Direct Response Marketing Group Limited Privacy Policy
1. Introduction and Scope
Direct Response Marketing Group Ltd ("DRMG") recognises that the privacy of the personal information that our customers provide to us is critically important. We take the privacy and security of your personal information very seriously. We are committed to complying with our legal obligations under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other data protection laws.
This Privacy Policy explains what types of personal information we collect about you, what we do with that personal information, the legal basis for our processing of your personal information, what rights you have in relation to your personal information and how you can exercise those rights. It also explains how we keep your personal information safe and secure.
This privacy policy also applies to DRMG’ subsidiary companies, including in particular the following companies:-
· DRMG Ltd (company No. 06333962 )
· The Rewards Club
We shall refer to all such companies hereafter as "Associated Companies" and to DRMG and such companies as "DRMG and Associated Companies".
In this privacy policy the terms "we", "us" or "our" may refer to DRMG or to any of the Associated Companies.
2. Who are DRMG ?
DRMG is a company, registered in England and Wales under No. 06333962, whose registered office is DRMG House, Cremers Road, Sittingbourne, England, ME10 3US. DRMG is the parent company for the Associated Companies and their sub brands, listed below:
- Book Club
- Gardening Club
- Motor Club
- Perx
- Puzzle Book
- Rewards Club
- Supercard
Each of these brands and associated companies may use your personal data and contact you.
DRMG is registered with the Information Commissioner’s office under Registration No. Z3435076.
DRMG
For everyday interactions, DRMG is based out of DRMG House, Cremers Road, Sittingbourne, ME10 3US. Our primary business encompasses the retail of a diverse array of products through catalogues, online platforms, and advertisements, aimed at enhancing convenience and addressing common household and garden issues. Our product range spans household essentials, innovative gadgets, automotive accessories, health and mobility aids, along with various other general merchandise. With a history dating back to 1992, DRMG, alongside its affiliated sub-brands, has been committed to providing quality solutions to everyday challenges. As the principal entity, DRMG, together with its subsidiary brands, assumes the role of Data Controller in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
The Rewards Club
The Rewards Club Limited operates a number of Clubs, including the following:
- Book Club
- Gardening Club
- Motor Club
- Perx
- Puzzle Book
- Rewards Club
- Supercard
The operation of these Clubs involves the use of various telemarketing companies, as described in more detail in section 11 below.
The Rewards Club operates a website, which provides more information about who it is, which can be viewed at https://therewardsclub.net
3. Contact us
There are three ways to contact DRMG and Associated Companies to discuss any data protection issues you may have:-
In writing
The Data Protection Officer
DRMG House Cremers road, Sittingbourne, ME10 3US
By email DPO@therewardsclub.co.uk
By phone
03451740580
4. Data Protection Management at DRMG and Associated Companies
DRMG and its Associated Companies have designated a Data Protection Officer to oversee and ensure compliance with data protection laws and regulations. This individual is tasked with managing all aspects of data protection within our organizations to ensure adherence to the
Data Protection Act 2018 and the UK GDPR. For any data protection inquiries or concerns, please refer to the contact information provided in section 3.
5. Types of Personal Data Collected
In compliance with data protection legislation, we recognize personal data as any information that can identify an individual. This excludes anonymous data, which cannot be used for identification.
The personal data we collect includes but is not limited to:
· Contact Information: This encompasses your first name, surname, title, physical address, postcode, email address, telephone numbers, and account credentials such as usernames and passwords.
· Financial Information: This relates to your billing and delivery addresses, payment methods, and card details.
· Order Information: Details regarding the products and services we are providing to you.
· Transaction History: Records of your past purchases and transactions with us.
· Marketing Preferences: Your choices regarding receiving marketing communications from us.
· Interaction Records: Details about your communications and interactions with us.
This information collectively is referred to as "Customer Personal Data."
Additionally, for service improvement purposes, we may gather anonymous data about how individuals navigate and interact with the DRMG website.
Please note, we do not collect or process data from individuals under the age of 18. All registrants or data providers to our service must confirm they are 18 years old or above.
6. Updating or Modifying Your Personal Data
To ensure the accuracy and current status of your personal data, we encourage you to inform us of any changes, such as modifications to your name, address, or marketing preferences. You can update your information by reaching out to our customer services team at 03451740580 , where our staff are ready to assist you with any updates or changes. Alternatively, you can email your updates to our Data Protection Officer at DPO@therewardsclub.co.uk . Your cooperation helps us maintain the integrity and accuracy of your personal data.
