1. Who we are

In this Privacy Policy, references to we, us, or our mean the CMO Group PLC company that processes your personal information. The relevant CMOStores entities (together known as “CMO Group PLC”) are:

CMO Group, (company number 06755395) registered in England, whose registered office is Burrington Way, Burrington Business Park, Plymouth, PL5 3LX

You can find out how to contact us in Section 9 below.

2. Your Privacy

Throughout our interactions with you, we will gather and manage personal information about you. Personal information comprises any details that enable us to recognise you as an individual, such as your name, email address, or phone number.

We are resolute in our commitment to guarding your privacy. We will use your personal information in compliance with all relevant laws and regulations related to data protection and privacy, including the EU and UK General Data Protection Regulations ("GDPR"). This document tells you:

What personal information we collect.
Why we collect this personal information.
How we will use it.
How long we will keep it.
Who else will see it.
How you can contact us.
Your rights in relation to your personal information that we hold, including your rights to change, delete and see your personal information.

In this Privacy Policy, references to digital services mean our website, our digital app and any software and web-based applications that we make available for your use (“Digital Services”).

For the purposes of the GDPR (and equivalent data protection laws), we are the controller in respect of your personal information that we collect, and process as further described in this Privacy Policy, unless otherwise stated.

As described below, we may share your personal information with other organisations that may receive and process your personal information as a controller (see Section 7 for further details).

When using our Digital Services, we will also place cookies on your device - please see our Cookies Policy for more information about the cookies we use and how you can change your cookie settings.

3. What information do we collect?

We collect the following types of information:

(a) Information we collect when you register with us:

When signing up, we may request various pieces of information from you, such as:

Your name.
Your postal/delivery address.
Your email address.
Your telephone numbers.
Your profession.
A password
Whether you would like to receive information from us via email, SMS text, post, or telephone.
Information concerning your marketing preferences; and
If you are placing an order, your payment card number, expiry date and CVV number.

(b) Information we collect about how you use our trade counters, our contact centre, and our Digital Services:

When you shop with us at our trade counters, communicate with us via our contact centre or a third-party platform (such as Twitter, Meta and/or other social media applications), shop or browse using our Digital Services or other organisations' websites where our adverts are shown, we may collect:

Details of your purchases with or through us.
Information relating to your engagement with/responses to our marketing campaigns.
CCTV footage in which you feature when you visit our premises (and, if you have an accident while on our premises that you bring to our attention, we may record details of that accident and any injury you suffer in the relevant trade counter's accident log).
Information contained in and records of communications between us, including recordings of telephone calls when you contact us, and messages sent using instant messaging applications or third-party platforms.
Information that you provide to us by using our Digital Services, including any photos you have uploaded via our Digital Services or third-party platforms (such as information when you share content on social media, write a review, submit an enquiry, request marketing to be sent to you, competition entry, feedback, survey questionnaire).
User-generated content that you consent to us sharing on our Digital Services and/or on our social media channels, which may include any photos and information you have posted on your social media account about your CMOstores purchase and/or experience.
Information about your preferences in connection with our Digital Services, to enhance and personalise your experience.
Information about any devices you have used (including the manufacturer, model and operating system, IP address, browser type and mobile device identifiers); cookies and information about your online browsing and purchasing behaviour and history on our Digital Services, as further set out in our Cookies Policy.

Please note that if you register an account and/or shop online with us, we will be able to link your personal information collected from you before registration and/or your online purchase to your account and personal information that we collect after registration and/or your online purchase.

4. Why do we ask for this information?

When you shop with us at our trade counters, we may request your contact information and your payment information. You can also shop at our trade counters without providing any contact information or, if using cash, payment information.

When you place an order through our contact centre or our Digital Services, we will need your contact and payment information to enable us to take payment and fulfil your order. When you want to place an order via our Digital Services, we ask you to login or register so you can open a customer profile, save your browsing information and your preferences, and retrieve them from any of your devices. You can browse our website without providing us with any of this information.

To ensure that your payment details are not being used without your consent, we will validate the name, address and any other personal information supplied by you (which may include further personal information being requested, such as your date of birth. during the order process against appropriate third-party databases. By placing an order through our Digital Services or our contact centre you consent to such checks being made.

You may also provide us with your personal information via our forums, product questions and reviews, contact centre’s live chat, survey responses and competition entries.

We will ask for or collect your personal information when you use our trade counters (if you have an account with us) and our customer support services, including telephone support and instant messaging via third-party platforms.

We ask for your permission to send you marketing and promotional material via post, telephone, email, and SMS so that we can send you free gifts, discount vouchers, invitations to events, special offers, market research, and any other marketing material that we believe may be of interest to you. If you give permission, you will be able to withdraw it at any time by:

Where you are a registered user of our Digital Services, by using the Account section after logging in using your username and password and updating your preferences.
Using the unsubscribe link in each communication we send out which will opt you out of receiving either marketing emails or SMS messages, as applicable.
By using the Contact us enquiry form on our Digital Services;
By emailing us privacy@cmostores.com
By telephoning us 01752 692 769; or
By writing to Cmostores.com, Unit 12, Burrington Way, Burrington Business Park, Plymouth, PL5 3LX.

