hottopdeal.com (“Hottopdeal”) are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018, once enacted. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised shopping experience.

We have published this notice to help you understand

• how and why Hottopdeal collect information from you;
• who we share your information with, why and on what basis; and
• what your rights are.

If we make changes to this notice we will notify you by updating it on our website. Hottopdeal will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Hottopdeal determines the purposes and way in which any personal data are, or will be, processed.

Should you need to contact us please write to: [email protected]

This privacy notice was last updated on 1st January 2019.

What information we collect when you register and why?

When you buy goods from us, you are entering into a contract with us. You will need to set up a Hottopdeal Account before ordering from us; so we can set this up we will ask you to provide some personal information such as:

• full name
• address (and previous addresses)
• date of birth
• contact numbers, and
• email address.

As an existing customer if you have shopped with us using a credit or debit card, or we have taken these details for a payment authorisation, we will securely collect and store this payment card information. New customers and existing customer whose payment cards have expired, you will be asked if you would like to automatically store these details in order to speed up the payment process. If you set up a direct debit payment, we will also collect bank details from you.

When you apply for a credit account, we get information about you from credit reference agencies. This is covered in more detail in the section- Who we share your information with and Why.

In order to undertake website personalisation, we will also gather information about the devices you use to access our sites (desktop and mobile), and this may include IP address. For further information on our use of cookies and tracking please see our Cookie Notice

When you shop in our stores Hottopdeal uses CCTV for security monitoring purposes.

How do we use your information?

Data Protection says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons and these are:

• Contract - your personal information is processed in order to fulfil a contractual arrangement e.g. in order to send you your Directory catalogue.
• Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
• Legitimate Interests - this means the interests of Hottopdeal in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Party’s such as delivery partners.
• Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.

Here is a list of the ways that we may use your personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.

What We Use Your Personal Information For	Our Reasons (Legal Basis)	Our Explanation Of Hottopdeal’s Legitimate Interests
Set up your Hottopdeal account	• Legitimate interest	Process efficiency in dealing with such activity.
Storing payment cards	Consent	N/A
Process your orders	• Fulfilling a contract	N/A
Notify you of your order status.	• Legitimate interests	Process efficiency in dealing with such activity, and to make improvements to our services.
Manage your account/ provide customer services to you. This may include: transfers to Third Countries who undertake customer services/communications activities call recording data verification customer complaints/queries	• Legal obligation/ Legitimate interests (depending on nature of services)	Keeping our records up to date, handling our customer contact efficiently and effectively, working out which of our products and services may interest you and telling you about them.
To detect, investigate and report financial crime (e.g. Fraud)	• Legal Obligation / legitimate interests	Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators such as the FCA. Complying with any regulations that apply to us. Process efficiency in dealing with such activity, and to make service and process improvements.
Undertake website personalisation and administration.	• Legitimate interests	Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites. Defining types of customers for new products or services
Marketing communications to inform you of special offers, promotions, new lines and Sales. Provide you with online advertising.	• Legitimate interests	Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.
Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you.	• Legitimate interests	Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.
Contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research.	• Legitimate interests	Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.
Maintaining network and data security	• Legitimate interests	To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.
Logistics planning, demand forecasting, management information and research	• Legitimate interests	We use information about shopping habits, products bought and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges.

Who we share your information with and why

Hottopdeal works with a number of trusted suppliers, agencies and businesses in order to provide you the high quality goods and services you expect from us such as delivery companies, credit reference agencies, fraud prevention agencies, product technicians visiting your home and market research companies amongst others. Some examples of the categories of third parties with whom we share your data are:

Supplier Partners

Hottopdeal works with a number of trusted partners who supply products and services on our behalf. All partners are subject to thorough security checks, and will only hold the minimum amount of personal information needed in order to fulfil the orders you place or provide a service on our behalf.

Delivery Partners

In order for you to receive your goods, Hottopdeal works with a number of delivery partners. Again, we only pass limited information to them in order to ensure delivery of your items.

