Privacy policy

We take your privacy very seriously. Please read this privacy policy 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 in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

It would be helpful to start by explaining some key terms used in this policy:

• We, us, our: AGT Retail Limited trading as All Good Things, Refined Networks or By Refined with company number 12003068 and registered address 7 Bell Yard, London WC2A 2JR and our group companies

• Personal data: Any information relating to an identified or identifiable individual

• Data subject: The individual who the personal data relates to

The personal data we collect about you depends on the particular products and services we provide to you. We will collect and use the following personal data about you:

• your name and contact information, including email address and telephone number and company details if applicable (Identification data)

• location data (Purchase Data)

• your billing information, transaction and limited payment card information (Purchase Data)

• your contact history, purchase history and saved items (Contact Data)

• voice recordings (for example if we record dealings you have with our customer services teams) (Contact Data)

• information to enable us to undertake credit or other financial checks on you or deal with any claims processes (if applicable) (Credit Data)

• Information about how you use our website, IT, communication and other systems (Analysis Data)

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you.

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website allgoodthings.co.uk or the website of our marketplace partners.

The marketplaces (“Marketplaces”) we work with include (although this list is subject to change):

• Amazon.co.uk
• Debenhams.com
• eBay.co.uk
• HarveyNichols.com
• JohnLewis.com
• Next.com
• Tu.com
• Very.co.uk
• Zalando.co.uk and other EU Zalando websites
• Own brand websites

We fulfil orders of our partner brands that you may place on the relevant Marketplace, or directly to you from our website.  If you have any questions about that please do not hesitate to contact us (see the ‘How to contact us’ section below). 

However, we may also collect information:

• from publicly accessible sources, e.g. Companies House or HM Land Registry as well as from data shared on public platforms including Instagram, TikTok, YouTube, Twitter/X or Facebook;
• directly from a third party, e.g:
– sanctions screening providers;
– credit reference agencies; or
– customer due diligence providers;
• from a third party with your consent, e.g. your bank or building society
• at our till points if you purchase in one of our ‘All Good Things’ stores
• from cookies on our website—for more information on our use of cookies, please see our cookie policy which is available at our website here .
• via our IT systems, e.g. through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV (where applicable) and access control systems, communications systems, email and instant messaging systems.

When you visit our website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse our website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to our website, and information about how you interact with our website. We refer to this automatically collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on our website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse our website.

Under data protection law, we can only use your personal data if we have a proper reason, e.g:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

We explain below what we use your personal data for and why together with the legal basis for us processing this data.

• Providing products and/or services to you, including fulfilling orders directly to you and updating you in relation to your order, providing you with tracking information and proof of delivery
—Type of data: Identification Data; Purchase Data; Contact Data
—Our reasons: To perform our contract with you or to take steps at your request before entering into a contract
—Legal basis for processing: To perform our contract with you

• Responding to any customer service queries that you might have
—Type of data: Contact Data; Identification Data; Purchase Data
—Our reasons: To provide you with a quality customer service
—Legal basis for processing: To perform our contract with you

• Processing orders that you make on the Marketplaces
—Type of data: Identification Data; Purchase Data; Credit Data
—Our reasons: To perform the purchase contracts you make with the Marketplaces or directly with us via the Marketplace platforms
—Legal basis for processing: To perform our contract with you

• Processing payments in respect of orders that you place via our payment providers
—Type of data: Identification Data; Purchase Data; Credit Data
—Our reasons: To enable you to purchase items on the Marketplaces
—Legal basis for processing: To perform our contract with you

• Dealing with collections or returns of product
—Type of data: Identification Data; Purchase Data; Contact Data
—Legal basis for processing: To perform our contract with you

• Preventing and detecting fraud against you or us
—Type of data: Credit Data; Identification Data; Purchase Data
—Our reasons: To prevent or detect fraud
—Legal basis for processing: For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us

• Conducting checks to identify our customers and verify their identity; Screening for financial and other sanctions or embargoes
—Type of data: Credit Data; Identification Data; Purchase Data
—Our reasons: To ensure compliance with legal and regulatory obligations or to complete checks required to process orders
—Legal basis for processing: Depending on the circumstances: to comply with our legal and regulatory obligations; for our legitimate interests to prevent or minimise fraudulent or illegal behaviour or to enable orders to be processed

