Customer Privacy and Cookie Notice

We take the privacy of your personal data very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint about the use of your personal data.

The controller for your personal data is Robinson Webster (Holdings) Limited (Jigsaw).

If you have any questions about this privacy notice or the personal data, we use about you please contact us using the details below:

• by email to: [e-mail] or
• by writing to: Data Protection Officer, Jigsaw, 3 Water Lane, Richmond, TW9 1TJ.

For EEA Residents: Please contact our EU Representative at [e-mail]. Alternatively, they can be reached via our Dublin Store: 34 South Anne Street, Dublin, Dublin 2, Eire

If you have any concerns about the way we have handled your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, by contacting them at www.ico.org.uk.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We regularly review this privacy notice and will update it where necessary. This privacy notice was last updated on 6 January 2023.

1. When will this privacy notice apply?

This privacy notice will apply to the personal data we collect and process when you:

1. visit www.jigsaw-online.com (Our Website);
2. purchase clothing from Our Website;
3. make an instore purchase at one of our Jigsaw stores;
4. provide details to our retail staff to enable them to assist with a purchase or enquiry;
5. sign up to receive communication from Jigsaw either via Our Website or in store;
6. speak to a member of the Jigsaw team on the telephone (which may be recorded for quality and monitoring purposes);
7. email our customer service team regarding purchases or make an enquiry relating to Jigsaw;
8. enter a competition or prize draw with Jigsaw; or
9. request a digital receipt for instore purchases.

This privacy notice also applies when we obtain your personal data from a third party source for marketing purposes. For example, Experian provides Jigsaw with a list of names and postal address to enable Jigsaw to send its catalogue to individuals who may be interested in hearing about Jigsaw's new collections.

If you receive a catalogue from Jigsaw and you do not wish to receive further catalogues, you can opt out by following the link www.jigsaw-online.com/postal-unsubscribe.

2. What is the lawful basis for using your personal data?

Processing of personal data will be lawful only if one or more of the following lawful bases for processing applies:

1. processing is necessary for the performance of a contract which you are party to or to take steps at your request prior to entering a contract;
2. for compliance with a legal obligation to which Jigsaw is subject;
3. for the purposes of Jigsaw’s legitimate interests or those of a third party (such as advertising agencies), but only if these are not overridden by your interests, rights or freedoms; or
4. you have given your consent to the processing of your personal data for the processing detailed in this privacy notice.

The table below sets out the personal data we process, why we use your personal data and the lawful basis we will rely on.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose in this privacy notice.

Personal data	What we use your personal data for	Lawful basis
Basic contact details as provided to us by you: full legal name; telephone number; email address; and postal address*	To enable us to process your online or in store purchase To enable your purchased item to be delivered To contact you to resolve any issues regarding your order	For the performance of our contract with you or to take steps at your request before entering into a contract
	To enable us to contact you via your preferred contact details To keep you updated about out of stock items To keep you updated on new products, services and offers To provide an alteration service for garments purchased To book in store style appointments To send you a digital receipt To send you a service feedback request form To answer any query, you have raised with us not relating to an order	For our Legitimate interests to enable us to provide a high standard of customer service to you and keep up to data with the latest products and services of Jigsaw.
	To enable us to identify you and notify you as a winner in a jigsaw competition that you have entered	For the performance of our contract with you or to take steps at your request before entering into a contract
Transactional and billing information*	To take payment purchases	For the performance of our contract with you or to take steps at your request before entering into a contract
	To prevent and detect fraud against you or Jigsaw	For our legitimate interests or those of a third party, to minimise fraud that could be damaging for us and for you
	To record and monitor purchases	For our legitimate interests or those of a third party to minimise fraud that could be damaging for us and for you
	Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations
Your feedback on your purchases or shopping experience, including your purchase and personal opinions	To improve our products and services based on customer feedback	For our legitimate interests to improve our products and ensure we deliver the best service to you
IP address using Our Website*	Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, to prevent and detect criminal activity that could be damaging for us and for you
	To monitor use on Our Website	For our legitimate interests to analyse or customer spend and behavior to improve our services
Call recording to stores and customer services*	To improve Jigsaw’s customer service	For our legitimate interests to ensure we are constantly providing a high level of customer service and can appropriately respond to customer queries
Your contact history, purchase history and saved items	To analyse customer behavior and to ensure we send you the most appropriate and relevant information regarding promotional offers	For our legitimate interests making sure that we can keep in touch with our customers and send them relevant information about existing orders and new products
Marketing preferences	Updating and enhancing customer records	For our legitimate interests or those of a third party, making sure that we can keep in touch with our customers about existing orders and new products
	To maintain a suppression list ensuring we are not sending marketing information to individuals who have opted out	To comply with our legal and regulatory obligations
	To enable you to refer a friend and receive incentives	For our legitimate interest to enable us to increase our database to individuals who would be interested in hearing about Jigsaw

3. What personal data must you provide to us as part of a statutory/regulatory or contractual requirement?

In certain circumstances you may be obliged to provide us with personal data and if you fail to provide the personal data, when requested, we may not be able to fulfil your purchase order or assist with your enquiry. Where this is the case we have identified these instances in the table above with an “*.”

4. Credit card and debit card information

All payment details are sent to and managed securely by our third party payment service provider. Jigsaw will only retain the card type and last four digits as a reference of the purchase.

5. What special category or criminal data does Jigsaw process about you?

We do not collect or process any special category or criminal data relating to our customers.

6. CCTV in our stores

It is not standard practice for our retail stores to use CCTV. Currently CCTV is only installed in Jigsaw Bellevue Road.

Jigsaw does not access CCTV recordings unless required for security purposes. This data is erased after two weeks unless it needs to be referred to due to a suspected incident or for some other legal reason.

