This website is operated and provided by My Bespoke Room Ltd, a company registered in England and Wales under company number 08804168, whose registered office is at 63 Bermondsey St, London, England, SE1 3XF ("MBR", "we", "us", "our"). MBR is the data controller of Your Data for the purposes of the Data Protection Legislation.
What Data is collected and how?
You are under no obligation to provide any particular Data to us; however, if You choose not to, some of the Interactive Services or Site functionality may not be available to You.
Data provided by You
We may collect from You the following types of Data about You:
Your email for the verification and authentication processes;
Your Registration Information for the MBR Registration Form (which may include Your name, address, telephone number, email address, company details and job position). We use this information to provide a better customer experience by sending order confirmations, substitution information, dispatch and delivery confirmations. Please ensure that email addresses are accurate and if you need to amend it please email us at firstname.lastname@example.org;
Your payment details i.e. Your bank name, account number and sort code;
Your visits to the Site and the MBR Content that You download;
Your UGC that You may upload or submit to the Site by way of e.g. Your MBR Brief;
information that You provide for a specific purpose, such as to provide You with certain information You request or to send You product information and offers, emails or newsletters;
information in connection with communications You send us, for example to report a problem or submit queries; and
if You call any of the customer service telephone numbers quoted on the Site, we may record Your call. These recordings are used for training and quality control to ensure that We continuously monitor and improve our customer service standards.
When You pay the MBR Fees or pay for Products bought using the Site or the Interactive Services, we use PayPal and Stripe Payments as third party partners to process payments ("Payment Processor"). You will be required to provide the relevant Payment Processor with financial data (i.e. Your payment details) in order to authorise payments and to receive payments. When You purchase MBR Interior Design Services or You purchase Products using the Site or the Interactive Services, Your consent is given to provide Your Data to the Payment Processor directly as a necessary part of using the Interactive Services. The policies of the Payment Processor will be applicable as between You and them. Except as provided here, We will not share financial Data with third parties (including Third Party Retailers) without Your prior consent.
Technical Data and automated collection
We may automatically collect or otherwise Process technical information such as the date of Your visit to the Site, the type of internet browser and operating system You use, the Internet Protocol (IP) address of the computer You use, traffic and path data, information from cookies, the website from which You linked to the Site and the website You visit as You leave the Site and details of the functions and services You select or use on the Site or the Interactive Services. This is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for MBR Users and to draw conclusions upon demographic information.
We use this information to collect broad demographic information about the visitors to the Site and the Interactive Services and to improve their content and to help us understand how MBR Users are interacting with the Site, the Interactive Services and other services provided.
Some of this technical Data may consist of cookies, which are small text files that often include a unique identifier that is sent by a web server to your internet enabled device when you visit a website. For details of how we deal with cookies, please see our Cookies Policy.
We do not expect to hold or Process any sensitive Data about You. However, if it is necessary for us to do so, then we will inform You in advance of the purposes for which we propose to Process Your sensitive Data. In most cases, we will always obtain your consent before processing Your sensitive Data, which is the legal basis for us being permitted to do so.
For what purposes is Data used?
Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the goods and services You have requested. We may also use the information that You have provided to ensure that the content on our Site is presented in the most effective manner for You and Your computer and to allow You to participate in any interactive features on our Site (including the Interactive Services) when You choose to do so.
By using our Site and providing Your Data, You agree that we may use Your Data to:
provide the products, services and customer support You request;
enhance the quality of the Interactive Services we can provide to You;
resolve disputes and troubleshoot problems;
prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our Service Terms;
manage, customise and improve our services, content and advertising;
tell You about goods and services and provide You with targeted marketing, service updates, and promotional offers based on Your communication preferences;
compare information for accuracy, and verify it with third parties; and
complete credit checks with credit reference agencies (where we extend credit to You), who may keep a record of any search that they undertake.
To minimise the risk of unauthorised access to Your Data, We may also use some of Your Data to authenticate You when using the Site and the Interactive Services.
Contacting You and opting out of certain purposes
You acknowledge that Your Data may be used by MBR or the relevant Third Party Retailer to contact You by post, phone or electronic mail when necessary in connection with Your use of the Site and the Interactive Services and/or Your purchase of Products or MBR Interior Design Services.
From time to time, MBR or the relevant Third Party Retailer may also contact You by post, phone or electronic mail in order to send You one or more of the following:
a MBR Mood Board;
a communication about an order placed by You; or
MBR reserves the right to contact a MBR Member in respect of a MBR Membership, an MBR Account or for related reasons. When You register to become a MBR Member, You give us Your consent to contact You for these purposes.
