are not happy with how we’ve handled your personal information then you have the right to complain to the Information Commissioner’s Office (ICO). You can write to: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, phone: 0303 123 1113 or visit the ICO website at ico.org.uk for more information.