7. Collection Methods for Your Personal Data
We obtain your personal data primarily from you. This happens when you engage with us by creating an account, signing up to receive our catalogue, placing an order (either through our physical catalogues or online), or when you reach out to us for any inquiries. Additionally, your information can be collected during phone conversations with our call center, through postal communications, or via interactions on the DRMG website.
Furthermore, we acquire certain information through collaborations with data alliances, which are elaborated upon in section 11 of this policy.
8. How do we use the personal data we collect about you?
We will use your Customer Personal Data in the following ways:
· Contact Data: We use this to set up and maintain your account, identify you as a returning customer, and send relevant account-related information.
· Contact, Order, and Billing Data: These details are used to process and fulfil any orders you make, provide requested services, manage payments, and address any post-sale queries.
· Order and Status Information: We keep you updated on your order's progress, address any related queries or issues, and ensure the delivery of your purchased items.
· Marketing and Preferences: Based on your purchase history and expressed preferences, we send you catalogues, promotional materials, and information about products or services we believe may interest you. This includes updates and offers from The Rewards Club Limited and its associated services such as Book Club, Gardening Club, Motor Club, Perx, Puzzle Book, Rewards Club, and Supercard.
· Product Updates: We inform you about any recalls or necessary information concerning products you've purchased.
· Customer Interaction Records: We maintain records of your transactions and interactions with us to better understand your needs and to improve our service offerings.
· Improvement and Development: We analyse your information to enhance our products and services, train our staff, and conduct performance monitoring.
· Legal Compliance: We process certain data to adhere to legal obligations.
Additionally, we may utilise your Billing Data for future purchases, either online or over the phone, to streamline your shopping experience with us.
9. What is the legal basis on which we process your personal data?
Data protection law provides that a company, such as DRMG, can only lawfully process personal data if it has at least one legally defined reason for doing so. The legally defined reasons we rely on are as follows:
· Consent: We process your personal data when you have explicitly consented to us doing so. This occurs when you provide your personal details for the purpose of ordering our products or services, creating an account, subscribing to our mailing list, or requesting a catalogue. Your consent is the foundation for sending you the requested products, catalogues, and additional information.
· Contractual Obligations: We may need to process your personal data to fulfil our contractual obligations to you. If you enter into a contract with us, or are considering doing so, this justifies our processing of your data to complete your orders or provide the services you have requested.
· Legitimate Interests: We process personal data based on legitimate interests, provided that our doing so is reasonably expected as part of operating our business and does not unduly affect your rights, freedoms, or interests. Part of our legitimate interests includes conducting marketing activities to inform you of products and services we believe may be of interest to you. This applies particularly if you are an existing customer or a potential customer who has expressed interest in our products, services, or the mail-order sector. In such cases, we may contact you by post or telephone to provide marketing materials and information about our offerings.
10. Marketing Communications and Your Preferences
If you are registered on our mailing list or are an existing customer, we may use your contact information to send you our catalogues and other promotional materials via post. Additionally, we might reach out to you by phone to discuss our products, services, and special offers.
From time to time, we may also send you emails and text messages about our products, services, and promotions that are similar to those you have previously purchased, including news, updates, and exclusive offers. However, we will refrain from sending you any marketing emails or text messages if you have indicated, at any time, that you do not wish to receive them. Furthermore, all our promotional emails and texts will provide you with the option to opt out, allowing you to instruct us to cease sending you further marketing communications.
To ensure the relevance of our communications, we may use your purchase history and website activity to tailor our marketing messages to your interests, a process known as profiling. This approach helps us make our communications more personal and relevant to you. If you would prefer not to be profiled in this way, please reach out to us by emailing DPO@therewardsclub.co.uk or calling 03451740580 . Note that if you opt out of profiling, we will no longer send you marketing communications, as we aim to avoid sending irrelevant content.
We conduct regular checks against the Telephone Preference Service and the Mail Preference Service to ensure we do not contact customers who have opted out of receiving marketing calls or mail.
We strive to use the most effective and convenient forms of electronic communication, which may include, alongside emails and text messages, other platforms like Facebook Messenger or WhatsApp.
You have the right to stop receiving marketing communications from us at any time. You can do this by following the methods outlined in section 3 or by clicking on the unsubscribe link provided in our communications.
We aim to process changes to your marketing preferences as swiftly as possible, typically within 30 days. However, there may be a short delay in implementing your preferences due to the scheduling of our mailings.
11. Who do we share personal data with?
DRMG may share Customer Personal Data with the Associated Companies. We may share Customer Personal Data with other businesses so that they can market and sell their products and services to their customers.
