Privacy Policy

Introduction

This privacy policy is designed to provide information on the types of personal data we may collect when you interact with our company or website. It explains how that data may be securely stored and processed.

If you would like any further details or clarification on our privacy policy, or anything concerning your personal data, please do not hesitate to contact us. You can find our full contact details at the bottom of this policy. We want you to be fully aware and informed of your rights, and how your data is used by our company.

We may choose to update our privacy policy from time to time. While we will notify you of any significant changes, you can always find the latest version on this page.

Who are First Class Watches and James Moore Jewellers?

First Class Watches Limited and James Moore Jewellers Limited are UK registered companies. These related companies are subsidiaries of our parent holding company, First Class Retail Limited.

For simplicity, we will use the terms ‘us’ and ‘we’ and ‘our’ to refer to us as the relevant data controller. The relevant data controller will depend on whether you are interacting with us online or in-store.

When using the First Class Watches or James Moore Jewellers websites, First Class Watches Limited is the data controller. When making a purchase in-store at James Moore Jewellers, Kenilworth, the data controller is James Moore Jewellers Limited. On some occasions it may be necessary to share personal data between the two companies, such as if you call our web team and request a product is put aside for you to see and purchase in-store.

We operate these website domains:

• firstclasswatches.co.uk
• firstclasswatches.com
• jamesmoorejewellers.co.uk

We also make sales in store at our Kenilworth address and make sales through online marketplaces such as Amazon and eBay.

Explaining the legal bases for data collection

Data protection laws describe several different reasons that a company may collect and process personal data, these include:

Consent

For certain situations, we may use your clear consent process your personal data for a specific purpose. For example, when you tick a box to receive email updates from us or when you use our website to request a price-match offer. When collecting your personal data, we will show you which data is required in relation to a specific service.

Contract

In specific circumstances, the processing of your personal data is necessary to comply with a contract or agreement. For example, if you order an item for our website for delivery, we will collect your name and address and pass this to our delivery courier.

Legal obligation

When the law requires us to, we made need to process and collect your personal data. For example, we may pass details of fraudulent purchases or other criminal activity to the relevant law enforcement authority.

Legitimate interest

For some situations, it is necessary to collect and process personal data to pursue our legitimate interests or those of a third party. These must be in a way which might be reasonably expected as part of running our business and cannot significantly affect your rights, freedom or interests.

For example:

• We may use your purchase history to send or make available personalised offers.
• We may combine sales information to identify best-selling products and to forecast demand.
• We may use your browsing data to monitor the usage of our website to improve the functionality and fix problems we identify.

When do we collect your personal data?

• When you visit any of our websites.
• When you make a purchase or products or services online or by telephone.
• When you make a purchase in-store.
• When you engage with our accounts on social media platforms.
• When you request a price offer or price match from us using our online form
• When you request a notification for a product to come back in stock
• When you place an order with us online, you will be able to track your order online. Our online website stores and gives you access to your order information and tracking information.
• When you contact us by any means with questions, complaints etc.
• When you contact us to reserve a product for collection or purchase in store.
• When you ask one of our employees to email you information about a product or service.
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send you.
• When you comment on or review our products and services.
• When you leave a product with us to repair
• When you sell an item of jewellery to us in-store
• When you return an item to us for refund or action under your warranty
• Any individual may access personal data related to them, including opinions. So if your comment or review includes information about an employee who provided that service, it may be passed on to them if requested.
• When you’ve given a third party permission to share with us the information they hold about you.
• When you fill in any forms. For example, if an accident happens in store, an employee may collect your personal data.
• When our payment provider, finance lender or online marketplace – such as Klarna Bank AB, afforditNOW, DEKO, PayPal, Amazon or eBay – share information with us about the product you have purchased.
• When you visit us in-store, we operate CCTV systems for the security of both customers and employees. These systems may record your image during your visit.

What kind of personal data do we collect?

