Privacy Notice

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

There is a full list of information because we want you to be fully informed about your rights, and how ViolaPets uses your data.

Our products and services are aimed at those aged 16 and over.

We are likely to update this Privacy Notice from time to time. We’ll notify you of any significant changes via email, but you’re welcome to come back and check it whenever you wish.

When you are using the ViolaPets websites, HOLAPETS LTD. is the data controller.

WHEN DO WE COLLECT YOUR PERSONAL DATA

When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the Partnership on the phone, in a shop or online.
When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
When you create an account with us.
When you shop online, we capture information through cookies and similar technologies, you can manage these when you visit our site.
When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
When you engage with us on social media.
When you download or install one of our apps.
When you join a loyalty programme.
When you contact us by any means with queries, complaints etc.
When you book any kind of appointment with us or book to attend an event, for example a store special event.
When you choose to complete any surveys we send you.
When you comment on or review our products and services.
Any individual may access personal data related to them, including opinions. So if your comment or review includes information about us, it may be passed on to the party related if requested.
When you fill in any forms. For example, if an accident happens in store, we may collect your personal data.
When you’ve given a third party permission to share with us the information they hold about you.
We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.
When you use our car parks and shops which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.

WHAT SORT OF PERSONAL DATA DO WE COLLECT

If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
Details of your interactions with us through contact centres, in store, online or by using one of our apps.
Any items you may have added to your Wish List.
Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your shopping preferences.
Details of your visits to our websites or apps, and which site you came from to ours.
Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.
Open rates, click through rates on email marketing campaigns through the use of Pixels.
Personal details which help us to recommend items of interest.

We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.

Payment card information.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit a shop or car park. We may also record audio when body worn video is in use.
Your car number plate may be recorded at some of our car parks to manage parking restrictions.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Learn more about this.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
When part of a user trial, to ensure you are sent relevant & appropriate products we may ask for vital statistics & details on your household.

HOW AND WHY DO WE USE YOUR PERSONAL DATA

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:

To process any orders that you make by using our websites, apps or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To send you email notifications when you place a product in your basket and you abandon your browsing before completing your checkout. We do this based on our legitimate interest. To provide you with tracking information so that you can follow your order. We do this under legitimate interest to enhance your customer experience and give you more information around where your delivery is and when your order will arrive.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our stores and car parks which may record images for security. We may also record audio where body worn video is in use. Our CCTV systems do not use facial recognition nor do they collect biometrics; they are also not connected to other systems containing personal data. We operate these systems on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
With your consent, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK.

Of course, you are free to opt out of hearing from us by any of these channels at any time.

To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
To comply with our contractual or legal obligations to share data with law enforcement.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across us, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest.
For our loyalty members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become a loyalty member. If you don’t want to continue receiving offers, you’ll be unable to continue your loyalty membership.
To process your booking/appointment requests (for example with a personal stylist). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.

Here’s more information on how we share personal data with third parties.

Help inform business decisions for example which 3rd Party websites we partner with to ensure our advertising reaches our customers
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

When you shop at one of our stores or online and use your loyalty card and/or payment card, including a Partnership card, we consolidate your purchases using the unique numbers of your loyalty card and/or tokenised payment card. A loyalty card is unique to you and has a number associated to you which allows us to match it to your profile and therefore any associated spend. Your payment card also has a unique tokenised reference number and we associate this with you when you have used this payment card, also with any spend.
We do this to ensure we have a clear view of what you like and to ensure that you are rewarded appropriately, so that direct marketing or browsing on our websites is tailored to what your preferences. This also allows your receipts to be stored in your kitchen drawer on your online account, if you have one, even if you are shopping in our store. We may also use the information we collect via the consolidation of your spend to inform our business decisions. This is done either by anonymising your spend and analysing it as part of a “spend-trend”, statistical view, or working with our third party suppliers, such as Google.

COMBINING YOUR DATA FOR PERSONALISED DIRECT MARKETING

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across our services as described above, for example your shopping history at both online and in-store. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us - such as the Land Registry mentioned above.

HOW WE PROTECT YOUR PERSONAL DATA

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and encrypted to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
We are comply with the standard of data protection and registered at the Information Commissioner's Office (the ICO). Our registration reference is ZB593955.

HOW LONG WILL WE KEEP YOUR PERSONAL DATA

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

WHO DO WE SHARE YOUR PERSONAL DATA WITH

We sometimes share your personal data with trusted third parties.
- For example, delivery couriers, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:
- With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
- For example, if you enter a holiday competition and tick a box agreeing that the travel company can send you promotional information directly. Or if we run a joint event with a restaurant, and you agree to receive direct communications from them.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may, from time to time, expand, reduce or sell the Partnership and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact our Data Protection Officer.

WHERE YOUR PERSONAL DATA MAY BE PROCESSED

ViolaPets is a UK based company and so we will transfer your data to the UK, which is outside of the EU. We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

Protecting your data outside the UK

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by a Partner of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time by completing an online form.

If we choose not to action your request, we will explain the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration of an extended warranty.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

HOW CAN YOU STOP THE USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
If you have an account, log in into your VIOLAPETS account, visit the ‘My Account’ area and change your preferences.
In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
Write to Data Rights Team - DPO ViolaPets, 3 Hawthorne Crescent, London, SE10 9GA
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

CONTACTING THE REGULATOR

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.

ANY QUESTIONS

We believe this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. But we understand it may not cover every aspect of concern.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at DPO@holapets.co.uk
This notice was last updated on 23/09/23