- What is Comfort Click Ltd?
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- Combining your data for personalised direct marketing
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Contacting the Regulator
- If you live outside the UK
- Any questions?
We realise that you will see a lot of information on this page, but we want you to be informed about your rights and how Comfort Click uses your data. We will also tell you how we combine data across our different websites to build a picture of you.
We trust that the sections below will answer any questions that you may have. If you feel that you want to know more about something more specific, we are happy to help.
Our products are aimed at those aged 18 and over.
When you are using Comfort Click's websites, Comfort Click Ltd is the data controller.
Comfort Click is a UK based company and therefore, when visiting our websites, personal data that we may collect through cookies or online forms will leave the EU and other parts of the World for the UK.
Comfort Click Ltd – which we’ll refer to as ‘Comfort Click’ within this document – is made up of a number of related businesses:
Comfort Click has associated companies that include Click Leaf Ltd, Le Luna Ltd and Wisby Ltd. These companies have common ownership and are either similar types of businesses or have been formed for assisting the other companies mentioned. Whenever we refer to Comfort Click, we refer to all of the entities mentioned above.
To make it easy for you when read this policy, 'we' and 'us' means Comfort Click and it's various brands.
The law on data protection lists a number of different reasons for which a company may obtain, collect and process your personal data including;
In certain situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll make clear to you which data is necessary in relation to a particular service.
In cetain situations, we may need your personal data to comply with our contractual obligations.
For instance, if you order an item from us for home delivery, we will collect your address details to deliver your purchase, and pass them to our courier, postal companies and fulfilment company.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting our company to law enforcement. This is by using our legitimate interest.
In specific situations, we require your data to pursue our legitimate interests in a way that may reasonably be expected as part for the running of our business and which does not materially impact your rights, interests or freedom.
For example, we will use your purchase history to send you or make available personalised offers.
We will send you direct marketing emails when you shop with us and do not choose to opt out - this is commonly referred to as a 'soft opt in'.
From time to time, we combine the shopping history of many customers to identify trends and make sure that we can keep up with demand as well as develop or buy in new products.
With your consent, or when you shop with us and do not choose to opt out from receiving our emails ('soft opt in'), we will use your personal data, preferences and details of your transactions to keep you informed by email, websites, SMS and by telephone about special offers, discounts, promotions, competitions and new products that we believe to be suitable for you.
The law that we use will be English law.
- When you visit any of our websites, and use your account to buy products and services, or redeem vouchers/promo codes from Comfort Click on the telephone or online.
- When you buy something online and use the checkout as a guest (i.e. without logging in).
- When you create an account with us.
- When you buy online, we capture information via cookies and similar technologies, you can manage these when you visit our website.
- When you buy a product via the telephone but don't have (or don't choose to use) an account.
- When you engage with us on social media platforms such as Facebook and/or Instagram amongst others.
- When you join our loyalty programme.
- When you sign up to our Email Newsletters or sign up to have an account.
- When you contact us by any means with queries, complaints, suggestions etc.
- When you enter competitions or prize draws.
- When you complete any surveys that we send you.
- When you comment on or review our products or our entire service.
- Any individual may ask for the personal data that we hold relating to them. If your review or comment includes information about a partner of ours who provided that service, it may be passed on to them upon request.
- When you’ve authorised a 3rd 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
- Your name, gender, date of birth, billing/delivery address, orders, receipts, email, preferred methods of payment and telephone numbers.
- For your security, we will keep an encrypted record of your login password.
- Details of your interactions with us either online, in person or by telephone.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, promo code redemptions, brands that you show interest in, web pages you visit and how and when you contact us.
- Any items you may have added to your wish list or rather a list of items that you have demonstrated an interest within.
- Copies of documents you provide to prove your age or identity where the law requires this (including your driving licence and/or passport and utility bills). This will include details of your full name, address and date of birth. If you provide a copy of your passport, the data will also include your place of birth, gender and nationality.
- Information on your shopping preferences.
For example, which of our websites that you prefer to visit and where you redeem any promo code vouchers.
- Details of your visits to our websites, and also which website or search engine you came from to ours.
We will only ask for and use your personal data collected for suggesting products of interest and for tailoring your shopping experience with us. Of course, it’s your choice whether you share any such details with us.
- We will not store your card data, however we will store your known payment method.
- Your product reviews and comments.
- To deliver an ultimate website experience, we collect technical data about your internet connection and browser as well as the country where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. We will also collect simulation videos of your experience with us to understand shopping behaviours.
- Your social media handle or username, should you engage with us through this channel (via all platforms), to help us respond to your feedback, comments or questions.
We want to give you the very best possible experience. One way to achieve that is to get the richest and most complete picture that we possibly can of who you are by combining the data we hold about you.
We then use this to offer you promotions and products that are most likely to interest you. In the case of members (those that create accounts with us), we’ll try to offer you relevant rewards.
The data privacy laws allow this as part of our legitimate interest in understanding our customers and providing the highest possible standards of service.
If you want to change how we use your data, you’ll find details in the ‘What are my rights?’ below.
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 or expect.
Here’s how we’ll use your personal data and why:
- To process any orders you make by using our websites. 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. For example, your details may need to be passed to a third party to supply or deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
For example, your details might be needed so they can be passed onto a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees, warranties and so on.
- So we can 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 over time and with completeness. 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 possible service and understanding how we can improve our service based on your experience on our website and also on telephone calls with us or live chats.
- 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 in relation to where your delivery is and when your order is likely to arrive.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and protect your account. We’ll also keep an eye on your browsing activity with us to identify and fix any problems and protect the integrity of our websites. We will do this as part of our legitimate interest.
For example, by checking your password when you login and using monitoring of internet protocol (IP) addresses to identify possible fraudulent log-ins from unexpected locations.
