Privacy policy

3.1 – The information we collect about you will be recorded electronically may be used in the following ways: 

3.1.1 – To verify your identity and to enable us to consider and process your order or your application for other products or services. Our legal basis for processing your personal information for this purpose is that it is necessary for our legitimate interests of carrying out our business of providing our products and services.  This is also necessary in preparation for entering into a contract with you.

3.1.2 – To detect, prevent and investigate actual potential fraud-related activities. Our legal basis is compliance with our legal obligations.

3.1.3 – To collect payment from you. Our legal basis for processing your personal information for this purpose is that it is necessary for our legitimate interests of carrying out our business and providing our products and services.  This is also necessary to perform the contract we have with you.

3.1.4 – To develop, manage and market products and services to meet your needs, our legal basis for processing your personal information for this purpose is our legitimate interest. We describe contacting you about our own products and services that may interest you as Direct Marketing. Our legal basis for processing your personal information for direct marketing is our legitimate interests in promoting our own products and services to people who have enquired about or purchased from us. Where the law requires your consent, we will obtain it.

3.1.5 – To help us to administer and service your account with us. Our legal basis for processing your personal information for this purpose is that it is necessary to perform our contract with you and also for our legitimate interest in order to provide you with the necessary service following your purchase of one of our products.

3.1.6 – To contact you in connection with your enquiry, even if you do not proceed to complete an order or application with us. Our legal basis for processing your personal information for these purposes is that it is necessary for our legitimate interests of servicing requests for information from people who might become customers, and of finding out why you decided not to proceed so that we can in the future better our product and service offerings to customers in general. Where we include Direct Marketing information in these calls, our legal basis is as set out at section 3.1.4.

3.1.7 – To extract certain information for the purpose of generating statistics for our own internal purposes (including market product analysis). Where we do this statistics-related processing to improve our internal processes, our legal basis for processing your personal information for these purposes is that it is necessary for legitimate interests pursued by us (namely, the development and improvement of our products and services).

3.1.8 – To update our website to better meet our clients’ needs in the future. Our legal basis for processing your personal information for this purpose is that it is necessary for our legitimate interests (ensuring the Website is presented as effectively as possible for you).

3.1.9 – To notify you about changes to our service. Our legal basis for processing your personal information for this purpose is that it is necessary for our legitimate interests of updating you if there is a change to our service we need to tell you about, for instance a change affecting an order you have placed or a store you have arranged to collect from.

3.1.10 – To comply with legal regulatory requirements to which we are subject, to establish and defend legal rights, to prevent, detect and investigate crime, to deal with requests to exercise your rights under data protection law (as relevant).  The legal basis for this is compliance with our legal obligations.

3.1.11 – To understand how visitors use our website, so that we can improve it and measure the effectiveness of our marketing. Our legal basis for processing your personal information for this purpose is your consent, given through our cookie banner. You can withdraw your consent at any time.

3.1.12 – To measure the effectiveness of our advertising and improve our marketing activities, including through the use of tools such as Google Ads Enhanced Conversions. This may involve securely sharing limited personal data (such as your email address or telephone number) in hashed form with third-party advertising platforms. Our legal basis for processing your personal information for this purpose is our legitimate interests in improving our marketing performance. Where required by law, we will rely on your consent.

4.1 – We may share your personal information with any member of our group or affiliated companies for the reasons set out above, who may process your personal information for the purposes described in Section 4.2.1 (onwards) below.

4.2 – Sometimes (and with your approval where required), we will share your information with carefully selected third parties outside our group. We may do this for the following reasons: 

4.2.1 -To our agents, staff and approved third parties to carry out services for us (such as providers of legal professional services (including auditors) and third parties who send communications on our behalf). Our legal basis for processing your personal information for this purpose is that, in the majority of cases, it is necessary for our legitimate interests (these are described above throughout section 3.1 above) to perform our contract with you (or in order to take steps at your request prior to entering into a contract with you).