7. Promotional communications and direct marketing

When we are permitted to do so we may use your personal data to send you updates (by email , or post) about our products and services, including exclusive offers, promotions new products and products you may have shown an interest in buying.

8. What are cookies and how are these used?

Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognise the device when it visits websites or uses online services. Jigsaw’s website may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all of our other cookie uses. Where we have your consent to do so, we use cookies to collect statistical information about website visits. We use this information to help us assess the effectiveness of our marketing strategies and to help us to improve our website.

You can see an up-to-date list of the cookies that we use on our website in the Cookie Declaration and manage your preferences. You can also click on this link to view a current up-to-date list and manage your preferences.

9. Who we share your personal information with?

We will share your personal data with other companies in order for them to fulfil services for us.

We share your personal data with the below companies:

1. our delivery providers;
2. our online payment providers;
3. our customer issue tracking tool provider, this includes our call recordings;
4. our customer reviews provider
5. our customer database system providers;
6. our digital marketing tool providers, such as email service provider;
7. our website platform provider;
8. our website app providers, for services such as wish list and reserve in store;
9. our order fulfilment providers, such as ship-from-store providers;
10. marketing service providers, for example those used to help us generate online advertisements or send catalogues.

We only allow our service providers to handle your personal data on our behalf if we are satisfied they will take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they only use your personal information to provide the requested service. They are not able to use your personal data for their own purposes unless you have a separate agreement with them directly to provide a service in their own right. These might include payment service providers with whom you have signed up for an account, such as Amazon Pay, PayPal, Klarna or others.

In certain circumstances we may disclose and exchange information with law enforcement agencies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

10. Sharing your personal data Epsilon Abacus (registered as Epsilon International UK Ltd)

We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate. Epsilon Abacus processes this information as a processor on behalf of these companies to help them understand individuals’ behavior and preferences. Epsilon combines information provided by participating retailers and charities with third party data. From this combined information, these companies can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here: https://www.epsilon.com/abacus/services-privacy-policy

Please note, that we only share personal data that is strictly necessary to support postal communications. Your email address and phone number will not be shared with the members of the Abacus Alliance and you will not receive any electronic marketing as a result. If you do not wish to be contacted by post by other companies, you can let us know by

a) opting out using the option on the payment page; or

b) emailing [e-mail]

11. Sharing your data with Meta Platforms

We place adverts on Meta platforms (Facebook and Instagram) (Meta). To make sure our adverts are seen by people who are most likely to be interested in them, we share your ‘hashed’ email address with Meta. Emails are hashed so that they are secure. Meta uses hashed email addresses to match our customers with Meta accounts so that we can serve our adverts to you via Facebook and Instagram.

Meta also uses hashed email addresses to analyse our customers so that we can target adverts to individuals who share similar interests or characteristics.

If you do not want your information to be used in this way you can opt out at any time by emailing [e-mail].

Jigsaw also shares personal data with Meta to help us measure how successful the adverts that we place on Meta platforms are. To do this we share information such as name and email address of customers who have been active on our website. Meta uses this information to identify if any of those customers have interacted with an advert on one of the Meta platforms. This enables us to understand how successful our Meta adverts are.

Meta does not share any identifiable personal data with us.

How long will your personal data be kept?

We will only keep your personal data for as long as is necessary for the purposes for which it was collected. In order to determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of your personal data. We will also consider legal and regulatory requirements, for example where the law says we must keep your personal data for a certain period.

12. Transferring your personal data out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK.

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK;
2. Where we use third parties outside of the UK, we may use specific contracts approved under UK law, these are sometimes known as standard contractual clauses which give personal data the same protection it has in the UK.

If you would like more information about the methods used to transfer your personal data outside of the UK, please contact us at [e-mail].

13. Keeping your personal data secure

We have appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

14. Your rights relating to your personal data

You have a number of rights in relation to how we use your personal data.  These are as follows:

1. your right to request access to your personal data – you have the right to know how we are using your personal data, a right to see a copy of the personal data we hold for you and a right to be provided with additional information, for example, about how and why we are using your personal data and who it is being shared with.
2. You have the right to request that any inaccurate personal data is amended – if you think that any of the personal data that we hold about you is wrong or incomplete then you have the right to tell us and we have to ensure that the personal data we have is reviewed and if necessary, amended to ensure it is correct.
3. You have the right to ask for your personal data to be deleted – in certain circumstances, you can ask us to delete your personal data where there is no good reason for us to hold or use this anymore, where:
   1. we are using your personal data because you provided us with your consent to use it in this way and you withdraw your consent; or
   2. where you have challenged our use of your personal data and there are no good reasons for us to process your personal data.
4. This does not apply to all of your personal data, as we may need to still keep your personal data, for example, to comply with laws.
5. You have the right to request restriction of processing your personal data – this right allows you to ask us to put processing on hold so:
   1. we can establish if the personal data that we have about you is correct;
   2. we can investigate any objection you have made about the use of your personal data; or
   3. if we have no justification for keeping it any longer you may ask us to put the processing on hold but retain the personal data in case you need this, for example, for legal reasons.
6. You have the right to have your personal data sent to another organisation – in certain circumstances, you have the right to get your personal data from us in a way that is accessible and machine-readable, and you also have the right to ask us to transfer your personal data to another organisation. This only applies to personal data that you have provided to us and which is held electronically. We only have to comply with this right if it is technically feasible to provide this personal data in a commonly used format, for example, a csv file.
7. You have the right to object to the processing of your personal data – you have the right to tell us about any concerns regarding the processing of your personal data and to ask us to stop using your personal data. This includes objection to marketing.

If you would like to exercise any of those rights please contact us by email to [e-mail]