You can opt-out of certain uses of the Data we collect from You. For example, You may opt out of receiving any or all direct marketing from us (see "Opting out" below). However, to the extent that You request the Interactive Services, Products, or an MBR Mood Board, You cannot opt out of receiving the communications set out at (a) or (b) above, as these are a necessary part of receiving these items.
Any Data that is held with MBR shall be retained in accordance with Data Protection Legislation.
Legal basis for use of Your Data
The law permits us to process your personal data in the way that it does because the processing is:
necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business and to discharge our legal obligations to store and disclose information where necessary; and/or
necessary for the performance of our contract to provide You with goods and services; and/or
necessary in order to comply with a legal obligation to which MBR is subject.
Recipients of Data
The following categories of recipients may receive your Data and process it for the purposes outlined above:
We may disclose Data to provide our products and services (including the Interactive Services), to respond to legal requirements, enforce our policies, and protect our rights and property. The Data You provide to us may also be shared with third party companies, agents, contractors, service providers or related companies (including relevant Third Party Retailers and Payment Processors) if this is necessary to provide You with our products and services, respond to Your inquiries or for any other related purposes.
We may also share Your Data with:
other companies we have instructed to provide services for us;
other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
law enforcement agencies, other governmental agencies or third parties where we believe that it is necessary to do so in order to comply with laws or regulations, to assist law enforcement, or in other limited circumstances (for example if required by a court order or regulatory authority, to enforce the terms under which You transact or communicate with or via MBR, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
any successor in interest, in the event of a liquidation or administration of MBR; [and
credit reference agencies (where we extend credit to You)].
Links to Other Sites
Security of Information
The privacy and protection of Your Data is important to us. However, although we maintain physical, electronic, and administrative safeguards to protect Your Data from unauthorised or inappropriate access, You acknowledge that the transmission of information via the internet is not completely secure and we cannot guarantee the security of Your Data transmitted to us or provided via, to, from or through the Site. You accept that MBR cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential Data which You do not wish to communicate by email, please contact MBR by telephone or post to arrange an alternative method of communication. You transmit all Your Data at Your own risk.
Once Your Data is submitted, We have security procedures in place to protect the loss, misuse and alteration of the Data under their control. 128 bit industry standard Secure Server Software (SSL) is used as a minimum standard which encrypts all of Your Data in respect of a Your payment details including Your name, and address, so that it cannot be read as it travels over the Internet.
In addition, any MBR User statistics that We may provide to prospective partners regarding Your usage of the Interactive Services are provided in the aggregate only and do not include any individually identifiable Data.
Retention and Deletion of Information
All Data is stored in accordance with our internal retention and destruction policies. How long we keep Your Data collected through our Site depends on the context in which You provide it and the purpose for which we use it. We will only retain it for as long as is necessary for such purposes, after which time we will delete it. We will keep Your personal details, preferences, UGC and account details for as long as You have an active MBR Account. We will keep records of any purchasing activities for up to six (6) years after Your MBR Account is cancelled.
We may send You direct marketing communications, and retain Your contact information necessary for this purpose, (provided that You have consented to receiving them) for as long as You do not unsubscribe from receiving the same from MBR.
You understand and acknowledge that You have no ownership rights in Your MBR Account and that if You cancel the same, the same will be terminated and all Your information will be deleted from Your MBR Account and will be further deleted from any MBR archives. Your Data may continue to be retained by authorised third parties such as the relevant Payment Processor for limited purposes only, in accordance with its own privacy policies and practices.
Transfer of Your Data outside of the EEA
Data that You submit via the Site is sent to and stored on secure servers owned by or operated for us. Data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve our Site or the Interactive Services, or to assist in our security, credit risk or fraud protection activities.
Where recipients are outside the EEA, we ensure that the recipient provides an adequate level of protection for your personal data or the transfer is otherwise permitted under applicable Data Protection Legislation, by methods including using [standard contractual clauses, binding corporate rules, by registering for the Privacy Shield program, or by relying on a relevant adequacy decision by the European Commission]. You can obtain a copy of any of these safeguards by emailing us at email@example.com
We do not generally rely on your consent as the legal basis for transferring your personal data to outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on your consent as the legal basis for such processing. Where we do, you may withdraw your consent at any time in the manner described below.
Where required by Data Protection Legislation, You will be given a choice when You provide us with Data to opt into certain uses we may intend to make of that Data, such as sending You newsletters, information or offers containing updated information about us, our goods and services, promotions, our MBR Blogs, Interactive Services, customer surveys or our Site. You may also be asked if You would like to receive marketing from particular third party organisations. You will be able to indicate Your consent to each specific proposed use by checking the relevant box to opt in. We will not send you direct marketing, or pass Your details to third parties for the purpose of them sending You direct marketing, without Your consent.
