PURE PAINT is committed to protecting your privacy and takes its responsibilities regarding the security of customer information very seriously.
1. Who is responsible for your data
2. Purpose and Lawful Basis for processing your data
We have three purposes for processing your personal data:
To complete the sale of products to you and the carrying out of any logistics for delivery or return of goods. This purpose allows PURE PAINT to lawfully process your data for legitimate interests (GDPR 6F) and our legal obligations to your country’s tax and revenue authorities.
To inform, inspire and engage with relevant, personalised content about our colours, products and services. This purpose means that PURE PAINT continually give you the provision to withdraw consent to process your data for communication, education and marketing purposes (GDPR 1). Without your consent, PURE PAINT will not process your data for this purpose.
To determine shopping trends and conduct anonymised customer insight. This purpose allows PURE PAINT to state a legitimate interest (GDPR 6F) to combine the shopping history of many customers to identify trends and ensure we can keep up with demand or develop new products/services. This includes linking guest and account purchases in statistical analysis. All trends reports can not track back to individual customer sales and we protect your individual orders.
The purpose and lawful basis for processing your data may change from time to time, where this policy will be updated.
Since GDPR & DPA 2018 was introduced on the 25th May 2018, your granting of consent is a protected right. We will provide clear, unticked boxes to opt in or out (as relevant to the transaction being undertaken, and whether you are an existing customer or new) of marketing communications. The guidelines for this are set out in the Privacy and Electronic Communications Regulations (PECR) which operates alongside GDPR & DPA 2018. You will be given further opportunities to change your opt-in statuses in all subsequent emails.
We will keep your given consent on file for a period of up to 7 years from the last change before checking if your consent is still valid. This is in line with our average customer project cycle. We will not contact you if you have withdrawn consent, but you can grant or withdraw your consent at any time. We are still working on making this self-serve at www.pure-paint.com, but in the meantime you can call our Customer Service team (Tel. +353 (0)61 378362) or send an email to firstname.lastname@example.org and express your preference to not receive marketing communications.
At 7 years we will write to you by email or post, depending on your preferences, with a statement of consent and your current choices. We will then send a reminder email after 30 days if no contact has been received. If this is not responded to then we will take that your granting of consent is still valid.
We will also include the opportunity to unsubscribe or withdraw consent on all marketing emails.
4. Personal data we collect about you
For more information on the parties who may share your personal data with us, please see section 7 below.
Categories of data we collect
We may collect and process the following categories of information about you:
Category of Data collected / held
When we process such data
name and surname and your contact details
(email address, telephone number and postal address)
When you create an account on our website
When you purchase our products
When you engage one of our colour consultants
When you take part in our competitions,
When you attend our events and talks, or
When you choose an offer we make available on our website
When we undertake market research when you have consented to be included in phone, email or workshop surveys
When you apply for roles within PURE PAINT
Information about your transaction, including your payment card details
When you purchase our products or services
Information related to your home and our services in connection with your home (e.g. property style, number of rooms, type of project)
When you use our colour consultancy / advice
When you use our services in-store
Anonymised information related to your demographic profile (for example, deciding new opportunities for PURE PAINT)
When you choose to allow this information to inform our analysis while creating an account or through managing your preferences
The communications you exchange with us (for example, your emails, letters, calls, or your messages on our online chat service)
When you contact PURE PAINT or you are contacted by us
Your social media account ID
When you interact with us on social media
When we target social media posts
Your posts and messages on social media directed to PURE PAINT
When you interact with us on social media
When you reply to our requests for feedback or participate in our customer surveys
Information about how you use our website or our mobile app, such as your searches for products
When you navigate on our website or when you use our mobile app
When you partially or fully complete a checkout online
Sensitive personal data
Information that could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences is considered “sensitive personal data” under the Irish Data Protection Act 2018 (DPC), EU General Data Protection Regulation (GDPR), PCI-DSS, and European data protection legislation. We do not collect this data from customers.
5. How and why we use your personal data
We use your personal data for the following purposes:
To manage your orders and provide our services to you. When you purchase from us, or seek advice, we use your information to perform our services in relation to your purchase or enquiry, for example to provide you with product, tailor specific advice to your project’s needs or change bookings for consultancy appointments.
To communicate with you and manage our relationship with you. Occasionally we may need to contact you by email and/or telephone for administrative or operational reasons, for example in order to send you confirmation of your purchases and your payments, to inform you about your consultancy appointments, to notify you when backordered products are available or to advise you of disruption and changes to your appointments and deliveries. If you are using our mobile app, we may also send you app notifications for these purposes.
Please be aware that these communications are not made for marketing purposes and as such, you will continue to receive them even if you opt-out from receiving marketing communications.
We will also use your personal data if we contact you after you have sent us a request, filled in a web-form through our website or contacted us on social media.
Your opinion is very important to us, so we may send you an email or SMS to seek your feedback.
We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our customer and to improve our services and experiences for customers.
To personalise and improve your customer experience
We may use your personal data in order to tailor our services to your needs and preferences and to provide you with a personalised customer experience. For example, if you inform us about your preferred products, colours or style we will be able to send you inspirational tips and ideas relevant to your interests.