• Details of your visits to our websites, the device used and how you found our website
• Details of your interaction with us through our website pages, contact forms, telephone calls, in-store. Such as notes from your conversations with employees, details of any complaints, items you viewed, added to your basket or sent us a request about.
• When making an enquiry with us, we will collect your contact information.
• When placing an order with us online or by phone we will collect your name, billing/delivery address, email address and telephone number.
• When purchasing a product or placing a deposit against a product in-store, we will collect your email or telephone number as necessary.
• Payment card details as required by your payment method
• Special requests such as watch bracelet adjustments and gift wrap requests.
• In some cases, we may require copies of documents to prevent and deter fraud (such as passport or driving licence) or where required by law.
• Information gathered from cookies in your web browser. We use these small files to remember your computer or device as your browse our website. For example, this allows us to remember what you saved in your basket and to allow you to complete the order process. We have included further information about cookies at the bottom of this policy.
• Social media usernames when you contact us or interact with us on social media
• Your comments and reviews relating to our products and services
• Responses to surveys that you choose to fill out
• Images of jewellery or watches given to us for repair or sale
• Images recorded on CCTV when visiting us in-store and warehouse CCTV filmed while our employees pack and send orders
• For technical and performance monitoring, we collect technical information from your web browser such as IP address, web browsers user agent and IP address country and location as you browse our website
• Web pages visited, links clicked, search terms entered, and advertisements clicked as you browse our website

How and why do we use your personal data?

We want to give you the best possible customer experience. In order for us to do this we must process personal data that you provide to us in many ways as detailed below. In some circumstances we may use your browsing data on our website and purchase history to determine what types of products that we believe will be most interesting to you. Data privacy laws allow us to do this as part of our legitimate interests in understanding our customers and to provide a consistently high level of service that is expected of retailers. If you wish to change how we use your data, there is more details concerning your rights in the sections below.

• To process any purchases that you make with us on our website, on the telephone or in-store. If we don’t collect personal information during our checkout process, we won’t be able to fulfil your order or keep a record for our legal obligations and for warranty purposes. For example, your details may need to be shared with a third party to facilitate payment, delivery and aftersales support. We will process and keep this data for a reasonable period to fulfil our contractual and legal obligations.
• To answer your questions, return request or to assist with complaints we use the information that you send to us, and combine it with other information we may have already collected, in order to formulate a response. Depending on how you contact us, we may keep a record of the messages sent and received, or notes summarising the communication so that we can reference our earlier responses and so that a full record is available. We process this data based on contractual obligations, legal obligations and our legitimate interests to provide you with a high level of customer service and our intention to improve our service based on the experience of previous customers.
• To protect our business from and your details from fraud or criminal activity. This includes using your personal information to prevent unauthorised access to your order information and personal data. We process this data under our legitimate interest. For example, when you contact us about your order we may ask you to confirm personal data to check that it matches what we have on file before discussing your order details. We also monitor the IP address of devices accessing our website, so we can identify possible attempts to undermine the security and availability our website.
• We also monitor CCTV in-store and in our fulfilment warehouse for the security of our customers and business. These images are kept for a reasonable amount of time before being discarded.
• To process payments and to prevent fraudulent transactions. We do this under our legitimate interests. This also helps to prevent our customers experiencing fraud.
• When we discover criminal or suspected criminal activity. We process this data to prevent or detect unlawful acts. We aim to protect individuals and businesses from criminal activities which may lead to us sharing information with law enforcement.
• With your consent, we will use your personal data such as name, email address and details of any previous products purchased to keep you informed by email. You may choose to opt-out of this at any time by using the “unsubscribe” link on all our marketing emails or by contacting us using the details below.
• Under our contractual obligations, to send you email updates in relation to a purchase you have made. For example, when your order is placed you will receive a confirmation email for your records and when it is despatched with any relevant tracking information.
• Following an order, we will send you an email later to check everything is satisfactory with your order and allow you to leave a product review, and an email to ask you to leave a service review of our company with one of our independent partners. We do this under our legitimate interest to improve the quality of our service and product information for our website and does not require specific consent.
• Under our contractual obligations, optionally, send you text message updates regarding the status of your order. For example, when it has been dispatched and to pass this information to our courier so that they may keep you updated.
• To send you information required by law or which is necessary to inform you about changes to services that we provide to you. For example, an update to our privacy policy, product recall information or legally required information relating to a purchase.
• To contact you when a product you are interested in purchasing is back in stock, by email or SMS. This is done using your consent when the notification is requested, and we will not use this contact information in relation with any of our other marketing without your explicit consent.
• To allow us to carry our repairs to products in store or with third party under our contractual obligations for any jewellery and watch servicing or warranty returns. For example, we may use photographs to keep a record of items brought to our store for jewellery repair.
• To keep a record of second-hand jewellery purchased from the public under our legal and contractual obligations. For example, a record and image of a second hand ring, the price paid for it and the customer’s contact details.
• With your consent given at the time of entering, to administer any prize draws or competitions you may have chosen to enter.
• To display the most relevant content to you on our website. For example, a list of recently viewed products or relevant products based on what you have viewed or bought previously. We do this based on your consent to store cookies or similar identifiers in your browser or device. See our section about cookies below if you would like further information or how to disable cookies.
• To allow us to show relevant off-site advertisements to users of our websites, browsing history is linked to cookies controlled and created on your computer by third-party companies, such as Google and Facebook. We use this technology to link products and brands you may have viewed, added to your basket or purchased to buy personalised advertising on third party websites and platforms. These third-party vendors also use this information to optimise adverts based on how relevant or likely to purchase you may be and provide us anonymous demographic profiling data for our website audience such as age distribution and interest categories. This is all done based on the consent you have previously given to third-party vendors. This personalised advertising is done under the consent you have provided to these third-party networks. We have included details on how to opt-out of this personalised advertising below.
• To develop, test and improve the systems and products we provide to you under our legitimate business interests. For example, we will investigate requests from your IP address and website session ID as stored in your cookie if you tell us you are having problems using our website.
• To comply with our contractual or legal obligations to share data with law enforcement and the security and fraud prevention teams at companies which we work with. For example, in response to a court order requesting to share specific data.
• To store our data centrally and to allows us to build a richer picture of your preferences and purchase or interaction history, we may combine data between the subsidiaries of our holding company, First Class Watches Limited and James Moore Jewellers Limited. We’ll do this under our legitimate interest.
• To process your order or enquiries (for example placing an order on our website). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery providers). We do so to maintain our agreement with you. Without sharing your personal data, we’d be unable to fulfil your request.