4.2.2 – To facilitate the processing of debit card and credit card payments made by you, we may also share your personal data with third-party payment processing service providers. This is processing that is necessary for our legitimate interests.

4.2.3 – To provide you with information about special promotions and offers as referred to in the “Keeping You Informed” section below. Our legal basis for processing your personal information for this purpose is our legitimate interest.

4.2.4 – To protect us, our group of affiliated companies or others. We may share your information with third parties when we believe it is necessary to comply with the law or protect our or another person’s rights, property, or safety. This includes exchanging information with third parties (such as other lenders, law enforcement agencies and regulatory authorities) to protect against fraud and reduce risks. Our legal basis for processing your personal information for this purpose is that it is necessary to comply with our legal obligations and, in other cases, to protect our legitimate interests by responding to requests from law enforcement agencies.

4.2.5 – If there is (or is to be) any change in ownership of our business or assets, then we may wish to share your information so that the new (prospective) owners may continue to operate our business effectively and continue to provide services to our customers. This may include new shareholders or any organisation that takes over or transfers any agreements we have entered into with our customers.  Our legal basis for processing your personal information for this purpose is that it is necessary for purposes of legitimate interests pursued by us and/or new (prospective) owners (which are, for new/prospective owners, shareholders or other organisations acquiring our business, to conduct due diligence in order to make a decision around acquiring our business (or a stake in our business).  The purchaser of our business assets may then rely on its own lawful reasons for processing when it has your personal information – you should refer to its privacy notice.

4.2.6 – We may share your personal information with other people if you give us consent – this would be our legal basis for that sharing.

We will place appropriate obligations and restrictions on third parties to protect your personal information, in line with our obligations under data protection laws.

In addition, see paragraph 5, as we may share your personal information with fraud prevention agencies.

4.2.7 – This website is operated using the Shopify ecommerce platform, and Shopify processes personal information on our behalf in order to host our website and process your orders.

4.2.8 – If you choose to pay using a buy now, pay later provider such as Klarna, we will share the information necessary to process your payment with that provider. That provider will use your information in accordance with its own privacy policy, and will be responsible for the credit agreement you enter into with them.

4.2.9 – We may share certain personal information with advertising partners (such as Google) to help measure the effectiveness of our advertising and to improve our marketing. This may include sharing identifiers such as email address or telephone number in a secure, hashed format as part of services such as Google Ads Enhanced Conversions. Where required by law, this will be done on the basis of your consent.

5.1 – Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, to verify your identity. These checks require us to process your personal data.

5.1.1 – The personal data you have provided, we have collected from you, or we have received from third parties may include your:

• name
• date of birth
• residential address history
• contact details such as email address, telephone numbers
• financial information
• employment details
• identifiers assigned to your computer or other internet-connected device including your Internet Protocol (IP) address
• vehicle details

When fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, verifying identity, protecting our business, and complying with applicable laws. Such processing is also a contractual requirement of the services or financing you have requested.

We, fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud and prevention agencies can hold your personal data for different periods of time, if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

5.1.2 –  As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:

• our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or
• you appear to have deliberately hidden your true identity.

You have rights in relation to automated decision making: if you want to know more, please contact us using the details above.

5.1.3 –  If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

5.1.4 –  Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

5.1.5 – Your personal data is protected by legal rights, which include your rights to:

• object to our processing of your personal data;
• request that your personal data is erased or corrected;
• request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the contact details below.

If you are unhappy about how your personal data has been used, please refer to our company complaints policy (a copy of this is also available in store). You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data https://ico.org.uk/.

5.2 – Automated decision making including profiling

5.2.1 – You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

6.1 – Some companies within our group of affiliated companies, sometimes other third parties with whom we share personal information, are or may be located outside the UK and the EEA (as it is made up from time to time). In addition, some of our service providers may be located outside the UK and the EEA or use data processing locations outside the UK and the EEA.

When we share your personal information with certain other third parties, your personal information will be transferred outside the UK (and in some cases outside the EEA).  Where applicable laws do not provide adequate protections for your personal information, we will take steps to ensure appropriate safeguards apply to maintain the same level of protection required under UK data protection laws.