You also have the option of "unsubscribing" from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to You. Details of how to unsubscribe will be included on each electronic mailing we send You. Alternatively, just send an email to firstname.lastname@example.org with "URGENT – UNSUBSCRIBE REQUEST" in the subject line and the email address that You wish to be removed within the email, or send Your request to MBR using any of the contact details below.
We will action any opt out request from You without delay, and in any event within one month.
If Data has been passed to third parties, You may need to contact them separately if You change Your mind in relation to their use of Your Data.
At any time, you have the right to:
request a copy of any Data that we hold about you;
information about how we process your Data (for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences, and the safeguards we rely on if we transfer your personal data from within to outside of the European Economic Area);
ask us to rectify any Data that we hold about you, if you consider that it is inaccurate.
ask us to erase any Data that we hold about you, if you consider that we do not have the right to hold it;
object to us processing your Data in your particular situation, which you may exercise if we rely on the fact that the processing is necessary for the purpose of legitimate interests pursued by us in order to carry out that processing; and
withdraw any consent you give to our processing your Data (although please note that in certain circumstances it may be lawful for us to continue processing your Data even where you have withdrawn your consent).
You can exercise any of these rights by contacting us using the details below. Any request for your Data must be in writing and we will respond within one month. Please note that we may ask you to verify your identity and ask you for more details about your request.
There may be some information which we are not legally able to disclose to you. Also, in exceptional circumstances, it may not be practicable for us to provide you with copies of all the documents that you request. If this is the case, we will explain our reasoning to you. We may have to charge you an administrative fee for the cost of providing you with a copy of certain documents.
You also have the right to complain to the data protection regulator about our information rights procedures. The regulator is the Information Commissioner's Office and their contact details are available here: https://ico.org.uk/concerns/
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to Your device when You visit a website. Cookies are then sent back to the originating website during Your browsing session or on each subsequent visit, or to another website that recognises that cookie. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the Site. Some expire at the end of Your session on the Site, others will remain on Your computer for a little longer. When You return to websites or visit websites that use the same cookies, these cookies and therefore Your browsing device, are recognised.
Cookies can be first-party or third-party. First-party cookies are cookies set by the specific website You visit i.e. the website displayed in the URL window. Third party cookies are set by third party services that appear on our Site. They are set by the operators of that service and are not in our control. They are set by e.g. Twitter, Facebook and other advertisers or file sharing platforms. They may use the information they obtain from Your use of their cookies to track Your browser across multiple websites; to build a profile of your web surfing; or, to target advertisements which may be of particular interest to You.
Cookies can be categorised in accordance with the categories found in the ICC UK Cookie guide as set out below:
Strictly necessary cookies – these cookies are essential in order to enable You to move around a website and use its features and enable services You have specifically asked for. Consent is not generally required for these cookies.
Performance cookies - these collect information about how visitors use a website, for example, by recording which pages users go to most often (usually on an anonymous basis).
Functionality cookies - these cookies allow a website to remember the choices a user makes, such as a user name or language preference.
Targeting or advertising cookies - these collect information about a user's browsing habits and are usually placed by advertising networks with the website operator’s permission.
Cookies can also be categorised in accordance with how long they are saved on Your device: "Session cookies" are short-term cookies that are only saved on the computer’s memory for the duration of a user's visit to the website, whereas "Persistent cookies" remain saved in the computer’s memory for a set period of time, even after the browser session has ended.
The cookies we use
We do use or allow third parties to serve cookies that fall into the four categories above. For example, like many companies, we use Google Analytics to help us monitor our traffic, to get a sense of how many visitors the Website receives every day and which sections of the site users typically look at. It's a key way of a knowing how well they're doing and what they can do better. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions. Please note we do not allow advertising on our Website so there will be no cookies for this purpose.
How do I refuse or restrict cookies?
If You would like to restrict or block cookies used on our Site (or on any website), You may do so by activating the browser setting which allows You to refuse the setting of cookies. You will need to do this on each device that You use to access the internet. The Help or Internet Settings function within Your browser should tell You how. Alternatively, You may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of Your mobile phone You will need to refer to Your handset manual.
Please be aware that some of the services on the Site or the Interactive Services will not function if Your browser does not accept the relevant cookies.
Please be aware that if You select to refuse or restrict cookies You may be unable to access certain parts of our Site.
Changes to this Cookies Policy
We may amend this Cookies Policy at any time without notice by posting the amended terms on the Site. All amended terms will automatically take effect immediately on posting. Please check this Cookies Policy periodically to inform Yourself of any changes. Your continued use of any portion of the Site following the posting of the updated Cookies Policy will constitute Your acceptance of the changes.