This Policy explains how we collect your personal information, how it is used, processed and stored, as well as informing you what your individual data protection and privacy rights are.
This policy was updated on 12th October 2018, version 1.5
Who is responsible for processing my personal information?
2pushex UK Limited (Company No. 852773) is the Data Controller and the legal entity who is responsible for the personal information that is collected, processed and stored.
Personal information (or ‘personal data’) means any information that can personally identify you, such as your name, address and contact details.
What personal information do you collect about me?
Please rest reassured that we only collect information that is necessary to provide our products and services, as described in this policy.
• Like many retailers, we collect your name, address, email address, date of birth, telephone number and your order details when you shop by phone, post, online or at our retail store.
• We may also collect other information when you provide this to us. This may include special categories of personal information, such as your information relating to your health (for example if you have a 2push Personal Account and miss a payment due to a health-related event).
• When you browse our website, we gather information about the pages you visit. This includes technical information such as your IP address, browser type and cookie information (unless you have disabled cookies on your device).
How do you collect my personal information?
We collect your personal information directly from you, for example through our order forms, application form for a 2push Personal Account, from our website or through conversations we have with you.
We also collect your information from third parties, such as Credit Reference Agencies (or CRAs), fraud prevention agencies and our data alliances (all of which are discussed further below).
Why do you need my personal information?
We collect and use your personal information for a number of reasons, including:
When you place an order
• To process and deliver your order.
• To communicate with you, for example, to provide delivery updates.
When you apply for a 2push Personal Account
• To process your credit application including verifying your identity and credit record, and to identify and prevent fraud and money laundering.
• To communicate with you regarding your application.
• To administer your account, for example to process payments, make collections, trace debts, provide you with notices and statements, update and maintain our records.
• Should your application be unsuccessful we may need to store your personal information and will do so in accordance with our record retention policy.
On our website
• To personalise and improve your online shopping experience, making your future website visits easy, enjoyable and secure.
For other purposes
• To provide reports to our regulatory authority or law enforcement agencies.
• To send you special offers and promotions on products and services we think will be of interest to you.
• To create an understanding of your interests and preferences so that we can tailor special offers and promotions that we send to you.
Please note that if you do not provide us with certain information this may affect the service we are able to provide to you. For example, we require your personal information to be able to deliver the goods you have ordered and to be able to assess your application for a 2push Personal Account.
What legal bases do you have to process my personal information in this way?
We rely upon different legal bases to process your personal information depending on the reason for which we have collected or obtained it:
• For administrative purposes, when you have placed an order, for example to process payments, deliver your order, make collections.
• When you apply for a 2push Personal Account it is necessary for us to verify your identity, consider your credit history and accuracy of the details you have provided in your credit application to fulfil our legitimate interest of promoting responsible lending and fraud prevention.
• When we administer your 2push Personal Account and our contract with you and to comply with legal obligations.
• We process your contact information and shopping habits so that we can provide to you our products, services and special offers that we feel you may be interested in to fulfil our legitimate interest in providing you with information about our products, services and special offers.
• To provide the necessary reports to our regulatory authority or law enforcement agencies.
Do you make automated decisions about me?
When you apply for a 2push Personal Account we use an automated decision making software tool to underwrite your application. The use of the software is a requirement to enter into a regulated credit agreement with us. You have the right to request that we do a manual review of the results of the automated decision rendered.
Where do you store and process my personal information?
The personal information that you provide to us is stored and processed on secure servers in the UK and France.
How long do you keep my personal information for?
We have robust data retention and deletion procedures in place. How long we keep your personal information will depend on the purposes for which we process it. We delete information on an annual basis.
We generally keep your personal information for at least six years unless we are required by law to keep it for longer. We keep personal information relating to any 2push Personal Account that you have for at least seven years since your last transaction.
All telephone recordings are kept for six months for training, quality assurance and investigative purposes.
When you request to receive a catalogue or join our email list but don’t place an order, we will delete your personal details after 18 months.
We may keep your personal information for longer than the period shown above if we have a legal obligation to do so.
Can I see what personal information you hold about me?
Yes, if you would like to. You have the right to access the personal information we hold about you and this is known as the ‘right of access’. You can make the request by phone, email or by writing to us – see the How to contact us section for further information.
What other data protection rights do I have??
Right to rectify
We want to make sure that the personal information we hold about you is accurate and up to date. You can ask us to update your personal information if you think it is out of date or incorrect.
Right to be forgotten
In certain circumstances you can ask for the information we hold on you to be deleted, should there be a legal or contractual obligation to hold your personal details we may not be able to carry out your request, however, we will explain this fully to you.
Right to restriction of processing
You can ask us to limit how we use your details in certain circumstances. For example, if you have challenged the accuracy of your personal details, you can request that we do not use it until it has been rectified.