Please note that, even if you choose not to receive this marketing information, we may still use your personal information to provide you with important services communications, including communications in relation to any orders you submit or products you purchase. We may also offer you the opportunity to indicate the specific types of marketing communications you are particularly interested in receiving from us; where possible, we will tailor the communications you receive to reflect your choices, but we may send you other communications that we believe may be of interest to you.

We ask for your consent before using any user generated content on our website and/or on our marketing channels. If you give us your consent in writing or by supplying media to your review, you will be able to withdraw it at any time by messaging us on the platform we used to contact you, or by contacting us using the contact details provided below in section 9

When you use your payment card to make a purchase with us (either at our trade counters or via our Digital Services), we will link details of that purchase with other purchases made with the same payment card. (For security purposes, we do not keep your payment card details for this purpose.) We use this information to better understand how our customers purchase from us. If you opt in to receiving marketing communications from us, we will link details of your purchases with us with the other details that we hold about you, and we may use this information to make our communications with you more relevant. We may also provide you with offers and marketing information about our products and services printed with your till receipt. We may use the information we hold about you, including details of the items you have bought, to provide you with offers and information that we believe may be of interest to you in this way. You can opt out of this use of your personal information by contacting us via one of the methods above.

5. How do we use your personal information?

We have outlined the reasons why we use your personal information below. By law, we are also obligated to state the "legal basis for processing", which means we must inform you of the grounds on which we are allowed to use your information. This information is also provided below. The legal basis for each purpose is either that we have obtained your consent to use your personal information, or that we need to use your personal information to fulfill a contract with you, or that the use of your personal information is necessary for our legitimate interests. In the latter case, we will explain what those interests are.

PURPOSE/ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To register you as a new customer	(a) Identity	Performance of a contract with you
To register you as a new customer	(b) Contact	Performance of a contract with you
To process and deliver your order including:	(a) Identity	Performance of a contract with you
Manage payments, fees and charges	(b) Contact	Necessary for our legitimate interests (to recover debts due to us)
Collect and recover money owed to us	(c) Financial
	(d) Transaction
	(e) Marketing and Communications
To manage our relationship with you which will include:	(a) Identity	Performance of a contract with you
Notifying you about changes to our terms or privacy policy	(b) Contact	Necessary to comply with a legal obligation
Asking you to leave a review or take a survey	(c) Profile	Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
	(d) Marketing and Communications
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity	Performance of a contract with you
	(b) Contact	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
	(c) Profile
	(d) Usage
	(e) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
	(b) Contact	Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
	(b) Contact
	(c) Profile
	(d) Usage
	(e) Marketing and Communications
	(f) Technical
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
	(b) Usage
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity	Necessary for our legitimate interests (to develop our products/services and grow our business)
	(b) Contact
	(c) Technical
	(d) Usage
	(e) Profile

We would like to kindly inform our users that our Digital Services are designed for individuals aged 18 and above, and we do not intentionally collect data from minors.

6. How long do we keep your personal information?

We are required by law to keep your personal information only for as long as is necessary for the purposes for which we are using it. The period for which we keep your personal information will be determined by a number of criteria, including the purposes for which we are using the information, the amount and sensitivity of the information, the potential risk from any unauthorised use or disclosure of the information, and our legal and regulatory obligations.

7. Who do we share your personal information with?

We use the personal information to improve our websites and other Digital Services and for analysis purposes and to offer you products and services that they believe may be of interest to you.

We may disclose your personal information to third parties, including in the following circumstances:

We often rely on third-party service providers to help us with various tasks that involve handling your personal information. For instance, we may engage third-party providers to deliver packages, send SMS text messages and emails, maintain and update our customer databases, analyze data to improve our products and services, provide marketing assistance, process payments and refunds, conduct surveys, enroll customers in loyalty programs, provide customer service, and handle claims. These third-party providers are given access to your personal information only for the purpose of performing their tasks, and they are not allowed to use it for any other reason. We may also use the information we receive from these providers to enhance our customer databases, conduct credit checks, and prevent fraud.
We offer customers the option to pay for their purchases through our Digital Services using online payment methods and digital wallets. In such cases, your personal information may be shared with the providers of those services, such as PayPal, to complete the transaction. For more information on how PayPal uses your personal data, please refer to their Privacy Policy.
We may share the information we have about you, such as your email address and details of your purchases, with third parties who also possess your information or have an existing online relationship with you. This is done to identify you and provide you with relevant marketing online. For example, we may share your information with social media platforms, such as Facebook, Instagram, Twitter, YouTube, Pinterest, Reddit, and Google, so they can recognise you as our customer and customize the marketing messages we send you via their sites, applications, and products.
We may share your personal information with external agencies and organisations, including law enforcement agencies, to prevent and detect fraud and criminal activity. These agencies may check the information we provide against public and private databases and keep a record of these checks for future reference.
We may also disclose your personal information to the police and other law enforcement authorities to prevent and detect crime. If we receive any claims or potential claims against us, we may share your personal information with our third-party claim handlers and insurers. For example, we may provide our insurers with CCTV footage and information contained in our accident logs.
If we sell or buy any business or assets, we may share your personal information with the prospective seller or buyer of those assets.
If we transfer substantially all of our assets to a third party, your personal information may be one of the transferred assets.
We may share your personal information with third parties if we are required to do so by law or to enforce or apply any agreements we have with you or with third parties.
We may also share your information to protect our rights, property, or safety or those of our customers, employees, or third parties.
We may share your details with third parties to improve the quality and accuracy of our database, suppress inaccurate records, append marketing information, conduct solvency and credit scoring, conduct market research, and enable functionality, analytics, and marketing communications.

Links to external sites

We may provide links to the websites of other CMO Group companies from our Digital Services. Your use of those websites is subject to the terms of use and policies available on those websites.

From time to time, we may also establish relationships with third parties that will enable you to access the websites or applications (such as video players) of such third parties directly from our Digital Services. Each third party operates its own policy regarding the processing of your personal information and the use of cookies on its website(s) or through its applications and you are advised to read the third party's privacy policy and cookies policy.

Please note that third-party websites and applications are not under our control. When you click through to these websites or access these applications you leave the area controlled by us. Similarly, where you have contacted us or shared user-generated content with us using a third-party platform (for example a social media platform), the third party(ies) that provide these platforms will use your information in accordance with their own privacy notices. We do not accept responsibility or liability for any issues arising in connection with the third party's use of your data (including your personal information).

Where will your personal information be processed?

Your personal information may be transferred to, and stored and processed in, one or more countries outside the country in which we are established (see Who we are, above), including countries which do not provide equivalent protection for personal information. In these circumstances, we will take reasonable steps and implement appropriate measures to ensure that your personal information is adequately protected in accordance with the law.

These measures include either:

Transferring your personal information to countries that have been deemed to provide an adequate level of protection for personal information under applicable data protection law; or
Transferring your personal information where the recipient has agreed to an approved agreement in the form of the standard contractual clauses.
Occasionally, we may transfer your personal information in circumstances where there are no adequate safeguards where this is permitted by data protection law.

Please contact us using the details below if you want further information on the specific safeguards used by us when transferring your personal information out of the country in which we are established.

8. Your rights

You have the right to ask us to:

Confirm what personal information we hold about you and provide you with a copy of that data.
Correct any personal information that is inaccurate.
Remove your personal information where there is no good reason for us to continue to hold that data.
Temporarily stop using your information if you are questioning our right to use that data and in other circumstances where that right is applicable.
Stop using your personal information unless we can demonstrate a valid reason, we need to continue to hold that data e.g., to support a product warranty.
Stop using your personal information to send you marketing materials such as our catalogue, marketing email, discounts, or vouchers.
Provide you with the personal information that you have provided to us, in a structured and commonly used electronic format, or transmit that information directly to another company if that is technically feasible. This applies where we are using your personal information on the basis of your consent or because it is necessary to perform a contract with you (see How do we use your personal information, above).

Our security procedures mean that we may request proof of identity before we are able to disclose your personal information to you or comply with other requests.

We want to make sure that the personal information we hold about you and your preferences as to how we contact you are accurate and up to date. If any of the details are incorrect, please let us know (details below) and we will amend them.

You also have the right to make a complaint to the Information Commissioner's Office if you are not happy with how we have handled your personal information.

You can contact the supervisory authority for UK residents via https://ico.org.uk

CMOStores.com limited (company number 06755395)

9. How to contact us?

To update your details, object to data processing, request data is erased or ask for a copy of your personal information, you can:

call us on 01752 692 769
write to us at: Customer Correspondence, CMOStores, Unit 12, Burrington Way, Burrington Business Park, Plymouth, PL5 3LX
email us at privacy@cmostores.com

If you would like to contact the Data Protection Office, please email privacy@cmostores.com , or write to Data Protection Office, Burrington Way, Burrington Business Park, Plymouth, PL5 3LX

10. Protecting your personal information

The transmission of information via the internet is not completely secure; this risk is common across the internet and not specific to our services. We cannot guarantee the security of your data (including your personal information) transmitted to our services; any transmission is at your own risk.

It is important for you to protect against unauthorised access to your password and to your computing device. Be sure to sign off and close your browser when you have finished your session. This will help to ensure that others do not access your personal information if you share your computing device or use a computing device in a public place such as a library or internet cafe.

We would recommend that you do not use the same password and e-mail address combination for your CMOstores account as you use on other websites. Using the same password and e-mail address combination for multiple accounts puts your personal data at risk. Should your details be subject to a cyber-attack on another website, this can lead to your personal data being compromised in credential stuffing attacks.

11. Updates to this notice

We may update this notice from time to time. The latest version of this notice will be posted on our website.