We may also collect information on how you use our website, which pages of our website you visit most, which colours, finishes or product you search for and what products you buy, in order to understand what you like. We may use this information to tailor the content and offers that you see on our website and, if you have agreed to receiving marketing communications, to send you relevant messages that we think you like.
If you are in the process of making a purchase under your account and you leave our website before your order has been placed, we may contact you in order to help you easily complete your purchase.
To inform you about our news and offers that you may like. We may send you marketing communications, if you have indicated that you are happy to receive these, for example when you create an account on our website or purchase from us in-store and you explicitly agree to receive such communications. You can also request us to send you marketing communications through managing your preferences in your account.
If you are happy to receive marketing communications, we will provide you with news from us such as new products that you may be interested in or services that you may like. In addition, if you are happy to receive marketing communications, we may send you communications that include the promotion of our partners’ products and services that may be related with your purchase history.
Please note that we do not share your contact details and other personal data with other companies for marketing purposes, unless we have obtained your consent to do so.
If you do not want to receive marketing communications from us, you can simply tell us so by clicking the relevant box before confirming your booking. You can also choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us.
If you have a PURE PAINT online account, you can easily manage your marketing preferences through your account and you can at any time opt out from receiving marketing communications, by clicking on the “Contact Preferences” section of your account.
If you prefer, you can also call our Customer Service team and express your preference to not receive marketing communications
To improve our services, fulfil our administrative purposes and protect our business interests
The business purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development.
To comply with our legal obligations, for example, our obligation to provide your information to local police agencies.
6. Requesting access to your personal data
You have a right to request access to the personal data that we hold about you. This could include purchase information relating to products and services.
If you would like to request a copy of your personal data, or have questions in relation to your personal data, please contact us via email email@example.com
7. Right to be forgotten
You have a right to be forgotten and have data erased and / or stop being processed where the personal data is no longer necessary for the purpose of collection, you withdraw consent, when you object to the processing or to comply with a legal obligation.
We will not erase your records as we need to maintain your transactional data for our legal obligations to the local tax and revenue authorities. What we will undertake is to anonymise your records, overwriting your personal data with fictional names, addresses and emails. Once this has been done it will be impossible to restore a single customer, and a new customer registration will be required.
We have a number of security and governance protections in place that will be excluded from your right to be forgotten:
Encrypted system backups, held for up to 10 years. It is practically impossible to alter these backup files
Our anti-spam and email gateway. We maintain email archiving for security reasons, and your info may be kept in this archive. Access to this gateway is limited to named data controllers for PURE PAINT.
If you have questions in relation to your personal data, please contact us at firstname.lastname@example.org
8. Right to restrict processing
You have a right for your personal data to be stored but not processed. This is achieved through the withdrawal of consent.
If you have questions in relation to your personal data, please contact us at email@example.com.
9. Rights related to automated decision making including profiling
You have a right to be excluded from automated decision making. PURE PAINT have a number of different customer and consumer types who we personalise experiences for. These include home decorators, interior designers, professional painter and decorators, stockist owners and more. Our personalisation of your experience is achieved through automating profiling based on purchase behaviours and information shared.
You can select your preference at our contact preference centre, but opting out of this, you will not be able to receive any personalised inspiration or communications
If you have questions in relation to your personal data, please contact us at firstname.lastname@example.org
10. Security of your personal data
We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data. When you provide your personal data through our website or our mobile app, this information is transmitted across the internet securely using high-grade encryption.
Furthermore, PURE PAINT is a PCI DSS compliant organisation. This means that we adhere to high security standards in order to protect your payment card details when you are sending us this information.
11. Cookies or other tracking technologies
In order to improve our services, to provide you with more relevant content and to analyse how visitors use our website and app, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.
For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website. This software does not enable us to collect any personal data. In addition, in order to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or html form.
12. Sharing your personal data
Your personal data may be shared with other companies within our Group. We may also share some of your personal data with, or obtain your personal data from, the following categories of third parties:
• Suppliers providing services to us in order to help us run our business and improve our services and your customer experience. We may for example share your personal data with the companies who provide deliveries for us. We may also disclose your information to the companies who help us get your feedback on our services.
At PURE PAINT, we select very carefully our suppliers who process your personal data on our behalf and require that they comply with high security standards for the protection of your personal data.
• Credit and debit card companies
PURE PAINT shares some of your personal data, which includes information about your method of payment and purchase value, to the credit or debit card company that issued the card you used to make your booking. In order to ensure the security of your transactions and prevent or detect fraudulent transactions, we may also share your information with our fraud screening partner.
We may disclose your personal data when this is required by the law of any jurisdiction to which PURE PAINT may be subject.
13. Receiving your personal data from customers
PURE PAINT supply paint direct to consumer, but also trade to Paint to Designers and Painters/Decorators/Contractors (3rd party data controllers). They may place orders with PURE PAINT (data processor) to be shipped direct to your home or chosen location. We employ data processing agreements to cover this activity and all 3rd party data requests should be passed to the relevant 3rd party data controller.
15. Contact information