This section explains in detail how and why we use personal data. We collect or use personal data to:
We use personal data to |
Why do we process your personal data in this way? |
Legal Basis for using your personal data |
Make our Services available to you |
Processing your purchase orders and refunds:
We need to process your personal data so that we can fulfil our duties to provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.
Completing the transaction you request through our bill payment service:
To process the payment of your bills, we collect your personal data and other evidence to effect payment on behalf of your service providers or merchants in order for them to authenticate your identity and verify your payment. In addition, we need your personal information to fulfil the legal and regulatory requirements, for example, to verify that you are not listed as the designated person by the Anti- Money Laundering Office.
Giving customer supports:
When you contact us about our Services and offers, we rely on your personal data including your contact details to revert to you and give you our responses, assistance, clarifications or address the concerns you may have about our Services, whether by phone, email, post or by responding to social media posts that you have directed at us.
Managing promotions, competitions:
We need to process and disclose your personal data so that we can manage the promotions and competitions you choose to enter (for example announcement of competition/lucky draw winner), including those we run with our suppliers and Retail Partners.
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Consent Basis
for Clubcard Customer at the time you apply for our Clubcard.
Contractual Necessity
for Non-Clubcard Customer (at the point of contact)
– We will not be able to provide you with your products or services if you do not provide us with this data.
Legitimate Interests
for Non-Clubcard Customer
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Accommodate your request in relation to tax |
We need to collect and use your personal data to comply with your requests when you ask us, for example, to issue tax invoice or VAT report in case you want to claim tourist tax refund. |
Contractual Necessity and Legal Obligation |
Manage your account including your Clubcard membership |
Your personal data enables us to comply with the Terms and Conditions which are agreed with you in relation to the orders you made using Clubcard and enable you, as a Clubcard member, to participate in promotional activities and enjoy other benefits thereunder such as vouchers, reward points redemption, and any other sale promotions. |
Consent Basis |
Manage and improve our day-to-day operations |
To manage our Websites and Mobile Apps, we use cookies and similar technologies on our Websites and Mobile Apps to improve your customer experience. Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Websites and Mobile Apps. You can disable other cookies but this may affect your customer experience. For more information about cookies and how you can disable them, you can find the method publicly available online.
Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you, we rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range, services and stores. This allows us to serve you better as a customer. We also use personal data to improve our customer experience (e.g. substituting products (when we are out of stocks) and fulfilment experience (how we pick / pack / deliver) to customers.
Detect and prevent fraud or other crime, it is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of Services. This helps us to make sure that you can safely use our Services.
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Consent Basis
for Clubcard Customer
Contractual Necessity and Legitimate interest
for Non-Clubcard Customer
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Conduct marketing research and communications |
Developing and improving our product range, services, stores, information technology systems, know-how
We rely on the use of personal data to carry out marketing research and internal research and development, and to improve our information technology systems (including security) and our product range, stores and service standard. This allows us to serve you better as a customer.
Personalising your experience with the Company
- Looking at your browsing behaviour and purchase history (including Clubcard transactions) helps us personalising our offers and services for you, we can provide you with special offers or rewards to enhance your shopping experience.
- Providing you with relevant marketing communications (including by email, post or online advertising and other channels available time to time), relating to our products and services, and those of our suppliers, Retail Partners and our Group. As part of this, online advertising may be displayed on websites across our Group and on other organisations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of our suppliers and Retail Partners. We want to ensure that we provide you with marketing communications, including online advertising, that are relevant to your interests. To achieve this we also measure your responses to marketing communications relating to products and services we offer, which also means we can offer you products and services that better meet your needs as a customer.
- Using your personal data to improve our customer experience (e.g. substituting products (when we are out of stocks) and fulfilment experience (how we pick / pack / deliver) to customers.
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Consent Basis
for Clubcard Customer
Contractual Necessity and Legitimate interest
for Non-Clubcard Customer
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Customer survey and feedbacks |
From time to time, we may invite you to take part in and manage customer surveys, reviews and other marketing research activities carried out by our Group and by other organisations on our behalf.
In the event you decide to take such customer surveys, you are deemed to give consent for us to collect, use and disclose any additional personal data that you may provide for the purposes stated in this Policy or other purposes we notify you in the survey forms.
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Consent Basis
(upon agreeing to do the survey or provide feedback) |
Detect and prevent fraud or other crime and compliance with law |
It is important for us to monitor how our Services are used in order to detect and prevent fraud, other crimes and any misuse of services, to conduct ourselves in compliance with the laws, and to verify your identity in connection with the requests you made under this Policy. This helps us to make sure that our legal and regulatory compliance has been addressed and you can safely use our Services. |
Legal Obligation and Legitimate Interest |
Contact and interact with you |
Contact you about our Services, for example by phone, SMS, instant messenger (including but not limited to Facebook Messenger), email or post or by responding to social media posts that you have directed at us. We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications.
Manage promotions and competitions you take part in, including those we run with our suppliers and Retail Partners. We need to process your personal data so that we can manage the promotions and competitions you choose to enter.
Invite you to take part in and manage customer surveys, reviews and other market research activities carried out by our Group and by other organisations on our behalf. We carry out market research to improve our Services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services or your Clubcard.
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Consent Basis
for Clubcard Customer
Legitimate interest
for Non-Clubcard Customer
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Claims |
In order to resolve legal claims or disputes involving you or us. For example if you have any accident or there is an incident at our stores. |
Legal Obligation and Legitimate Interest |
CCTV |
In order to protect you, our business, the local community, and colleagues, we record CCTV footage to monitor the safety of our stores and to prevent and detect crime and anti-social behaviour.
If you park in our car parks, we may utilise Automatic Number Plate Recognition Technologies (or other technology with the same nature) to identify if your vehicle has complied with our parking rules. Where there is a security or claim incident involving a vehicle, we may use this technology to assist in our investigation into those incidents.
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Legitimate Interest |
Pharmacy |
To ensure the safe delivery of healthcare services, we need to process your personal data, including your medical information, to ensure we provide you with the highest standard of care or as required by applicable laws. Your prescriptions information will not be used for any other purpose.
By using our pharmacy services and supplying your personal data (including medical and health information), you are deemed to give consent for us to collect, use and disclose such personal data for the purpose under this paragraph.
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Consent Basis and Medical Necessity |
Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are: