Privacy Policy

Privacy and cookies policy
  • At SPG Superstore, we’re working hard to serve shoppers a little better every day. Looking after the personal data you share with us is a hugely important part of this. We want you to be confident that your data is safe and secure with us, and that you understand how we use it to offer you a better and more personalised shopping experience.

What this policy covers

The data controller (who determines the purpose and manner in which your personal data is used) is Special Price Goods Private Limited (referred to in this policy as “we” or “us”).

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

  • Sets out the different ways you interact with us and the types of personal data that we collect
  • explains the reasons why we use the data we collect
  • explains when and why we will share personal data within the SPG Group and with other organisations; and
  • explains the rights and choices you have when it comes to your personal data
We offer a wide range of products and services, so we want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”).
    Using our Services means:
  • Shopping with us over the phone, online or otherwise using any of the websites (“our Websites”) or mobile applications (“our Mobile Apps”) where this Policy is posted; or
  • This Policy also applies if you contact us or we contact you about our Services

Parts of this Policy also apply to our store CCTV systems where they capture footage of you.

Our Websites or Mobile Apps may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal data on a website as we do not accept any responsibility or liability for websites of other organisations.

Personal data we collect when we interact with you

This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.

Types of data
  • Aggregated data
    • We try and remove personal data we do not need. If we remove enough personal data it becomes anonymous. This means that you cannot be identified.

    • We might also take data we hold and remove certain information and replace it with other non-identifying information such as ID number or reference number. This is an extra technique we use to protect data. We normally use these techniques to look at large amounts of individuals. This includes information that is statistical or demographic data.

  • Identity data
    • This is information that helps us identify who you are, so your name, title or Number.12345678810

  • Contact data
    • This is information that details how we can contact you i.e address, email or telephone number.

  • Financial data
    • This is information about your bank account and payment card details.

  • Location data
    • In some cases our apps might ask for your location information to help better serve you information about your local store, you will be made aware at the time if we would collect this data.

  • Transaction data
    • This is information about your purchase of a product or service from us. This includes when, where, what and how you purchased that item or service. It will also include where we sent that product or service and any points or other benefits collected as part of the transaction.

  • Technical data
    • This is information about your device used to access our site and apps. This could be information that identifies your device, its operating system, internet address, your login data; browser and plug-ins; location; where you came to our site from and where you leave to as well as how often you visit. If you use our in-store WIFI we will collect information about where and when you accessed our network; This is done via the use of cookies which is covered elsewhere in this notice.

  • User data
    • This is information collected about you as a user of our stores, products and services more generally (compared to other types of data that relate to you directly for us to deliver our specific service to you). This may include where you engage with Special Price Goods Private Limited in a survey, provide feedback on your shopping experience, are captured by CCTV, or other camera technologies such as queue monitoring or number plate recognition.

    • We will also collect information about you that allows us to create an analysis of you as a consumer to better judge what products and services to offer in our stores.

  • Interaction data
    • This is information about how you interact with our products and services, namely what you click on and interact with on our sites and apps or products in stores

  • Marketing and communications data
    • This is your marketing preferences and also your interaction with online marketing to be able to judge its effectiveness

When you register for our Services

You may provide us with:

  • Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title

  • Your account login details, such as your username and the password that you have chosen

  • We may collect:

  • Identity data

  • Contact data

  • Financial data

  • Technical data

  • User data

  • Marketing and communications data

When you shop with us online or browse our Websites or use our Mobile Apps

We may collect:

  • Information about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)

  • Information about your online browsing behaviour on our Websites and Mobile Apps and information about when you click on one of our adverts (including those shown on other organisations’ websites)

  • Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)

What type of data might be collected:
  • Identity data

  • Contact data

  • Financial data

  • Transaction data

  • Technical data

  • User data

  • Interaction data

  • Marketing and communications data

When you contact us or we contact you or you take part in promotions, competitions, surveys or reviews about our Services

We may collect:

  • Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media

  • Details of the emails and other digital communications we send to you that you open, including any links in them that you click on

  • Your feedback and contributions to customer surveys or reviews

  • What type of data might be collected:

  • Identity data

  • Contact data

  • User data

When you visit our stores

We may collect:

  • Footage of you may be recorded on our CCTV systems

  • What type of data might be collected:

  • Identity data

  • User data

  • Interaction data

Other sources of personal data
  • We may also use personal data from other sources, such as specialist companies that supply information, online media channels1, our Retail Partners and public registers (such as the electoral register). For example, this other personal data helps us to:

  • Manage your account

  • Review and improve the accuracy of the data we hold

  • Improve and measure the effectiveness of our marketing communications, including online advertising2.

