1. Introduction
  2. What is Banburys Ltd
  3. Explaining the legal bases we rely on
  4. When do we collect your personal data?
  5. What sort of personal data do we collect?
  6. How and why do we use your personal data?
  7. How we protect your personal data
  8. How long will we keep your personal data?
  9. Who do we share your personal data with?
  10. What are your rights over your personal data?
  11. How can you stop the use of your personal data for direct marketing?
  12. Contacting the Regulator
  13. Any questions?
  1. Introduction

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 will store and handle that data, and keep it safe.

We know that there is a lot of information here, but we want you to be fully informed about your rights, and how Banburys Ltd uses your data.

We hope the following sections will answer any questions you have but if not, please do not hesitate to contact us.

It is likely that we will need to update this Privacy Notice from time to time.  We will notify you of any significant changes, but you are welcome to come back and check it whenever you wish.

         2.What is Banburys Ltd?

Banburys Ltd is a family owned limited company with retail department stores in Barnstaple and Tiverton, along with a removals business.

For simplicity throughout this notice, ‘we’ and ‘us’ means the Company and its brands.

  1. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:


In specific 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 always make clear to you which data is necessary in connection with a particular service.

Contractual Obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if you order an item from us for home delivery, we’ll collect your address, and telephone, details to deliver your purchase, and pass them on to our warehouse.

Legal Compliance

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 Banburys Ltd to law enforcement.

Legitimate Interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact on your rights, freedom or interests.

We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.

We will also use your address details to send out your Loyalty Vouchers by post, along with direct marketing information telling you about product and services that we have available at that time.

  1. When do we collect your personal data?


  • When you join our Loyalty Card scheme
  • When you enter prize draws or competitions
  • When you choose to complete any surveys we send or ask you to complete in store
  • When you choose to request a quote for a removal, or household storage
  • When you comment on or review our products and services
  • When you book any kind of appointment with us or book to attend an event, for example a Beauty Treatment, Personal Shop, Carpet measure, etc.
  • When you purchase a product or service by phone
  • When you engage with us on social media
  • When you contact us by any means with queries, complaints etc.
  • When you ask one of members of staff to email you information about a product or service.
  • Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about the member of staff who provided that service, it may be passed on to them if requested.
  • When you fill in any forms. For example, if an accident happens in a store your personal data may need to be collected for Health & Safety reasons.
  • When our finance provider shares information with us about the product you have purchased through our Interest Free Credit offer.
  • We collect data from publicly-available sources (such as Land Registry) 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 stores which usually have CCTV systems operated for the security of both customers and staff. These systems may record your image during your visit.
  1. What sort of personal data do we collect?
  • If you have a Loyalty Card with us: your name, date of birth, address, email and telephone numbers

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, voucher redemptions, brands you show interest in, how and when you contact us.

  • 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.

For example, you might tell us your clothing size, which we’ll use to guide our Personal Shopper.  Or you might share information on your skin type which allows us to recommend appropriate beauty brands.

We will 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 is always your choice whether you share such details with us.

  • Your comments and product reviews.
  • Your image may be recorded on CCTV when you visit a store
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
  1. 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 Card 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.

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your consent to hear from us.

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

  • To process any orders that you make by using our website or in store.  If we don’t collect your personal data during this process, 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 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 and so on.

  • 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 obligation 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 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.
  • To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our stores which record images for security.  We do this 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, we will use your personal data to keep you informed by email about relevant products and services including special offers, discounts, promotions, events, competitions and so on.

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

  • To send you relevant, personalised communications by post in relation to updates, offers, services, products and Loyalty Vouchers.  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 Policy Notice, product recalls, 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 did not use your personal data for these purposes, we would be unable to comply with our legal obligations.
  • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering
  • To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a 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 or services more relevant to you.

Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences with us.

  • 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 the 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.
  • To process your booking/appointment requests (for example, with a personal shopper).  Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery personnel or fitter visiting your home).  We do so to maintain our appointment with you.  Without sharing your personal data, we’d be unable to fulfil your request.
  1. 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 appropriate steps to protect it.

We secure access to all transactional areas of our website using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

  1. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for a long as is necessary for the purpose for which it was collected.

At the end of the 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.

Some examples of customer data retention periods:


When you place an order, we’ll keep the personal data you give for five years so we can comply with our legal and contractual obligations.  In the case of certain products, such as electrical, we’ll keep the data for 10 years.


If your order included a warranty, the associated personal data will be kept until the end of the warranty period.

            9.Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.

For example, delivery personnel, removals porters, carpet fitters, for fraud management, to handle complaints 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 data held by them will either be deleted or rendered anonymous.
  • We will not share your data with third parties for their own purposes and or benefit.

We will only share your data in very specific circumstances, for example:

  • 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 personal data to the police or other enforcement, regulatory or Government body 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 Company 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

              10.What are your rights over your personal data?

An overview of your different rights

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.
  • 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).
  • 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.

You have the right to request a copy of any information about you that the Company holds at any time, and also to have that information corrected if it is inaccurate.  To ask or your information, please contact Data Protection Officer, Banburys Ltd, 32/33 High Street, Barnstaple, EX31 1BN, or email  This email address can also be used to ask for your information to be amended.

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

Your right to withdraw consent

Whenever you have given us your consent to use our personal data, you have the right to change your mind at any time and withdraw consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of out 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.

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 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.

                11.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.
  • Write to Customer Data, Banburys Ltd, 32/33 High Street, Barnstaple, EX31 1BN

Please note that you may continue to receive communication for a short period after changing your preferences while our systems are fully updated

                  12.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 (opens in a new window; please note we can’t be responsible for the content of external websites)

                   13.Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will endeavour to answer your query:

  • Or write to us at Data Protection Officer, Banburys Ltd, 32/33 High Street, Barnstaple, Devon EX31 1BN

This notice was last updated on 19/05/2018