How we look after and protect your personal data

We know how important it is that your data is stored, accessed and transferred securely. We treat all your data with extreme care and take appropriate action to ensure it is protected.

When you browse our website, make an order online with us or over the telephone, we use encryption technology (also known as HTTPS, TLS or SSL) to ensure that nobody else can access this data while it is in transit. This also prevents unauthorised third parties from accessing your browsing history or tampering with the web pages we send back to your computer or device.

We monitor our internal systems and conduct penetration testing to ensure nobody can access data that you send to us. Access to your order history is protected by your order number, and we use personal data such as your name and email address to confirm your identity.

Sensitive information, such as payment card information, is securely send to the relevant payment processer and not stored. This prevents us or unauthorised third parties from retrieving the original details after they have been processed.

Purchases in-store are made in a secure manner using a safe payment terminal and till system in line with industry standards.

How long will we store your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as necessary in relation to the reason it was collected. After this time, your personal data will either be completely deleted or anonymised so that it cannot be related to you individually.

For example, when we look at the number of pages views and visitors to our website, this will be combined statistically in a way which does not tie this to you individually but allows us to make decisions and carry out business forecasting.

Examples of our data retention periods:

• For customer orders, we will store the personal data for seven years. This allows us to fulfil our contractual and legal obligations. Customer records that have not been used for seven years will also be removed from our system. After this time, we will anonymise the orders in our system.
• In our internal reporting about website visitors that is linked to you personally through cookies, user identifiers or advertising identifiers is retained for a period of 26 months. After this only aggregated data will be available to us in these reports.

Who do you share your personal data with?

In certain situations, it is necessary for us to share your personal data with trusted third-parties. This is necessary for us to provide our goods and services. For example, delivery companies, payment processors, technicians and service centres for repairs and warranty claims, for fraud management and to manage enquiries or complaints.

