Privacy Policy

General

Wren Kitchens Limited (“we” “us” “our”) is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) describes our privacy practices and how we process your personal data when you use our website and engage in other online and offline activities. For the purposes of European and UK data protection legislation, we are the data controller and we will process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 and national laws which relate to the processing of personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Personal data we collect from visitors to our website

1. We may collect and process personal data about you in the following circumstances:

   1. when you complete forms on our website, www.wrentrade.com ( “Website”) or otherwise send us information. This includes where you complete our ‘Book a free showroom appointment’, ‘Book a free home measure’ and ‘Request a brochure’ forms and when you request a ‘Remote planning appointment’. We will collect details such as your name, address, email address and telephone number so we can contact you about the services you have requested and respond to your enquiry;

   2. when you register for an account on our Website, we collect your name, email, password, phone number, and address.  We will use your number to send important updates about your kitchen enquiry or order, as well as use your address for any orders you have made;

   3. when you submit comments in response to our blog posts, we collect any information you voluntarily provide. Before you can leave a comment, you may be prompted to log in to your Google, Twitter, Facebook, or Disqus account for authentication purposes.  These third-party services may share your authentication information with us as well as information available on or through your accounts with these services.  Please visit Google, Twitter, Facebook, or Disqus’s privacy policies for more information on their privacy practices;

   4. when you voluntarily sign up to receive one of our newsletters or to be added to one of our mailing lists, we may collect your name, e-mail address, postcode/zip code, and organisation. For more information, please see section 5 below;

   5. whenever you provide information to us when reporting a problem with our Website, making a complaint, making an enquiry or contacting us for any other reason.  If you contact us, we may keep a record of that correspondence;

   6. when you upload photos and other information via our Website, or when uploading certain photos and other information via social media. This would include photo submissions made for Wren Kitchens promotional competitions, such as finished kitchen installation pictures uploaded to our Website or uploaded to Instagram using the competition hashtag;

   7. whenever you disclose your information to us, or we collect information from you in any other way, through our Website; and

   8. whenever you recommend a friend or accept a recommendation as part of our referral scheme.  Please note that it is your responsibility to obtain any necessary consents for any personal data you provide to us from friends or other third parties, and to provide them with a copy of this Policy so they understand how their personal data will be collected and used.

2. We also may combine the personal data that we have collected about you with other data about you obtained from other sources (both online and offline), such as from third parties and public sources. For example, if you post a review of your kitchen installation using the review hosting site such as Trustpilot or Google Reviews, we may combine any personal data from the review with other information about you.  If you post a picture on Instagram with a Wren Kitchens hashtag as part of a promotion, we may combine that personal data with other information about you.  Additionally, if you connect with us on social media, we may use the social media platforms’ data analytics and advertising tools to obtain personal data about you, such as your demographics, interests, and other characteristics, to use for research and analytical purposes, as well as for targeted or online behavioural advertising on other websites.

3. When navigating our Website or using our services, we may also collect data in the following ways:

   1. Automated Tracking
      We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection.  We may collect details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access) to help us build a profile of our users.  We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We also use automated tracking technologies, such as Google Analytics, and social media plug-ins, to collect other information about your website session, browsing, and device information for our legitimate business purposes. For more information on how and why we use these technologies, please see our Cookie Policy.

   2. Cookies
      We place cookies on your machine with an ID that allows us to track how you use our Website now and in the future. We may also join this website behavioural data with other data sources. We use this to help us improve our website, service and advertising efforts. You can disable cookies at any time by adjusting your browser settings. Each Brower is different so please refer to the instructions in your browser to learn about cookies and other privacy and security settings that may be available. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

4. Cross-Device Tracking

   We use data analytics companies, advertising networks, or social media companies, and features offered by Google Analytics services or the Facebook Pixel to engage in “cross-device tracking,” which occurs when platforms, publishers, and advertising technology companies try to connect a consumer’s activity across smartphones, tablets, desktop computers, and other connected devices. The goal of cross-device tracking is to enable companies to link a consumer’s behaviour across devices.

5. We will only use your personal data when the law allows us to. Most commonly we will use your personal data:

   1. for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

   2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

   3. where we need to comply with a legal obligation.

6. These uses of your personal data may include to:

   1. provide you with information, or provide other services that you requested from us;

   2. perform the terms of a promotional competition we are hosting;

   3. allow you to participate in interactive features of our Website, when you choose to do so;

   4. ensure that content from our Website is presented in the most effective manner for you and for your device;

   5. improve our Website and services;

   6. process and deal with any complaints or enquiries made by you; and

   7. contact you for marketing purposes where you have signed up for these (see section 5 for further details).

7. We may use your personal data where we have your consent to do so, including to provide you marketing communications and other materials you have signed up for (see section 5 for further details).

8. Website Links

   Our Website may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data, and we do not accept any responsibility or liability for these policies. When you leave our Website, we encourage you to read the privacy notice/policy of every website you visit.

