Date: 1st February 2023                                                                                   

Date of next review: February 2024

WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN (trading as James Meade) ("We", "the Company", “James Meade”) are committed to protecting and respecting the confidentiality, integrity and security of the personal information we hold about each past or present customer, enquirer or visitor to our website ("you", "your"). 

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how we comply with our responsibilities under applicable data protection laws ("Data Protection Laws"). Please read this policy carefully and if you have any questions or concerns please contact us using the information below. 

Data Controller

For the purposes of the Data Protection Laws, the data controller of your personal information is WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN.

Personal data collection

We only hold personal data about you which you have provided to us or to one of our authorised data processors or has been collected via social media metadata.

Categories of personal data we may collect and hold 

We may collect the following information from our customers:

• name;
• contact details including billing and delivery addresses;
• purchasing histories;
• credit card details if applicable; and
• social media metadata

Purposes for which your personal data is used 

• We will use the personal data which you provide to us for the following purposes:-
• allowing us to process brochure requests and deliver sales orders;
• identifying you automatically using your telephone number when ringing customer services;
• taking payments in relation to the purchase of products;
• fulfilling our lifetime product guarantee in respect of returns and replacements;
• sending you our postal catalogues and email newsletters;
• providing postal communications from third parties that we think may be of interest to you;
• undertaking customer research;
• de-duping against alternative and our own databases;
• preventing fraud and enhancing the security of our networks;
• understanding how our customers interact with our websites and personalising their repeat visits;
• inter-acting with you on social media;
• determining the effectiveness of our promotional campaigns and advertising;
• comparing to pooled information held within the data co-operatives to understand customer buying habits
• ;responding to queries and complaints; and
• fulfilling our legal and fiduciary responsibilities.

Legal basis for Processing 

• In processing customer data WCF relies on the following legal bases:
• Where it is necessary for the performance of our contract with you;
• Where it is necessary for compliance with our legal obligations;
• Where it is necessary for the purposes of our legitimate business interests, which include maintaining direct, relevant and appropriate contact with our customers to enable us to give them the best and relevant service and products; or
• Where you have given your consent for the processing of your personal data.

We may process customer data on more than one legal basis. Please contact us if you need details as to which legal ground we are relying on to process any specific item of personal data. 

Where we rely on consent to send marketing communications, you have the right to withdraw your consent at any time by contacting our customer services department or updating your marketing preferences online.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you at the time.

Disclosure of your personal data 

We will not disclose personal information we hold about you to any third party except as set out below. 

We may disclose personal data to third parties who are providing services to us, in particular to the IT companies that support our order processing and ecommerce systems, to the mailing houses and postal services that distribute our catalogues and products and to payment processors for the purposes of order payments and refunds. We also regularly de-dupe our customer databases against the Mail Preference Service and register of deceased and gone always to ensure that our database is as accurate as it can be and that we are not mailing those customers who do not wish to be contacted. Where we have obtained your consent, we may also share your data with data co-operatives to understand your buying habits and provide you with the opportunity to receive postal mailings from third parties which we think will be of interest to you. 

We may also disclose personal data we hold to third parties:

(a)              in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or (b)              if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.

Updating your marketing preferences

We have no desire to contact those customers or enquirers who do not wish to receive marketing correspondence from ourselves or carefully selected third parties. We rely on freely given, specific, informed and unambiguous statements which signify your agreement to the processing of your personal data for marketing purposes. 

• If you wish to change your marketing preferences, there are various ways in which you can do this:
• by telephone to our customer services department on 0330 024 1942;
• in writing to Customer Services, James Meade, WCF Home Shopping, Crawhall, Brampton, Cumbria, CA8 1TN;
• by email at info@jamesmeade.com;
• using the online contact form at https://www.jamesmeade.com/services/contact;
• by completing the opt out statements on the order form next time you place your postal order; 
• unsubscribe from marketing email communications by following the unsubscribe instructions in each email that we send out; or
• logging into your account by visiting https://www.jamesmeade.com/myaccount/login. 