Right to object to processing
You have the right to object to the processing of your personal information in certain circumstances. These include where processing is based upon our legitimate interest and where we process your personal information or undertake profiling for direct marketing purposes.
Right to data portability
You have this right if we process your personal information by automated means and processing is based upon consent or performance of a contract. In such cases you can obtain the information we hold on you and reuse it for your own purposes, including to move, copy or transfer your personal information to another controller. Note that the information you can access under the right to data portability is different from the right of access.
You also have the right to be told which Credit Reference Agencies we have used and obtain a copy of your file from these agencies (please see below for further information about how we use CRAs).
If you want to exercise any of these rights, or have any queries in relation to them, you can make the request by phone, email or by writing to us – see the How to contact us section for further information.
We will respond to your request as soon as possible and always within statutory timeframes. Note that it may be necessary for us to contact you to verify your identity before we can deal with your request.
Can I choose how to be contacted by 2push?
Yes of course. You can choose how you want to be contacted by us, whether by post or email.
If you do not wish to receive our mailings you can opt out at any time by changing your preferences on your order form, via the telephone or online. We print up to six weeks in advance, so it may take up to this time for you to stop receiving mailings if you decide to opt out.
When you provide your email address you can unsubscribe from our email list at any point simply by clicking the unsubscribe link at the bottom of your email. After a week, you won’t receive any more marketing emails.
Do you share my personal information with other companies?
There are some circumstances where we may share your personal data including your name, address and email address with others. We do this when it is necessary to fulfil our legitimate interest of upholding customer service, better understanding our customer base and keeping you informed of offers and promotions that we believe you may be interested in.
On this basis, your personal information may be shared with:
• Companies who provide services to you on our behalf, like delivery companies.
• Our UK sister brands (Afibel, Coopers of Stortford and Sedagyl) who may contact you about their products.
• Research companies whom we may ask to contact you directly for your opinions on our products and services.
• Members of the data sharing alliances that we work with, Epsilon Abacus Alliance and Transactis 2017 Limited , who may contact you by post with information about products or services you may be interested in.
Data alliances bring together customer information on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. They share information on what their customers buy. The data alliances analyse this pooled information to help the retailers understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.
We may have obtained your contact details from the data alliances that we work with if you are a customer of one of their members. This should have been explained to you before your contact details were shared.
We will never share your email address for the purposes of enabling another business to market to you.
We may share your personal information, including your name, address, email address, as well as a record of any transactions you conduct on our website or offline with us with a third-party advertising partner and its service providers in order to deliver to you banner advertisements and other advertising tailored to your interests when you visit certain websites. Our advertising partner will make the data we provide it pseudonymous. To learn more about the use of this information or to make choices about receiving personalised advertising provided by third parties, please visit the European Digital Interactive Advertising Alliance by clicking here: http://www.youronlinechoices.eu/We may share your personal information, including your name, address, email address, as well as a record of any transactions you conduct on our website or offline with us with a third-party advertising partner and its service providers in order to deliver to you banner advertisements and other advertising tailored to your interests when you visit certain websites. Our advertising partner will make the data we provide it pseudonymous. To learn more about the use of this information or to make choices about receiving personalised advertising provided by third parties.
How is my personal information shared with Credit Reference Agencies?
In addition to the companies above, we may also share your personal information with Credit Reference Agencies (CRAs), debt collection agencies and fraud prevention agencies to comply with our legal obligations and fulfil our legitimate interests of responsible lending.
In order to process your application for a 2push Personal Account, we will perform credit and identity checks with a CRA.
To do this, we will supply your personal information to the CRA and they will give us information about you. This will include information from your credit application, your financial situation and financial history. The CRA will supply to us both public (including the electoral register) and shared credit, financial situation, financial history information and fraud prevention information.
We will use this information to:
• Assess your credit status and whether you can afford to take credit.
• Verify the accuracy of the information you have provided to us.
• Prevent criminal activity, fraud and money laundering.
• Manage your account(s).
• Trace and recover debts.
• Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a Personal Account with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When the CRA receives a search from us they will place a search footprint on your credit file that may be seen by other lenders.
Information held about you by the Credit Reference Agencies may already be linked to records relating to people with whom you are linked financially. For the purposes of credit searching you may be treated as financially linked and you will be assessed with reference to any ‘associated’ records.
CRAs will also link your records together and these will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the Credit Reference Agency Information Notice (CRAIN). The CRAIN is also accessible from each of the three CRAs online:
To request a printed copy of the CRAIN simply get in touch by writing to us with your query at: The Credit Team, 2push, Bowling Green Mills, Bingley, BD97 1AD or phone 0330 123 4083 (open 8.30am – 5pm, Monday-Friday)