1. SUMMARY

1.1 Andrew Martin International Limited are committed to protecting and respecting your privacy at all times.

1.2 This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1.3 For the purpose of the Data Protection Act 1998 (Act), the data controller is Andrew Martin International Limited, 190-196 Walton Street, London, SW3 2JL.

1.4 We may record telephone conversations to use in our internal staff training programme.

2. PERSONAL DATA WE COLLECT FROM YOU

2.1 We may collect, process and store the following data about you:

i) When you purchase a product Online, in one of our stores or by phone

ii) When you order a brochure of fabric sample from Andrew Martin

iii) When you sign up for our email newsletter

iv) When you review or comment on our products and services

v) When you engage with us on social media or through surveys we may send you

vi) When using our website, we may collect technical data about your equipment, browsing behaviour and any websites that referred you to andrewmartin.co.uk. We collect this personal data by using cookies and other similar technologies.

vii) When you apply for a trade account with us through our website, over the phone or in one of our Retail stores.

2.2 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data including first name, last name, title.
• Contact Data including billing address, delivery address, email address, telephone numbers. We will also collect your social media username, if you interact with us through those channels.
• Financial Data including bank account and payment card details
• Transaction Data including details about payments to and from you and other details of products you have purchased from us.

2.3 To deliver the best possible web experience, we collect Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

• Profile Data including purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data including information about how you use our website. This includes information gathered by the use of cookies in your web browser. Learn more about how we use cookies and similar technologies by reading our cookie policy.
• Marketing and Communications Data includes your preferences in receiving marketing from us. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
• We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.4 HOW AND WHY WE USE YOUR PERSONAL DATA

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

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

2.4.2 If you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide some services you asked for. Examples of how we use information held about you include:

• To process any orders that you make on our website or in store. If we don't collect your personal data during checkout, we won't be able to process and deliver your order and comply with legal obligations.
• To respond to your queries, refund requests and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• To listen to recorded telephone conversations for internal staff training.
• To send you relevant communications by email or post in relation to updates, products and services. We'll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by email or post at any time.
• To administer any of our prize draws or competitions which you enter
• To develop, test and improve the systems, services and products we provide to you. We'll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.

2.5. WHO DO WE SHARE YOUR DATA WITH?

2.5.1 We may have to share your personal data with the parties set out below for the purposes of operating our business. Examples of these third parties we would share your data with are:

• IT companies who support our website and other business systems
• Operational companies such as our third party delivery couriers
• Google, Facebook, Instagram and Pinterest to show you products that might interest you while you're browsing the internet. We'll also use your data to identify other internet users who share similar interests. This is based on your acceptance of cookies on our website. For more information about the cookies we use, please see our cookie policy. We may also share your personal details, such as your email address with third parties, such as Pinterest, Facebook and Google, for the purposes of targeted online advertising. To opt out from this form of email-based advertising please email [email protected]
• We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In order to protect your privacy we will:

• Only provide the information necessary to perform their specific services
• Only use the data for the exact purpose we specify in our contract with them
• Work closely with them to ensure their privacy is respected and protected at all times

2.6 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

2.7. INTERNATIONAL TRANSFER OF DATA

2.7.1 We will never transfer your data outside of the EEA in compliance with data protection laws.

2.8 PROTECTING YOUR DATA

2.8.1 The security of your personal data is very important to us and we are committed to treating it with the utmost care, taking all appropriate steps to protect it. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.

2.8.2 We secure access to all transactional areas of our websites and apps using 'https' technology.

2.8.3 We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

2.9 KEEPING YOUR DATA

2.9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

2.9.2 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. For example, if your order included a product guarantee, the associated personal data will be kept until the end of the guarantee period.

2.9.3 At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

2.10 WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?

2.10.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

2.10.2 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

2.10.3 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

2.10.4 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

2.10.5 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

2.10.6 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

2.10.7 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

2.10.8 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

2.10.9 You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must and will always comply with your request.

If you wish to exercise any of the rights set out above, please contact:

Data Privacy Officer

Andrew Martin International
190-196 Walton Street

London

SW3 2JL

or email [email protected]

2.10.10 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

2.10.11 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

2.10.12 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

3. #YesAndrewMartin

We love your passion for Andrew Martin products and interiors and the photos you post on Instagram and Facebook under #MyAndrewMartin. That's the reason we're asking you if we can share these photos on our website and our social media pages.

When you confirm the use of a photo with #YesAndrewMartin you are agreeing to the following conditions:

• You are granting Andrew Martin International permission to publish any photo tagged with #yesfischer on andrewmartin.co.uk, on social media or our newsletters. There is no payment for this agreement and it does not exclude any other agreements.

• Andrew Martin will at no time claim ownership rights for these photos, and only has the right to use them for marketing purposes on andrewmartin.co.uk, social media and in newsletters and catalogues.

• This means all image rights remain with you; every person depicted in your photos also agrees to our use of the photos; and the use of the photos by Andrew Martin International does not infringe upon the rights of any third party nor does it violate in any way any other relevant, valid rights.

We look forward to sharing your passion and your photos for our products and interiors!