• To enforce legal rights or defend or undertake legal proceedings
—Type of data: Credit Data; Identification Data
—Our reasons: To ensure we comply with legal and regulatory obligations as well as to protect our business
—Legal basis for processing: Depending on the circumstances: to comply with our legal and regulatory obligations; in other cases, for our legitimate interests, ie to protect our business, interests and rights

• Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
—Type of data: Credit Data; Identification Data
—Legal basis for processing: To comply with our legal and regulatory obligations

• Ensuring business policies are adhered to, e.g. policies covering security and internet use
—Type of data: Analysis Data
—Our reasons: For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
—Legal basis for processing: Legitimate interests

• Operational reasons, such as improving efficiency, training and quality control
—Type of data: Analysis Data; Purchase Data; Contact Data
—Our reasons: For our legitimate interests , i.e. to be as efficient as we can so we can deliver the best service to you at the best price
—Legal basis for processing: Legitimate interests

• Ensuring the confidentiality of commercially sensitive information
—Type of data: Purchase Data
—Our reasons: Depending on the circumstances: for our legitimate interests, ie to protect trade secrets and other commercially valuable information; to comply with our legal and regulatory obligations
—Legal basis for processing: Legitimate interests, compliance with legal and regulatory requirements

• Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures including troubleshooting, system maintenance, setting default options for you
—Type of data: Analysis Data; Contact Data, Device Information
—Our reasons: For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
—Legal basis for processing: Consent (via cookies); Legitimate interests (to improve our website, products, services, marketing, customer relationships and experiences)

• To deliver relevant website content, online advertisements and information for you, measuring effectiveness of advertising
—Type of data: Analysis Data; Contact Data, Device Information
—Our reasons: For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price and to confirm that our content is as applicable to you as possible
—Legal basis for processing: Consent (via cookies); Legitimate interests (to improve our website, products, services, marketing, customer relationships and experiences)

• Updating and enhancing customer records
—Type of data: Contact Data; Purchase Data; Identification Data
—Our reasons: To ensure that our customer records are appropriately maintained and updated
—Legal basis for processing: Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products

• Statutory returns
—Type of data: Identification Data; Purchase Data; Contact Data
—Our reasons: To process statutory returns
—Legal basis for processing: To comply with our legal and regulatory obligations

• Marketing our services and those of selected third parties to: existing and former customers; and third parties who have previously expressed an interest in our services
—Type of data: Identification Data; Analysis Data
—Our reasons: To enable our customers to keep in touch with us and learn about our products and services
—Legal basis for processing: Our legitimate interests, i.e. to promote our business to existing and former customers; Consent (via email opt-in)

• To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary.
—Type of data: Identification Data; Contact Data; Analysis Data
—Our reasons: To protect, realise or grow the value in our business and assets
—Legal basis for processing: Depending on the circumstances: to comply with our legal and regulatory obligations; in other cases, for our legitimate interests but only so far as is strictly necessary for the purposes of such business dealing

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. Where we do ask for your consent, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at customer-services@allgoodthings.co.uk;
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations outside the AGT Retail Group for marketing purposes.

We routinely share personal data with:

• companies within the AGT Retail Group
• third parties we use to help deliver our products and/or services to you, e.g. payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
• third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
• our banks.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

You may be able to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of the Marketplaces or our website, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

We use Shopify to power our online store – you can read more about how Shopify uses your personal information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use our website – you can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:
• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/

Please note that we do not alter our website’s data collection and use practices when we see a Do Not Track signal from your browser.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. In general, if you no longer have an account with us or we are no longer providing goods or services to you, we will delete or anonymise your account data after five years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It may sometimes be necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

As we are based in the UK we will also transfer your personal data from the EEA to the UK.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

You have the following rights, which you can exercise free of charge:

• Access: The right to be provided with a copy of your personal data

• Rectification: The right to require us to correct any mistakes in your personal data

• Erasure (also known as the right to be forgotten): The right to require us to delete your personal data—in certain situations

• Restriction of processing: The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

• Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

• To object: The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

• Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

• The right to withdraw consents: If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time.
You may withdraw consents by contacting us (see ‘How to contact us’ below).
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:
• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (e.g. your full name, address and any order number) and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data 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 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.

If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:
• the Information Commissioner in the UK
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see here.

This privacy notice was published on 24 July 2024 and last updated on 23 July 2024.

We may change this privacy notice from time to time—when
we do we will inform you via our website.

Individuals in the UK or EEA

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Reference: Data Privacy
Address: 7 Bell Yard, London, England, WC2A 2JR
Email: customer-services@allgoodthings.co.uk

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).