Safeguards include contractual obligations imposed on the recipients of your personal data. Those obligations require the recipient to protect your personal data to the standard required under UK data protection laws.  Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing where the framework is the means of protection for the personal information.  For more information about these appropriate safeguards, or others as may be relevant from time to time, including to obtain a copy of them or to find out where they have been made available, you can contact us using the details below.

Unless you have advised us to the contrary, we may contact you by telephone, SMS, post or email to send you information and communications about your order or the product or service you obtain from us. These are service communications, not marketing. (Please see the 'Keeping You Informed' section below regarding how you may be contacted for marketing purposes).

8.1 – How long we keep your personal information for depends on the basis on which it was provided, generally however:

8.1.1 – We will keep the information that is necessary to enable us to provide you with a service that you have requested for as long as it takes us to provide that service.

8.1.2 – If you have asked that we do not use your details for marketing purposes, we may still need to keep them in relation to that purpose to ensure our systems reflect your preferences.

8.1.3 – We will keep records of any transactions you enter into so that we can respond to any complaints or disputes that arise and deal with any claims in relation to such transactions (including protecting or enforcing our legal rights). Otherwise we will keep the information where appropriate for our legitimate business needs for as long as necessary to do so, such as for the purposes of regulatory reporting, auditing, anti-money laundering/fraud investigations and credit file reporting.

8.1.4 – If you apply for a product or service and are unsuccessful, we will keep your personal information for as long as we reasonably need to in case of questions or queries from you in relation to the application.

8.1.5 – We will keep other personal information about you if it is necessary for us to do so and to comply with the law or our regulatory obligations, or where appropriate for legitimate business needs (including the purposes described at section 8.1.3 above).

9.1 – From time to time we would like to contact you by SMS, post, email, or telephone, with offers relating to products of ours which we think you might be interested in. We will not offer you Direct Marketing products from external third parties. We do this where you have enquired about or purchased from us, and only in relation to our own products and services. Every marketing message includes a simple way to opt out.

9.2 – If you do not want these communications, you can advise us, and we will not communicate further to you in this way. Please contact us to opt out. You can also change your mind later.

9.3 – If you do indicate in the way described at section 9.2 that you do not want to receive communications from us, please note that this will not prevent us from being able to provide you with the products or services you are applying for – this is separate to the issue of marketing communications.  You will not receive any marketing from us, and we will not share it with anyone else for them to send marketing to you.

9.4 - Where you have provided your mobile number and given explicit consent to receive SMS marketing, we will use your phone number to send you marketing messages about our products, promotions, and updates. You can opt out of receiving SMS marketing at any time by replying STOP to any message we send, or by contacting us at info@sandrjewellers.com. 

If you provide us with your consent, you have the right to withdraw it at any time by emailing info@sandrjewellers.com or by requesting this in store. We will process your request to withdraw consent for marketing communications as promptly as possible; however, this may take up to 5 working days, during which time you may still receive marketing communications from us.  In addition, certain rights under privacy law can be relevant where processing of your contact details is based on consent, such as erasure and portability – please see below.

9.5 – We may also use your personal information to measure the effectiveness of our marketing activities, including through technologies such as Google Ads Enhanced Conversions, where permitted by law. You have the right to object to this processing or opt out at any time, including by withdrawing your consent where applicable.

The rights explained in this paragraph apply to you in relation to the company which is the data controller of your information.  The data controller is the entity that determines the purposes and means of processing your personal information.  We are a data controller of your personal information; therefore, you are entitled to make requests to us to exercise your rights in relation to your personal information controlled by us. However, we can only comply with your requests to the extent that we are a data controller of your personal information – if your request relates to any other companies (including affiliated companies within our group), you must make a separate request to them to exercise your rights.

10.1 – Under data protection laws, you have the right to make the following requests in relation to your personal information.  Please be aware that these rights do not apply in all circumstances.  If you seek to exercise one against us, we will explain to you at that stage whether or not the right does apply to you based on the facts.