• We share only the required information to perform the specific requirement
• They may only use your data for the exact purposes specified in our agreement with them
• We work closely with these third-parties to ensure your privacy is always respected
• If we stop using their services, any of the data held by them will either be deleted or anonymised

Types of companies we work with:

• IT companies to support our website and company systems
• Operational companies to process and fulfil orders such as payment providers, delivery companies and finance lenders if for example you choose to take our finance options provided by these lenders
• Marketing companies to allow us to manage our electronic interactions with you
• Online advertising companies such as Google and Facebook to show personalised advertising of products we believe you may find interesting while using the internet or apps. This is based on your consent provided to these companies previously. If you wish to withdraw your consent, please see the section below concerning opt-out of personalised off-site advertising.
• Data analytics companies who provide insight into how website visitors find and use our website

In certain situations, we may share data with third parties for their own purposes however we will only do this in very specific circumstances.

• With your consent, given at the time the data is supplied, we may pass data to a third party for direct marketing purposes. For example, if you choose to enter a joint competition and explicitly agree to be contacted by a third party for promotional purposes
• For fraud management we may share information about activity on our website or systems. This may include sharing data about individuals with law enforcement or third party security teams such as those at your bank.
• It may be necessary to disclose your personal data to police or law enforcement, regulators or government agencies. This can include within your country of origin or elsewhere, upon a valid request to do so. We will assess the privacy-impact on a case-by-case basis and considering the circumstances in detail.
• Should part or all of our business be sold, expanded, reduced or transferred to a new owner or controlling party, we reserve the right to transfer relevant personal data to the new party under this privacy notice.

To provide our services we currently work with the following companies who will process your personal data as part of our agreements with them:

• Google
• Amazon
• Facebook
• Microsoft
• Twitter
• Instagram
• YouTube
• Pinterest
• Vend
• SagePay
• WorldPay
• PayPal
• Apple
• Klarna Bank AB
• AfforditNOW
• Deko
• Royal Mail
• Global-E
• DHL
• eBay
• Postmark
• Intuit Quickbooks
• Fruugo
• Barclays
• Lucid Interactive
• ChannelAdvisor
• Crafty Clicks
• UK Dedicated Servers
• Trustpilot
• Pingdom
• Freshdesk
• Zendesk
• Errorception
• Papertrail
• DPD
• Stripe
• T H March

In order to be able to offer you Klarna's payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna can be found here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna's privacy policy.

Where your personal data may be processed

Sometimes it may be necessary to share your personal data with third parties and suppliers outside the European Economic Area (EEA) or European Union (EU).

For customers placing international orders, your data will be transferred to our systems in the UK. When these orders are placed through our website, they are collected by a third party fulfilment provider, Global-E as a co-controller.

We protect your data when it is sent or processed outside of the EU / EEA. For the international companies that we work with, we have procedures and agreements in place to ensure your data receives the same level of protection as if it was being processed inside the EU or EEA. For example many of these companies follow both the General Data Protection Regulation (GDPR) and EU-US Privacy Shield frameworks.

What are your rights over your personal data?

As an overview, you have the following rights with regards to your personal data:

• Access to the personal data we hold about you, free of charge in most cases.
• Correction of any incorrect, out of date, incomplete or inaccurate data.
• The right to withdraw your consent or object to processing of your data where we have no overriding legitimate interest, where the data is being processed for direct marketing or any other consent-based processing of your personal data.
• Review by an employee of any automated decisions based solely on automatic processing. For example, where no human has yet reviewed the outcome and reason for the decision.

Withdrawing consent

Wherever you have given us consent, you have the right to withdraw and change your mind at any time

Legitimate interest

When we rely on our “legitimate interest” for processing of your data, you may ask that we stop for reasons connected to your individual situation. We must follow your wishes unless we believe we have a legitimate overruling reason to continue processing your data.