- To process payments and to stop fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect customers from fraudulent activities.
- If we discover any criminal activity or alleged criminal activity through our use of fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We 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 about relevant products including personalised offers, discounts, promotions and competitions.
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 and products. We’ll do this on the basis of our legitimate business interest.
- To display the most interesting content to you on our websites, we’ll use data we hold about your favourite brands and/or products. We do so on the basis of your consent to receive for our website to place cookies or similar technology on your device.
For example, we may display a list of items you’ve recently looked at, or offer you suggestions based on your purchase history and any other data you’ve shared with us.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering the event.
- To develop, test and improve the systems, services and products we offer to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll save your browser’s Session ID to help us understand more when you leave us online feedback about any problems that you’re having
- To comply with our contractual or legal obligations to share data with law enforcement agencies and authorities.
For example, when a court order is put forward to us to share data with law enforcement agencies or a recognised court of law.
- 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 and services more relevant to you.
- To build a rich and more complete picture of who you are, what you like and prefer, and to inform our business decisions, we’ll combine data captured from across our company, 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 example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different geographical areas. This may then guide which products we display on localised websites and/or certain categories within them and other brands that we trade from.
- For our member or logged in area, to decide which information to show you, with the help of technological algorithms. We do so on the basis of your consent when you become a member by creating an account. If you don’t want to continue receiving offers, you’ll be unable to continue your account with us.
For example, if you consent through our website, we may use your shopping preferences to offer you tailored rewards.
- Sometimes, we’ll need to share your details with a third party who is providing a service (such as a delivery courier). Without sharing your personal data, we’d be unable to fulfil your request for a delivery on particular times and dates.
- Help inform business decisions for example which 3rd Party websites we partner with to make sure that our advertising reaches our customers.
Across Comfort Click, we record your interactions with us e.g. looking at how often you might shop with us or how much you spend. We do this to create a profile on how you interact with us and in turn, that can affect how we engage with you. For example, if you shop with us regularly, then this can affect what offers and rewards you may get from us. We rely upon our legitimate interest to undertake this activity.
When you purchase a product from us that is delivered by the manufacturer or supplier, we will pass on your contact details so that they can deliver your purchased product. The same with regards to warranties provided by the manufacturer or supplier of the product you purchased. We do this to make sure that we fulfil our contractual obligations to you.
If the manufacturers or suppliers wish to pass your details to other third parties, or use it for any other purpose, they must provide you with sufficient information about who they share your personal data with, and for what purposes they intend to use it, and in some cases they may be required to ask for your consent to do so. If they do not provide you with that information or collect your consent, and you are worried that they may have shared your personal data with someone else, you are entitled to contact them directly for further clarity.
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 websites as described above, for example your shopping history at our Websites. 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.
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 careful steps to protect it.
We secure access to all transactional areas of our websites using SSL certification (or otherwise known as) ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks to identify ways to further strengthen security.
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.
Examples of data retention periods;
When you place an order with us, we will keep the personal data that you give us for five years so we can comply with our legal and contractual obligations. In the case of certain products, such as electrical items, we’ll keep the data for 10 years.
If your order included a warranty, the associated personal data will be kept until the warranty expires.
We will only share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the rule we apply to those third parties to keep your data safe and to protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or made anonymous.
Examples of the kind of third parties we work with are:
- Technology related companies that support our website and other business systems that we use.
- Operational companies such as couriers, postal companies and fulfilment companies (that pick and pack your order).
- Marketing companies who help us manage our electronic communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
- Data insight companies to ensure your details are up to date and accurate.
- 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 authorities.
- 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 account.
- For further information please contact us.
To help personalise your journey through our websites we currently use the following companies, who will process your personal data as part of their contracts with us:
Comfort Click 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 not in the UK.
For instance, this might be required in order to fulfil your order, process your payment details or provide support.
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.
You have a right to ask for;
- 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 expiry of a warranty).
- A computer file in a common format (CSV, GSHEET, PDF 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 certain circumstances, generally while we are deciding on an objection that you have made.
- We stop processing your personal data, in certain circumstances; for example, when you have withdrawn consent, or object for reasons related to your own reasoning.
- That we stop using your personal data for direct marketing (either via specific channels or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and appropriate criteria for a decision).
- You can contact us to request to exercise these rights at any time by contacting us.
- If we choose not to action your request, we will explain the reasoning for our decision to refuse.
Your right to remove consent
Where you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw this 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, health reasons or similar.
You do have the right to stop the use of your personal data for direct marketing activity through all channels, or specific channels that are used. We will always comply with your request.
Checking your identity
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 for you.
There are a few ways that you can stop direct marketing communications from us;
- Click the ‘unsubscribe’ link in any of our email communications that we send you. We will then stop any further emails from that particular brand of our business.
- If you have an account, log in and change your preferences.
- Write to us at Comfort Click, 106 Lower Addiscombe Road, Croydon CR0 6AD, UK.
You may continue to receive communications for a little while after changing your preferences whilst our systems become updated.
If you feel that your data hasn't been treated properly, 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 ICO.
You can contact them by calling 0303 123 1113.
Or visit ico.org.uk/concerns
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.
For all non-UK customers
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods that you have requested. In our normal course of business, we will transfer your personal data to the UK and may also transfer your personal data to third parties located in the UK and elsewhere and to your country of residence.
We shall try to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your personal data other than for the services they provide and for which they need the personal data, and to adequately protect the confidentiality and privacy of your personal data.
We will ensure that any third parties only process your personal data in accordance with their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside. We do not actively take steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
EU & EEA Countries
If you have any questions,please contact our Data Protection Officer who would be delighted to help:
- Email us using the address email@example.com
This policy had it's last update on 30/01/2021.