• The right to be informed: including about our processing of your personal data.  This is why we have this data privacy policy.

• Access: You have the right to access the personal information we hold about you as a data controller (although certain exceptions may apply).  In certain instances, you may be required to pay a reasonable fee based on our administrative costs if you request additional copies. You will need to make a separate request and pay a separate fee for each company within the group of affiliated companies whose records you wish to access.  This right enables you to obtain confirmation that your personal data is being processed, to access it, to obtain other supplementary information, and to understand how it is processed.  This helps you understand and verify the lawfulness of the processing of your personal data.

• Rectification:  You have the right to request that we rectify any inaccurate personal information about you (we also require you to inform us if your personal data is inaccurate or out of date – see paragraph 11.1 below).  This includes the right to have any incomplete personal data completed (taking into account the purposes of the processing), including by means of providing a supplementary statement;

• Erasure (‘right to be forgotten’):  In certain circumstances, you have the right to request that we erase your personal data.  This right is not absolute – it applies only in particular circumstances where it does not apply; any request for erasure will be rejected.  Circumstances when it might apply include where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed, if the processing is based on consent which you then withdraw, when there is no overriding legitimate interest for continuing the processing, if the personal data is unlawfully processed, or if the personal data has to be erased to comply with a legal obligation.  Requests for erasure will be refused where that is lawful and permitted under data protection law, for instance where the personal data has to be retained to comply with legal obligations or to exercise or defend legal claims;

• Restriction; In certain circumstances you have the right to request that we restrict our processing of your personal information, for instance where you contest it as being inaccurate (until the accuracy is verified); where you consider that the processing is unlawful where this is the case; where you request that our use of it is restricted; or where we no longer need the personal data;

• Data portability: You have the right to request that we provide you with a copy, in a machine-readable portable format, of the personal information you have provided to us, or to request that we transmit it directly to another data controller. This right applies only where we process personal data based on consent or a contract by automated means; it is different from the right of access (see above). The types of data you can obtain under the two separate rights may be different; you are not able to obtain through the data portability right all of the personal data that you can obtain through the right of access;

• Right to object: In certain circumstances you may have the right to object to our processing of your personal information.  This right allows individuals, in certain circumstances, to object to processing based on legitimate interests, direct marketing (including profiling), and processing for statistical purposes.  However, in such a case we may be able to demonstrate that the processing is required on compelling legitimate grounds or for the establishment, exercise or defence of legal claims;

• Rights in relation to some automated decision making about you including profiling (as relevant) if this has a legal or other significant effects on you as an individual.  This right allows individuals, in certain circumstances, to access safeguards against the risk that a potentially damaging decision is taken without human intervention.

• Please note that where we process your information for direct marketing purposes, you always have the right to object to that processing.  Furthermore, where we are processing your personal information based on your consent, you have the right to withdraw your consent to the processing at any time.  If you do this and if there is no alternative lawful reason which justifies our processing of your personal information for a particular purpose, this may affect what we can do for you.  For instance, it may mean that we cannot take into account the data concerning your health in connection with arrears of payments or that you cannot receive any marketing from us about third party products and services and those of our group of companies (as relevant).

You have the right to complain to the Information Commissioner’s Office at any time (see below for more details).

11.1 – If any data or information we hold about you is inaccurate or out of date, then please let us know, and this will be corrected where appropriate. Please see section 10.1 above for more details about the right to rectification.

11.2 – To exercise your rights as described in section 10, please contact us as set out at section 17.

12.1 – Appreciating that the privacy and security of your information is of the utmost importance, we have implemented technology security policies, rules and measures to protect the personal information we hold about you.

12.2 – We take the steps required by UK data protection law to protect your personal information. However, please be aware that providing information online over the internet carries inherent security risks, and we cannot therefore guarantee the security of any data disclosed online, particularly during transmission from you to us. We ask that you do not provide us with any sensitive personal information online (please see the ‘Special categories of personal information’ Section below) unless we specifically ask for this.