Personal data we collect about you when you are a Customer

1. We may collect details such as your name, address, telephone number and email address when you order goods or services from us in one of our showrooms, online, over the phone or via a remote planning appointment. We will use this information to process your order, comply with our contractual obligations and, where you have set up an online account with us, to help manage your account. Additionally, when you place an order, we may collect payment information, such as bank details. We may also collect contact details from you relating to a third party we may contact (with your consent) to discuss an order which you have placed. We may also use your information including your address and the type of product purchased from us to help inform the sale of our products to future customers. We may also use your name and contact details to address your customer service queries in order to manage your order process.

2. In order to perform our contract with you, we may also need to share personal data with third parties such as payment providers, suppliers, postal service, other delivery organisations and installers, and online appointment hosts, in order to assist in the delivery and performance of the goods and services you have ordered.

3. We may also instruct third parties to conduct customer experience and other surveys on our behalf to improve our services and for customer research and marketing purposes (unless you have previously opted – out from us or a third party contacting you for marketing purposes).

4. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

5. We may also publish your feedback on our Website and in other marketing materials (subject to obtaining your prior consent where necessary).

6. We will also use your personal data in the ways described in sections 6, 7 and 9 of this policy.

Personal data we collect about you when you are referred to us

We may use your personal data which is collected directly from third-parties who have received your consent. This may apply if you have indicated to a third party that you would be interested in using Wren to design your kitchen.

We operate a trade referral scheme whereby third party tradespersons (approved by us) may refer individuals to book an appointment to use Wren’s services (to design a kitchen) in return for a reward on completed orders following a successful referral. Only Wren-approved tradespersons are eligible to use this scheme.

The personal data received by the tradesperson may include your name, email address, contact number, and any other information you provide to them. The personal data will be shared with us in written format by way of a portal on a website controlled and operated by us www.wrentrade.com.

We rely on the consent (as a lawful basis) received by the tradesperson who is making the referral in respect of them sharing your personal data with us. The tradesperson must keep a record of the consent given by you.

If your consent has been received for the tradesperson to share your personal data with us, we will send an email to one of our kitchen designers and to your email address inviting you to book an appointment with one of our kitchen designers. If you choose to book an appointment with us, we will ask you for more personal data in order for us to book an appointment.

We will not share your personal data received by a tradesperson under this scheme except as set out in this Privacy Policy (see ‘Disclosure of your personal data’ section below). If you change your mind and would no longer like to hear from us, please see ‘Right to Withdraw Consent’ below.

Your privacy rights (as detailed below) including your right to withdraw your consent apply under this scheme. We will be a controller of your personal data when it is shared with us under this scheme. You can contact us at [email protected] with any questions.

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 the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with our goods or services). In this case, we may have to cancel any order you have placed with us, and we will notify you if this is the case at that time.

Marketing

1. In addition to the uses described in sections 2 and 3 above, where you have purchased our products or services, indicated that you would like to receive marketing correspondence from us, subscribed to our mailing lists or newsletters, or entered into any of our competitions or provided us with your details at networking events, we may use your personal data where you have given your consent or where this is necessary for our legitimate interests and these are not overridden by your rights and freedoms in order to provide you with details about our goods and services which we think may be of interest.

2. You have the right to opt-out of receiving marketing correspondence from us at any time. To opt-out of receiving such information you can:

   1. log onto your online account and amend your preferences;

   2. click the unsubscribe button contained in any marketing email which we send you; or

   3. email us at [email protected] providing us with your name and contact details.

   4. We may contact you in order to obtain the contact details for any third parties including contractors who have provided you with installation or other related services in order to perform a contract or where we have a legitimate interest to do so in connection with the provision of services.

Monitoring and recording

1. We may monitor and record communications with you (such as telephone communications and remote planning appointments) for the purpose of quality assurance, training, fraud prevention and compliance.

2. We have CCTV cameras installed in our premises and in our delivery vehicles for the purpose of crime prevention and for health and safety reasons.

3. We have a vision camera installed in several of our showrooms, the purposes of which is to track footfall in our stores. The camera converts a non-audio video still of an individual into anonymised information. Gender and age are estimated by the system and converted into data. The image does not leave the local system and within a few minutes is deleted, leaving anonymised data behind. This anonymised data is stored separately and kept indefinitely. No biometric data is stored.

4. We may also take photos of the products delivered and/or installed at your property in order to demonstrate the delivery and performance of products and services to you.

In-person visitors to The Nest, our manufacturing sites, and showrooms

1. Visitors to our registered office at The Nest and our manufacturing sites will be required to register their details on a third-party visitor management system. The system will record personal data and a photograph will also be taken before access to the site is granted. This data will be stored on a cloud platform and deleted after a period of time, in line with our data retention policy. We require these details to give us visibility of who is onsite to ensure site security and safety.

2. We use voice-activated virtual assistants in our showrooms to demonstrate how smart devices link up with various kitchen appliances that we offer and how you can control Wren appliances by making voice commands to such a virtual assistant. The virtual assistants in our showrooms are part of Amazon Echo smart speakers or Google Home smart speakers. When you speak to the Amazon Echo or Google Home in one of our showrooms using one of their “wake” words, a recording of what you have asked is sent to Amazon’s or Google’s servers so their systems can process and respond to your request. Your personal information when using these smart devices is governed by Amazon and Google’s privacy policies.