IT Companies

Hottopdeal works with business who support our website and other business systems

Marketing Companies and Online Advertising

We work with marketing companies who help us manage our electronic communications with you or carry out surveys and product reviews on our behalf.

We use technologies such as cookies within digital marketing networks, ad exchanges and social media networks such as Facebook’s Custom Audience to get relevant marketing messages across to you. These messages may appear when you are on other websites or apps. Hottopdeal online advertising is intended to help you find what you are looking for and keep you up to date with news of products and services, including store events, offers and promotions by Hottopdeal. The online advertising you see will be based on any information we may have about you and your visit to the Hottopdeal website or app such as products you have looked at, search history or ads you have previously clicked on

Payment processing

Hottopdeal works with trusted third party payment processing providers in order to securely take and manage payments

Credit Reference Agencies

When you apply for credit with us we will make searches about you with credit reference agencies. We do this to make sure customers who apply for credit accounts are able to manage the level of credit offered and not committing fraud by providing false or inaccurate information.

In order to process your application we will supply your personal information to credit reference agencies (CRA’s) and they will give us information about you, such as your financial history. We do this to assess your creditworthiness and product suitability, check your identity, manage your account, trace, recover debts, and prevent criminal activity.

We will also continue to exchange information about you with the CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will be linked to the data of your spouse, any joint applicants or other financial associates

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at

Experian Credit Reference Agency Information Notice

CallCredit Credit Reference Agency Information Notice

Equifax Credit Reference Agency Information Notice

We will use automated credit-scoring methods to assess your application and to confirm your identity. We will automatically check your credit history against our lending criteria and if you don’t meet our requirements you will be declined for credit. For more information see the CRAIN notices above. There is also an automated decision section below with further detail. Should you wish to object to the use of automated credit scoring, please contact the Data Protection Officer.

Debt recovery and fraud prevention services

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Automated Decisions

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision-making: if you want to know more please contact us using the details above.

Consequences of Processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

Data Transfers

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

Your Rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the contact details above. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.

Transfers to third countries

Some of the information you provide to us may be transferred outside the European Economic Area such as India and the US. This is a transfer to a third country. Hottopdeal has a business relationship with Capita India who provides us with IT support, customer and supplier account administration services. Although the data is held in UK data centres colleagues in India may access it, for them to undertake the activities described above.

If you place an order with us and you are outside of the UK we will transfer the data that we hold on you to Hottopdeal. To find out more please contact us at [email protected]

Hottopdeal also works with suppliers and partners who may make use of Cloud and/or hosted technologies, we undertake data security due diligence on our partners, ensure that suitable contracts are in place and that these partners conform to appropriate accreditations.

Wherever these transfers take place Hottopdeal will have an appropriate contract in place and there are strict rules regarding the confidentiality and security of your information in place to safeguard it.

Keeping in touch with you

We want to keep you up to date with information about new ranges, special offers and improvements to our website. When you set your account up, we will ask you if you want to receive this type of marketing information.

If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at the address provided above, emailing [email protected].

You may continue to receive mailings for a short period while your request is dealt with

How long we keep your information

If we collect your personal information, the length of time we retain it is determined by several factors including the purpose for which we use that information and our obligations under other laws.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
• we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
• in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

What are your rights

You are entitled to request the following from Hottopdeal, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk

• Right of access –to request access to your personal information and information about how we process it
• Right to rectification –to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. Contact Call Centre 0333 777 8000
• Right to restriction of processing – to restrict processing of your personal information
• Right to data portability - to electronically move, copy or transfer your personal information in a standard form
• Right to object - to object to processing of your personal information
• Rights with regards to automated individual decision making, including profiling –rights relating to automated decision making, including profiling

If you have any general questions about your rights or want to exercise your rights please contact [email protected]

You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website www.ico.org.uk where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

Cookie Notice

This notice is designed to help you understand what cookies are, how Hottopdeal uses them and the choices you have regarding their use.