12.3 – To help protect your personal information, we take steps where possible to anonymise your personal information where it is not necessary for the information to be identifiable for the purposes of the processing – for example, we anonymise your personal information before using it to test our IT systems.

Information about you which is considered special categories of (or ‘sensitive’) personal information under the data protection legislation includes information about your medical or health conditions, racial or ethnic origin, genetic data, biometric data (for the purpose of uniquely identifying you), political opinions or trade union membership, religious or philosophical beliefs, sex life, sexual orientation.   (In addition, there is a separate category called criminal convictions and offences data, which may be relevant if fraud or other crimes are suspected).  (Please note that financial information is not considered by data protection legislation to constitute a special category of information). If we need to process special categories of personal information about you, we will notify you and ask you to specifically agree to the use of such information, as appropriate. Otherwise we ask that you do not provide us with such information where we do not request it, for example in emails to us or on telephone calls.

If you call any of the telephone numbers quoted in our literature, on our website or in correspondence, we may record your call. We use these recordings for training, regulatory, and quality control purposes to ensure we continuously monitor and improve our customer service standards.

15. Cookies and similar technologies 

A cookie is a small text file that a website places on your device. It allows the site to recognise your device on return visits and to remember information about how you use the site. This section also covers similar technologies that are not strictly cookies, including local storage, session storage, and tracking pixels. Where we refer to "cookies" below, we mean all of these.

15.1 Your choices

When you first visit our website, you are shown a consent banner where you can accept all cookies, reject all non-essential cookies, or choose which categories to allow. Rejecting non-essential cookies will not affect your ability to browse and buy from our website.

You can change or withdraw your consent at any time using the cookie preferences link in the footer of every page. Withdrawing consent is as straightforward as giving it.

15.2 Categories of cookies we use

Strictly necessary. Required for the website to function, to keep your basket and checkout working, and to remember your cookie choices. These do not require your consent and cannot be switched off.

Analytics. Help us understand how visitors find and use our website — which pages are viewed, how people move through the site, and where they encounter difficulty. We use this to improve the site.

Marketing. Used to measure the performance of our advertising and to make the advertising you see more relevant. These cookies allow us to understand which campaigns lead to enquiries and orders, and are set by advertising and attribution providers on our behalf.

15.3 Strictly necessary

15.4 Analytics

15.5 Marketing

15.6 Third parties on our site

Some cookies on our website are set by third parties rather than by us. Some pages also include content served by third parties, which sends your IP address and basic browser information to that provider when it loads. We do not control cookies set by these providers, and you should refer to each provider's own cookie or privacy policy for details of how they use the information they collect.

Shopify. Our website and checkout are operated using the Shopify platform. See Shopify's privacy policy.

Google. We use Google Analytics to understand how our website is used, and Google Ads to measure the performance of our advertising. See Google's privacy policy and how Google uses information from sites that use its services.

Meta. We use the Meta pixel to measure the performance of our advertising on Facebook and Instagram. See Meta's privacy policy.

Ruler Analytics. We use Ruler Analytics to understand which marketing activity leads to enquiries and orders. This includes call tracking, which means the telephone number displayed on our website may vary so that calls can be attributed to the marketing activity that prompted them. See Ruler Analytics' privacy policy.

Klaviyo. We use Klaviyo to send our marketing emails and to understand how you interact with them. See Klaviyo's privacy notice.

Elfsight. We use Elfsight to provide the chat widget on our website, which allows you to continue your conversation with us on WhatsApp. See Elfsight's privacy policy.

Zoho. We use Zoho Forms to collect enquiries submitted through our website. See Zoho's privacy policy.

Trustpilot. We display a Trustpilot review widget, which loads from Trustpilot's servers. See Trustpilot's privacy policy.

15.7 Controlling cookies through your browser

Our consent banner is the simplest way to manage cookies on this website. You can also control cookies through your browser settings, which allow you to block or delete cookies across all websites you visit. Blocking all cookies, including strictly necessary ones, may prevent parts of this website from working correctly. Your browser's help pages provide guidance.