Legal basis for processing your personal data as a Customer or Visitor

1. We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   1. for the performance of a contract we enter into with you;

   2. where necessary for compliance with a legal or regulatory obligation we are subject to; and
      for our legitimate interests (as described within this Policy) (but only if your interests and fundamental rights do not override these interests).

Disclosure of personal data to third parties

1. As well as set out elsewhere in this Policy, we may disclose your information to the following parties, because we have a legitimate interest in doing so:

   1. our group companies (including our subsidiaries, our holding companies and any subsidiaries of our holding companies as defined in Section 1159 of the Companies Act 2006) for purposes described in this Policy;

   2. staff members and third party suppliers in order to facilitate the provision of goods or services to you;

   3. our affiliated entities to support internal administration;

   4. IT software providers that host our Website and store data on our behalf and service providers and suppliers to Wren Kitchens;

   5. our professional advisers including consultants, legal advisors, bankers and insurers;

   6. HM Revenue and Customs, U.K. regulators, and other U.K. authorities who require reporting of processing activities in certain circumstances, as well as those in the United States when needed to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

   7. third party companies like Trustpilot and Google Reviews that collect and assess customer feedback;

   8. to third-party organisations who provide us with information on an anonymised basis about customer demographics and expenditure;

   9. to third party organisations who provide us with online appointment hosting services from time to time; and

   10. to third parties with whom we may in the future negotiate a sale, transfer or merger of our business.

2. We may also disclose personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements, or to protect our rights, property, or safety of our customers, or others.

3. We may share your personal data, like an e-mail address or other data, with ad networks for online behavioural advertising purposes with your consent.

4. We will not sell or distribute personal data to other organisations without your approval.

Cross-border data transfers

1. Your personal data may be stored and processed in any country where Wren Kitchens or their service providers operate their business, including the United States, which may not have protections for personal data which are equivalent to those of your jurisdiction and/or which may not be considered adequate by the European Union (“EU”). By using our Website and / or services, you acknowledge that we may transfer your personal data to countries outside your country of residence, and that these may provide different data protection rules than in your country and such rules may not be equivalent to those of the EU.

2. Where we transfer data from the EU and other jurisdictions outside the European Economic Area (“EEA”), we will implement appropriate safeguards approved by the European Commission for the security of the processing of your personal data outside the EEA

Data security

1. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Website or to the third party; any transmission is at your own risk.

3. Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

Access to, updating, deleting and restricting use of personal data

1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

2. Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances, and to withdraw your consent to the processing of your personal data where this has been provided, although we may have the right to process your data without your consent in certain circumstances, as set out elsewhere in this policy. You also have the right to access information held about you and for this to be provided in an intelligible form and rights in certain situations to rectification of your data, to object to automated decision making, to have your data erased or to have your data transferred to another provider. If you would like a copy of some or all of your personal information, please send an email to our Data Protection Officer at [email protected] specifying your name and the details of your request. We will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time. We reserve the right to charge a reasonable fee for the administrative costs of complying with your request if your request is manifestly unfounded or excessive, or if you request further copies of your data following a request.

3. You can also ask us to do the following (although please see section 12.4, which might apply to your request):

   1. update or amend your personal data if you feel this is inaccurate;

   2. remove your personal data from our records entirely;

   3. send you copies of your personal data in a commonly used format, and transfer your information to another entity; or

   4. restrict the use of your personal data.

4. If you make this type of request, we may request specific information from you to help us confirm your identity and verify your request. Data protection legislation may allow or require us to refuse your request. If we refuse your request we will inform you of the reasons why, subject to any legal or regulatory restrictions.

5. Please send any requests relating to the above in writing to our Data Protection Officer at [email protected] specifying your name and the details of your request.

Retention of personal data

1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (for example to respond to any questions, complaints or claims made by your or on your behalf and to show you that we treated you fairly), unless a longer retention period is required by law or to fulfil a legal obligation or for accounting purposes.

2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

3. Details of retention periods for different aspects of your personal data are available upon request by contacting us on [email protected].

Right to withdraw consent

Where you have provided your consent to the collection, processing and transfer of your personal data, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact us at [email protected].

Age Restrictions

1. The Website is not intended for use by individuals under the age of sixteen, and we request that these individuals not provide personal data through the Website.

2. If you are a parent or guardian of a child under the age of sixteen and believe that he or she has disclosed his or her personal data to us, please contact us using the information provided under “Contact Us.”

Changes to our privacy policy

1. We reserve the right to update this privacy policy at any time. Please check the “Last Updated” legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Privacy Statement on the Website.

2. Any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact us

Your personal data will be held by Wren Kitchens. Our contact details are:

Our Data Protection Officer oversees our compliance with this privacy policy. If you have any questions, comments or requests regarding this Policy including any requests to exercise your legal rights, or how we use your personal data please contact our Data Protection Officer at [email protected].

We appreciate the chance to address your concerns in the first instance. However, you may also have the right to contact the U.K. Information Commissioner’s Office (“ICO”) if you are unsatisfied with our response to any issues you raise. The contact details for the ICO can be found here: ico.org

Last updated: May 2022