Direct marketing and emails

You have the right to stop the use of your data for marketing through all channels. We must comply with this request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

• Click the “unsubscribe” link in any marketing email that we send you. We will then stop any further emails from that marketing list.
• Contact our team by email on info@firstclasswatches.co.uk – we will send you an email to inform you that this has been done
• Contact our team by telephone on 01926 298499 during office hours (Mon-Sat 9am-5pm)
• Write to First Class Watches or James Moore Jewellers, 9 Warwick Road, Kenilworth, Warwickshire CV8 1HD

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

How can you stop personalised off-site advertising?

We rely on the consent given to third-party vendors to conduct our personalised off-site advertising. You can withdraw consent for personalised off-site advertising by visiting the specific third party vendor and adjusting your consent settings. The “Network Advertising Initiative” and “Your Online Choices” websites allow you to easily control preferences from many vendors, including those we do not work with.

• Network Advertising
• Your Online Choices
• Google
• Google Analytics & DoubleClick
• Facebook

How do you manage cookies set by our websites?

Cookies are tiny text files stored on your computer when you visit certain web pages, which we use to keep track of what you have in your basket, and to remember you when you return to our site.

Please note that cookies can't harm your computer, and they do not contain any sensitive information such as payment details, but we do use them to remember your device between visits and allow you to complete purchases on our website.

If you don't wish to enable cookies, you'll still be able to browse the site and use it for research purposes. Most web browsers have cookies enabled, but you can disable these in your web browser setting for certain or all websites should you need to.

For iOS Safari you can do this in the “Settings app” on your home screen. Select “Safari” from the menu and under “Privacy and Security” tap on the “Block Cookies” section.

For Chrome Mobile and some Android devices, you can do this by opening your web browser and clicking on the menu (represented by three dots). Choose “Settings” and then choose “Site settings” you can then click “All Sites” to change settings for a specific site or “Cookies” to change settings for all sites.

For Chrome Desktop, you can change individual site settings by browsing to the website in question and clicking the area to the left of the “address bar”. This normally shows “Secure” or our company name while visiting our website. You can then click “Cookies” and block or allow individual cookies.

For other devices and browsers please consult the relevant help files.

Please note that if you choose to block certain cookies, you may find that certain functionality will not work on our website. To use these portions of our website you may need to re-enable the relevant cookies. You can always contact us by telephone or in-store to place an order, if you prefer.

We do have relationships with carefully-selected and monitored suppliers who may also set cookies during your visit to be used for remarketing purposes - in other words to show you different products and services based on what you appear to be interested in. If you wish to opt-out of this personalised advertising, please see the section above this one.

Do not track (DNT) is a feature offered by some browsers, with some newer browsers offering it as default. If you enable it, it sends a signal to websites to request that your browsing isn't tracked, for example by third party ad or social networks, or analytic companies. You can opt out of tracking and analytics on this website by changing your settings in the Managing Cookies section on this page.

At present no industry-wide uniform standard has been agreed and adopted to determine how DNT requests should be managed, so our website doesn’t currently respond to DNT requests. Until that standard is established, we'll continue to review DNT and other new technologies, but won't respond to DNT requests.

How can you access, or correct, personal data held by us?

There are several ways you can contact us for “Data Protection Requests”. To help us deal with these requests as quickly as possible, we ask that you state you are exercising your rights under Data Protection Regulation and to include any specific concerns you may have, if applicable.

• Contact our team by email on info@firstclasswatches.co.uk
• Contact our team by telephone on 01926 298499 during office hours (Mon-Sat 9am-5pm)
• Write to First Class Watches or James Moore Jewellers, 9 Warwick Road, Kenilworth, Warwickshire CV8 1HD

Please note that while we will try to deal with your request as quickly as possible, it may take us some time to compile and send this information to you, depending on the nature of the request.

Contacting the regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to https://www.ico.org.uk/concerns

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

Contacting us

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our team who will be pleased to help you:

• Contact our team by email on info@firstclasswatches.co.uk
• Contact our team by telephone on 01926 298499 during office hours (Mon-Sat 9am-5pm)
• Write to First Class Watches or James Moore Jewellers, 9 Warwick Road, Kenilworth, Warwickshire CV8 1HD

This notice was last updated on 25/07/2019