We provide Customer Personal Data to businesses which enable us to provide our products or services to you, including for example payment processors and delivery companies. We work with a PCI compliant payment processor to arrange your payments and we share your personal payments data with sub processors when necessary under strict data processing contracts.
We also outsource certain business functions (such as telemarketing, order fulfilment and certain CRM functions) to trusted third parties. To enable those third parties to carry out those business functions we either provide them with, or they receive from our customers, Customer Personal Data. Such third parties are data processors in relation to Customer Personal Data, which they acquire from us and we remain the data controller in relation to such Customer Personal Data. We have detailed contracts in place with such third parties which oblige them to fully comply with UK data protection laws.
We also share Customer Personal Data where necessary with organisations for the purposes of detecting and preventing fraud or other criminal conduct and/or in order to comply with our legal obligations.
We are members of a number of data alliances. Data alliances collect customer information from their members, including details of customer names and addresses (but not email addresses) and transactional history. That pooled information is then used by alliance members to better target customers with products and services that are more likely to be of interest to them. Alliance members are active in the charity, clothing, food and drink, finance, leisure, travel, gifts and gadgets, health and beauty, household goods, gardening, home interior, entertainment and mail order sectors. The data alliances we are members of include:-
- Abacus Alliance, a data sharing alliance run by Epsilon International UK Limited. A copy of Epsilon Abacus’s privacy policy can be viewed here: https://www.epsilon.com/abacus/services-privacy-policy
We also work with a variety of trusted partners across multiple sectors, including charity, financial, leisure, travel, gifts, health and beauty, household goods, gardening, home interiors, entertainment, and mail order. These partners offer products or services that we believe might interest you. Consequently, we might share your contact information with these entities. However, when you register with us, create an account, or purchase items, you have the option to opt out of having your contact data shared with these partners.
Should you receive marketing materials from our partners, you retain the right to opt out of future communications at any time by utilising the opt-out feature provided within their marketing materials. Our network of trusted partners includes sectors such as:
Retailers/Mail Order:
· Automotive
· Fashion/Clothing
· Household Items
· Gardening Supplies
· Gifts and Collectibles
· Beauty Products
· Food & Wine
· Gadgets
Charities:
· Animal Welfare
· Arts and Culture
· Community Support
· Environmental Conservation
· Support for the Elderly and Disabled
· Housing and Medical Aid
· Overseas Aid
· Public Service and Military Support
Lifestyle:
· Health and Wellbeing
· Leisure Activities
· Outdoor Adventures
· Entertainment Services
· Home Interiors
· Travel Services
Finance:
· Insurance (Home, Car, Pet, Personal)
· Banking Services
· Pension Plans
· Investment Services
· Claims and Legal Services
Please be aware that our data partner, Epsilon Abacus, may transfer data outside the European Economic Area (EEA). Such transfers are conducted with appropriate safeguards in place,
including the standard data protection clauses adopted by the EU Commission to ensure the protection of your personal data.
For more information about our data sharing practices, how to opt out, or about data transfers, please contact us on 03451740580, write to us at the address provided, or email us at DPO@therewardsclub.co.uk
12. What are your legal rights in relation to your personal data?
You have a number of legal rights in relation to the personal data we hold about you. These include:
· The right to be informed about how we process and manage your personal data. We comply with your rights in this regard by the publication of this privacy policy.
· The right to obtain a copy of any personal data about you which we hold at any time and to obtain certain information about how we process that data. This is called a Subject Access Request and you can submit such a request by emailing DPO@therewardsclub.co.uk
· The right to request that any inaccurate or incomplete personal data that we hold about you is corrected. You can update your personal data by emailing DPO@therewardsclub.co.uk
· In certain circumstances, the right to request that we erase or restrict our processing of personal data that we hold about you.
· The right to request the transfer of your personal data to you or to a third party.
· The right to request that we stop using your personal data for direct marketing or for purposes based on legitimate interests. You can tell us at any time to stop marketing to you by using any of the methods set out in section 3 above or by emailing DPO@therewardsclub.co.uk
· The right to require us to stop processing your personal data where you contest the accuracy of the information we hold about you.
· Where our processing of your data is based on your consent, the right to withdraw your consent at any time so that we then stop processing your personal data based on that consent.
· The right to have any decision, made solely on the basis of automatic processing of your personal data, reviewed by a human being, express your point of view on the decision, obtain an explanation of the decision and challenge it.
· The right to compensation in certain circumstances where we breach your rights relating to your information in a way that causes you damage.