By continuing to use hottopdeal.com the “Site”, you are agreeing to our use of cookies in the manner described in this notice.

What are cookies?

Cookies are small text files that are stored on your browser or the hard drive of your computer or other device when you visit the Site, this allows the Site to recognise you as a user either for the duration of your visit (using a ‘session cookie’) or for repeat visits ( a ‘persistent cookie’). They are not harmful and do not contain any information such as your home address, date of birth or credit card details.

The cookies we use fall into four broad types:

Strictly Necessary Cookies

These cookies are essential in helping you to move around our Site and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, such as setting up an account cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you've been on the internet.

Analytical/Performance Cookies

In order to keep the Site, its services and products relevant, easy to use and up-to-date, we use web analytics services to help us understand how people use our Site. For example, we can see which parts of the Site and products are most popular, identify when errors occur, and test different versions of a page or feature to see which one works best.

Functionality Cookies

These cookies allow websites and applications to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect is usually anonymised which means we can't identify you personally. They do not gather any information about you that could be used for selling advertising or remembering where you've been on the internet, but do help with serving advertising.

Targeting Cookies

We also use cookies to assist in targeted advertising. Although these cookies can track your visits around the web they don't know who you are. Even if you sign in to your Hottopdeal account, the data is not linked to your profile. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. We also use them to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you.

What do we use Cookies for?

• They enable you to transact whilst other non-essential cookies enable us to give you and enhanced, personalised web experience and determine relevant products to show you.
• To personalise and improve your customer experience.
• To allow you to securely sign in to your Hottopdeal Directory Account, so that you can use "My Account" features such as order information, making payments and viewing statements.
• To recognise the device that you are using.
• To store the content of your online shopping bag whilst you browse the site and to complete an order.
• To record the areas of the Site that you have visited, products you have viewed and time spent browsing, as well as the products you purchased. Hottopdeal uses this information to help make the website more user friendly, develop our Site design and to continuously improve the quality of the service we provide.
• To distribute visitors to our Site evenly across platforms to ensure the content is served at the fastest possible speed.
• For re-marketing purposes to determine relevant related products to show you when you're browsing on other selected websites. These cookies can be associated with services provided by a third party such as an advertising network.
• We also offer you the facility to share your experience on our Site through social media sites such as Facebook and Twitter. By using these features, you are consenting to allow cookies from these providers. More information about how these providers use cookies can be found at their websites. By using these features, you are consenting to allow cookies from these providers. More information about how these providers use cookies can be found on their websites.

Cookies are an essential part of how our Site works, as they remember certain information about a visitor.

Hottopdeal uses its own 1st party cookies these are placed there and used solely by Hottopdeal. We use the Facebook Pixel, which uses both 1st Party and 3rd party cookies, as well as other Third-Party cookies (these are placed there by the third parties we work with, listed below).

Are cookies safe?

Yes. The information stored in cookies is safe and anonymous to any external third party, and your account security is never compromised. You can find more information about cookies at http://www.allaboutcookies.org/ and www.youronlinechoices.com/. For a video about cookies visit https://www.google.com/intl/en-GB/policies/technologies/cookies/

Can I turn off cookies?

Yes – but if you choose not to allow the use of cookies, your experience of our Site will be limited and many integral aspects of the Site, including (but not limited to) adding items to your shopping bag and accessing your account, will not work at all.

To change your cookie settings, or if you want to be notified each time a cookie is about to be used, you should amend the settings provided in your web browser to prevent us from storing cookies on your computer hard drive.

For information on how to disable cookies, please consult the "Help" tab of your browser via the menu bar. For further information on non-essential cookies used for targeting and banner advertising please see below.

Opting Out

Website visitors who don’t want their data used by Google Analytics can install the Google Analytics opt-out browser add-on. To opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. Learn more about the opt-out and how to properly install the browser add-on here.

Visitors can also opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings

This Cookie Notice was last updated on 9th November 2018 and further changes will be communicated by updating this notice.

Contact

Should you need to contact us please write to: [email protected].