Data Sharing

We share, swap, sell and purchase data with non-competitive trusted third-party retailers by using data co-operatives. This allows us to target our marketing to those customers who are likely to be the most responsive. Before sharing any customer data or before using any customer data acquired via a data co-operative, we would ensure that the data co-operative has undertaken appropriate due diligence to ensure that any data we send or receive for the purposes of marketing is compliant under the data protection laws. 

We also share data with a small number of registered UK charities for a small fee.

Your data is only shared where you have not opted out of receiving carefully selected postal mailings from third parties and you have not opted out of direct mail via the Mail Preference Service. If you do not wish to receive postal communications from carefully selected third parties, you should update your marketing preferences using one of the ways outlined above in this Policy.

Where we purchase customer data from other trusted third-party retailers for the purposes of one-off mailings, the data is deleted once the mailing has been completed unless the individual places an order and becomes a WCF customer.

Access and other rights

You may request to see the personal information we hold about you either digitally or on file at any point by making a request in writing to us via The Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on pam.murray@wcf.co.uk. This request will be responded to within 30 working days. You will be provided with a copy of the personal information we hold about you. If we require more time to respond fully to any request, we will notify you in writing within the 30-day period referred to. Any additional copies of any information we provide to you may be subject to a reasonable fee.

You also have other rights under Data Protection Laws in relation to your personal data. In particular, you may have (i) the right to request that we rectify or erase information we hold about you in certain circumstances, (ii) the right to ask us to limit our processing of your information, (iii) the right (if we are processing information based on your consent, such as for marketing purposes) to withdraw your consent, (iv) the right to object to certain processing of your information (including the right to object to processing of your personal data for direct marketing purposes at any time), (v) the right to ask us to move, copy or transfer your personal information to another organisation. 

If you wish to exercise any of these rights, please contact us via the Company Secretary at Crawhall, Brampton, Cumbria, CA8 1TN or via email on pam.murray@wcf.co.uk.

Accuracy of personal data

We try to ensure that the information we hold about you is accurate and kept up-to-date and may ask you to re-confirm certain information when you place an order. However, if at any time you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us in writing via Customer Services, WCF Home Shopping, Crawhall, Brampton, Cumbria, CA8 1TN, by calling 0330 024 1940 or via email at info@jamesmeade.com as soon as possible. We will promptly correct or delete any information found to be incorrect.

Security

We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of the personal data we hold about you, and against the accidental loss of, or damage to, such personal data.

Transferring personal data outside the EEA

Except if appropriate safeguards are in place that are in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation 2016/679), we will not transfer any personal data to a country outside of the European Economic Area ("EEA") or to a person based outside the EEA. Such safeguards may include us or one of our data processors entering into EU Standard Contractual Clauses (or their equivalent in the UK) with a third party outside the EEA to whom personal information is being transferred. Further information about the safeguards we may apply can be obtained by contacting the Company Secretary at WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on pam.murray@wcf.co.uk.

Those customers living overseas should note that postal address information will be shared with the postal services to allow catalogues and parcels to be delivered.

Retention of data

We are committed to ensuring that we do not retain personal data for any longer than is necessary for the purposes for which it was obtained. As we operate a no time limit product return guarantee, we hold order information indefinitely to enable us to fulfil this customer services promise. We also retain your marketing preferences in the event that your account is re-activated if you respond to an advertisement or marketing piece. Credit card tokens are held until expiry of the credit card.

You can update your marketing preferences at any time by using one of the methods outlined above.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Changes to this policy

We may make changes to this Privacy Policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you in writing. Please refer to this page regularly to see any changes or updates to this policy. 

Contact

If you have any queries about this policy or your personal data, or you wish to submit an access request or raise a complaint about the way your personal data has been handled, please do so in writing and address this to the Company Secretary, WCF Ltd, Crawhall, Brampton, Cumbria, CA8 1TN or via email on pam.murray@wcf.co.uk.

Complaints

If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you have the right to lodge a complaint at the Information Commissioner’s Office (https://ico.org.uk/).