If you would like to exercise any of your legal rights in relation to the personal data we hold about you, you can submit a request by emailing DPO@therewardsclub.co.uk
Generally you will not have to pay a fee to exercise any of your legal rights. However, we are entitled to charge a reasonable fee if any request is clearly unfounded, repetitive or excessive. We can also refuse to comply with an unfounded or excessive request. We may need to request information from you to confirm your identity, in order to make sure that personal data is not disclosed to someone who is not entitled to have it. We may also need to ask you for additional information to help us respond to your request. We will try to respond to your request within one month but, if the request is very complex or if you have made a number of requests, it could take longer. In such circumstances, we will explain to you why it will take longer to respond and we
will keep you updated.
13. How long will we keep your personal data?
We retain your personal data for as long as reasonably necessary to fulfil the purposes it was collected for and to enable us to comply with our legal obligations. Generally, we will keep Customer Personal Data for so long as the customer holds an account with us or if longer for up to six years after the last recorded transaction or interaction with the customer. Six years is the limitation period for a customer bringing a contract claim against us in relation to an order. At the end of this period, your personal data will be irretrievably deleted. In some circumstances, you can ask us to delete or anonymise your personal data earlier.
We don’t hold customer payment card data; this is encrypted and tokenised to ensure total security as soon as the customer payment transaction is completed.
14. How do we protect your personal data?
We take the security of your personal data very seriously. We use appropriate security measures to protect your personal data from unauthorised access, disclosure, alteration or loss.
All personal information you provide to us, which we store electronically, is stored on our private, secure network of computers. Access to our IT systems is password protected. Our IT provider regularly monitors our computer and network systems for possible vulnerabilities and attacks and use state of the art firewalls and anti-virus software, which is regularly updated.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
15. Where is your personal data processed?
We only process personal data in the UK or the EEA.
16. Personal Data of international customers
We are based in the UK and are committed to complying with data protection laws that apply in the UK. We do not take responsibility in relation to any other laws or regulations that may apply to personal data submitted from outside the UK and any person submitting any personal data to us from outside the UK is responsible for that personal data. Please contact us in any of the ways set out in section 3 above if you would like us to remove any personal data.
17. Changes to our privacy policy and updating your information
It is important that you update your personal data that we hold about you so that it is current and accurate. You can do this by emailing DPO@therewardsclub.co.uk
As we continue to develop our business and Website and take advantage of advances in technology, our privacy policy may change. This version was last updated on [date]. Any changes we may make to our privacy policy will be posted on this page and, if appropriate, we will notify any significant changes to you by email or in some other manner. Please refer to this page frequently for updates and changes to our privacy policy.
18. How do you make a complaint to the regulator?
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), which is the UK data protection supervisory authority, if you feel that your personal data has not been handled properly or if you are not happy with the way that we have responded to any request you have made relating to the personal data we hold about you. The ICO can be contacted by telephone on 0303 123 1113 or online at www.ico.org.uk/concerns. We would appreciate the opportunity to resolve any data protections issues with you, so please contact us in any of the ways set out in section 3 above, in the first instance.
Cookie Policy
Cookies and How We Use Them
What are cookies?
Computer cookies are small text files that a website transfers to your computer. Cookies cannot harm your computer and are anonymous. They do not contain any information that could be used to identify you, nor do they contain any confidential information such as your email address or credit card details.
Using cookies helps us to make our Website easier for you to use and helps us to give you a more personalised web experience, such as enabling us to present information about products and promotions, which we believe will be of more interest to you. Examples of our use of cookies include:
• Storing the content of your shopping basket as you proceed through 'Checkout' and so that it is available to you when you return to the Website.
• To record the areas of the site that you have visited and for how long, as well as the products that you viewed and those that you purchased. We use this information to help us improve the effectiveness of our Website design, to make it more accessible to our users and to improve the quality of service that we provide. We also use this information to inform the product recommendations you see while you are on our Website, in communications that we send to you, and in adverts that you see while on other Websites.
Are cookies safe?
Yes. The information stored in cookies is anonymous and secure. It cannot be used to identify you personally and cannot harm your computer.
Can I switch cookies off?
DRMG uses these cookies to make the DRMG Website easier to use and to allow it to provide the best possible standard of service. Cookies are an essential part of how our Website works.
However we require your consent to use them. To withdraw your consent, or if you want to be notified each time a cookie is about to be used, you should use the settings provided in your Website browser to prevent us from storing cookies on your computer. However if you choose not to consent to the use of cookies your experience of our Website could be impaired and it’s possible many important aspects of the site will not work at all.
DRMG Privacy Policy 29 February 2024
Direct Response Marketing Group Limited. Registered in England Company no. 06333962 VAT no. 917 7052 19
© 2024 Direct Response Marketing Group Limited. All rights reserved.