  • Online media channels include websites, social media sites, pay TV providers and any other channels that become available to us

  • Marketing messages that you may see on the internet

Why we collect the data we collect and why we are allowed to use that personal data
  • This section explains in detail how and why we use personal data. We use personal data to:

Make our Services available to you
  • This means that processing your personal data allows us to:

  • Manage the accounts you hold with us

  • Process your orders and refunds

Why do we process your personal data in this way?
  • We need to process your personal data so that we can manage customer accounts, provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.

Why we are using this data (Legal Basis):
  • Contractual Necessity – at the time we collect it:

  • Purchase & transaction data;

  • Contact details;

  • Profile details;

  • Delivery/collection details.

  • We will not be able to provide you with your products or services if you do not provide us with this data.

  • Legitimate Interests - following fulfilment of your order.

Manage and improve our day-to-day operations
  • Manage and improve our Websites and Mobile Apps

Why do we process your personal data in this way?
  • We use cookies and similar technologies on our Websites and Mobile Apps to improve your customer experience.

  • Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Websites and Mobile Apps. You can disable other cookies but this may affect your customer experience.

  • Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you

Why do we process your personal data in this way?
  • We rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range, services and stores. This allows us to serve you better as a customer.

  • Detect and prevent fraud or other crime

Why do we process your personal data in this way?
  • It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our Services.

Why we are using this data (Legal Basis):
  • Contractual Necessity – at the time we collect it:

  • Purchase & transaction data;

  • Contact details;

  • Profile details;

  • Delivery/collection details.

  • We will not be able to provide you with your products or services if you do not provide us with this data.

  • Legitimate Interests - following fulfilment of your order for the other personal data in that section.

Why we are using this data (Legal Basis):
  • Legitimate Interests

Personalise your SPG Superstore experience
  • Use your online browsing behaviour as well as your in-store and online purchases to help us better understand you as a customer and provide you with personalised offers and services.

Why do we process your personal data in this way?
  • Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer.

  • Provide you with relevant marketing communications (including by email, post or online advertising), relating to our products and services, and those of our suppliers. We may also measure the effectiveness of our marketing communications and those of our suppliers and Retail Partners.

Why do we process your personal data in this way?
  • We want to ensure that we provide you with marketing communications, including online advertising that is relevant to your interests. To achieve this, we also measure your responses to marketing communications relating to products and services we offer, which also means we can offer you products and services that better meet your needs as a customer.

  • You can change your marketing choices, both when you register with us, and at any time after that.

  • You also have choices when it comes to online advertising. We set out below your choices when it comes to cookies, and how you can control your online behavioural advertising preferences.

Why are we using this data? (Legal basis):
  • Legitimate Interests.

Contact and interact with you
  • Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.

Why do we process your personal data in this way?
  • We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications

  • Manage promotions and competitions you take part in, including those we run with our suppliers and Retail Partners.

Why do we process your personal data in this way?
  • We need to process your personal data so that we can manage the promotions and competitions you choose to enter.

  • Invite you to take part in and manage customer surveys, reviews and other market research activities carried out by the SPG Superstore and by other organisations on our behalf.

Why do we process your personal data in this way?
  • We carry out market research to improve our Services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services.

Why are we using this data? (Legal basis):
  • Legitimate Interests.

Claims
  • In order to resolve legal claims or disputes involving you or us.

Why do we process your personal data in this way?
  • For example if you have any accident or there is an incident at our stores.

Why are we using this data? (Legal basis):
  • Bringing or defending legal claims

CCTV
  • To monitor the safety of our store in order to prevent and detect crime and anti-social behaviour.

  • If you park in our car parks, we may utilise Automatic Number Plate Recognition Technologies (ANPR) to identify if your vehicle has complied with our parking rules. Where there is a security or claim incident involving a vehicle, we may use ANPR to assist in our investigation into those incidents.

Why do we process your personal data in this way?
  • In order to protect our business, the local community, customers and colleagues.

Why are we using this data (Legal basis):
  • Legitimate Interests.

Our Legitimate Interests in using your personal data
  • This section explains how and why we share personal data with other companies within the Special Price Goods Pvt. Ltd.

  • Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are:

  • to service our customers’ needs, including delivering our products and services;

  • to promote and market our products and services;

  • to service your account;

  • manage complaints and resolve any disputes;

  • to understand our customers including their patterns, behaviours as well as their likes and dislikes;

  • to protect and support our business, colleagues, customers and shareholders;

  • to prevent and detect anti-social behaviour, fraud and other crime;

  • to test and develop new products and services as well as improve existing ones.

Sharing personal data with Retail Partners and Service Providers
  • This section explains how and why we share personal data with Retail Partners and Service Providers.

  • When we share personal data with these companies, we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

Sharing personal data with other organisations
  • This section explains how and why we share personal data with other organisations.

  • We may share personal data with other organisations in the following circumstances:

  • if the law or a public authority says we must share the personal data or for the administration of justice;

  • if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud);

  • where we restructure, sell or transfer our business (or a part of it). For example, in connection with a takeover or merger.

How we protect your personal data

We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.

  • We apply physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data;

  • We protect the security of your information while it is being transmitted by encrypting it;

  • We use computer safeguards such as firewalls and data encryption to keep this data safe;

  • We only authorise access to employees and trusted partners who need it to carry out their responsibilities;

  • We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security;

  • We will ask for proof of identity before we share your personal data with you; and

  • We will reveal only the last four digits of your payment card number when confirming an order.

  • Whilst we take appropriate technical and organisational measures to safeguard your personal data, it is important that you keep your login details and devices protected from unauthorised access.

How long we use personal data for
  • We will not keep your personal data longer than we need to, the duration depends on several factors, including:

  • Why we collected it in the first place;

  • How od it is;

  • Whether there is a legal/regulatory reason for us to keep it;

  • Whether we need it to protect you or us

Cookies and similar technologies
  • We and our partners use cookies and similar technologies, to personalise and improve your customer experience as you use our Websites and Mobile Apps and to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

How we use cookies
  • Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Websites and Mobile Apps, and to improve your customer experience. Cookies can also be used to help us detect fraudulent activity or to prevent security breaches and so we may record information about your device within the cookie.

  • When you consent to Cookies on our Services, these may be used to do the following:

Improve the way our Websites and Mobile Apps work
  • Cookies allow us to improve the way our Websites and Mobile Apps work so that we can personalise your experience and allow you to use many of their useful features.

  • For example, we use Cookies so we can remember your preferences and the contents of your shopping basket when you return to our Websites and Mobile Apps.

Improve the performance of our Websites and Mobile Apps
  • Cookies can help us to understand how our Websites and Mobile Apps are being used, for example, by telling us if you get an error messages as you browse.

  • These Cookies collect data that is mostly aggregated and anonymous.

Deliver relevant online advertising, including via social media
  • We use Cookies to help us deliver online advertising that we believe is most relevant to you on our Websites and other organisations’ websites and using social media. Cookies used for this purpose are often placed on our Websites by specialist organisations.

  • Cookies used for this purpose are often placed on our Websites by organisations providing specialist services to us. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.

  • To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example your use of and in-store purchases.

Measuring the effectiveness of our marketing communications, including online advertising
  • Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

  • We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent.

Your choices when it comes to Cookies
Web browser cookies
  • You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. You can find more detailed information about how you can manage Cookies through your browser’s help function.

  • If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

Mobile Apps
  • Cookies work differently on Mobile Apps as they are coded into the App itself and will use a unique identifier created by your mobile device for use for advertising activities. You can turn off or reset this advertising identifier through your mobile device’s privacy settings.

Other data protection rights

In relation to your personal data, you also have the right to

  • 1. have inaccurate information corrected:

    • Summary of the right:

    • if you believe we hold inaccurate or missing information, please let us know and we will correct it.

  • 2. object to our use of it:

    • Summary of the right:

    • general objection - We will then consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section 3 below) or delete it (see section 4 below).

    • objection in relation to direct marketing - If you make such an objection, we will stop using your personal data for direct marketing purposes.

  • 3. restrict our use of it:

    • Summary of the right:

    • There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):

    • you have successfully made a general objection (listed in section 2 above).

    • you are challenging the accuracy of the personal data we hold.

    • we have used your personal data unlawfully, but you do not want us to delete it.

  • 4. have us delete it:

    • Summary of the right:

    • There are several situations when you can have us delete your personal data, this includes (but is not limited to):

    • we no longer need to keep your personal data;

    • you have successfully made a general objection (listed in section 2 above)

    • you have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it)

    • we have unlawfully processed your personal data.

  • 5. have us transfer or "port" a copy of it: