Privacy Policy




Welcome to Browns Builders Merchants Limited’s privacy notice.

Browns Builders Merchants Limited respects your privacy and is committed to protecting your
personal data. This privacy notice will inform you as to how we look after your personal data and
tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.







7.         DATA SECURITY



10.       GLOSSARY

1.         IMPORTANT INFORMATION AND WHO WE ARE Purpose of this privacy notice

This privacy notice aims to give you information on how Browns Builders Merchants Limited collects
and processes your personal data through your use of and any data you may
provide when you register as an account holder, purchase products from us, sign up for our
newsletters, submit enquiries or give us feedback.

Our  website  is  not  intended  for  children  and  we  do  not  knowingly  collect  data 
relating  to children.

It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to override them.


Browns Builders Merchants Limited is the controller and responsib                      rsonal data

(collectively referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data protection co-ordinator who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including any
requests to exercise your legal rights,  please contact  our data protection co-ordinator using the
details set out below.

Contact details

Our full details are:

Full name of legal entity: Browns Builders Merchants Limited, a private limited company with
registered number 02478452

Data protection co-ordinator: Neal Myers Email address:

Postal address: 123 Old Nottingham Road, Derby, Derbyshire, DE1 3QQ

We hope that we can resolve any query or concern you raise about our use of your information. We
would appreciate the chance to deal with your concerns in the first instance. However, you also
have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the
UK supervisory authority for data protection issues (

Changes to the privacy notice and your duty to inform us of changes

This  version  was  last  updated  in  March  2019  and  historic  versions  can  be  obtained  by
contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.


Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous

We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together follows:

•           Identity Data includes first name, maiden name, last name, gender and date of birth.

•           Contact Data includes billing address, delivery address, email address and telephone

•           Financial   Data   includes   bank   account   and   payment   card   details,   and  
credit information.

•           Transaction Data includes details about payments to and from you and other details of
products you have purchased from us.

•           Technical Data includes internet protocol (IP) address, your login data, browser type
and  version,  time  zone  setting  and  location,  browser  plug-in  types  and  versions,
operating system and platform and other technology on the devices you use to access our website.


•           Profile Data includes purchases or orders made by you, your interests, preferences,
feedback and survey responses.

•           Usage  Data  includes  information  about  how  you  use  our  website,  products  and

•           Marketing  and  Communications  Data  includes  your  preferences  in  receiving
marketing from us and our third parties and your communication preferences.

If you are opening a credit account with us, we may require different kinds of personal data from
your directors and/or shareholders. This is so that we may perform reference checks on the owners
and people in charge of our customer. Click here to find out more about how we use your personal

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal 
data  in  law  as  this  data  does  not  directly  or  indirectly  reveal  your  identity.  For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific
website feature. However, if we combine or connect Aggregated Data with your personal data so that
it can directly or indirectly identify you, we treat the combined data as personal data which will
be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about 
your  race  or  ethnicity,  religious  or  philosophical  beliefs,  sex  life,  sexual 
orientation, political opinions, trade union membership, information about your health, and genetic
and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you
and you fail to provide that data when requested, we may not be able to perform the contract we
have or are trying to enter into with you (for example, to provide you with goods). In this case,
we may have to cancel an order you have placed with us but we will notify you if this is the case
at the time.


We use different methods to collect data from and about you including through:

•           Direct Interactions. You may give us your Identity, Contact and Financial Data by
filling in forms or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:

•           Register as an account holder;

•           Purchase products from us;

•           Subscribe to our newsletters;

•           Request marketing to be sent to you;

•           Participate in our competitions or promotions; or

•           Give us some feedback.

•           Automated technologies or interactions. As you interact with our website, we may
automatically  collect  Technical  Data  about  your  equipment,  browsing  actions  and patterns.
We collect this personal data by using cookies, server logs and other similar technologies. We may
also receive Technical Data about you if you visit other websites employing our cookies. Please
click here for further information.

•           Third parties or publicly available sources. We may receive personal data about you
from various third parties and public sources as set out below:

•           Identity, Contact and Financial Data from credit reference agencies such as Experian
based inside the UK and/or the EU;

•           Contact, Financial and Transaction Data from providers of technical, payment and
delivery services such as PayPal based outside of the UK and the EU;

•           Identity and Contact Data from publicly availably sources such as Companies House and
the Electoral Register based inside the UK and/or the EU.


We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

•           Where we need to perform the contract we are about to enter into or have entered into
with you;

•           Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests; or

•           Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your
personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than
in relation to:

•           Carrying out credit searches before registering you as a credit account holder;

•           Sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground
has been set out in the table below.

Purpose/Activity                    Type of data                 Lawful     basis    for   

including    basis    of    legitimate interest

To  register  you  as  a  new customer

(a)   Identity

(b)   Contact

Performance of a contract with you

To register to you as a new account holder

(a)   Identity

(b)   Contact

(c)   Financial

(a)   Performance  of  a contract  with you

(b)   Necessary   to   our   legitimate interests (for accounts purposes and  to  ensure  we 
allocate  a suitable credit limit to you)

To process and deliver your order including:

(a)   Manage        payments, fees and charges

(b)   Collect    and    recover money owed to us

(a)   Identity

(b)   Contact

(c)   Financial

(d)   Transaction

(e)   Marketing     and Communications

(a)   Performance  of  a  contract  with you

(b)   Necessary   for   our   legitimate interests  (to  recover  debts  due to us)

To manage our relationship with you which will include:

(a)   Notifying    you    about changes to our terms or privacy policy

(b)   Asking  you  to  leave  a review or take a survey

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Marketing     and Communications

(a)   Performance  of  a  contract  with you

(b)   Necessary   to   comply   with   a legal obligation

(c)   Necessary   for   our   legitimate interests  (to  keep  our  records updated   and   to  
study   how customers            use            our products/services)

To  administer  and  protect our     business     and     our website                 (including
troubleshooting,            data analysis,    testing,    system maintenance,          support,
reporting   and   hosting   of data)

(a)   Identity

(b)   Contact

(c)   Technical

(a)   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)   Necessary   to   comply   with   a legal obligation

To  deliver  relevant  website content and advertisements to   you   and   measure   or understand 

(a)   Identity

(b)   Contact

Necessary     for     our     legitimate interests  (to  study  how  customers use     our    
products/services,     to

effectiveness        of        the advertising we serve to you

(c)   Profile

(d)   Usage

(e)   Marketing     and Communications

(f)    Technical

develop them, to grow our business and to inform our marketing strategy)

To   use   data   analytics   to improve       our       website, products/services, marketing,    
        customer relationships                   and experiences

(a)   Technical

(b)   Usage

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)

To  make  suggestions  and recommendations    to    you about goods or services that may be of
interest to you

To           facilitate           the

procurement                  and organisation    of    supplies made   by   third   parties   to
process   and   deliver   your order

(a)   Identity

(b)   Contact

(c)   Technical

(d)   Usage

(e)   Profile

(a) Identity

(b) Contact

Necessary     for     our     legitimate interests        (to       develop       our
products/services    and    grow    our business)

Performance of a contract with you


We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. You can ask us to stop sending marketing messages at any time by
contacting us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us and, in each case, you have not opted out of receiving that

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.

Our newsletters are distributed using an External Third Party (as set out in the Glossary). When
you sign up to receive our newsletters we will require the following information:

•           Your name and address;

•           Your email address;

•           Your telephone number; and

•           The types of products you would like to hear about.

We will rely on your consent to provide you with the newsletters or updates you have requested and
retain your details on our subscriptions database.

Without your contact details, we will not be able to provide you with newsletters and updates.

Opting out

You  can  ask  us  or  third  parties  to  stop  sending  you  marketing  messages  at  any  time 
by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, warranty registration, product/service
experience or other transactions.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set
or access cookies. If you disable or refuse cookies, please note that some parts of our website may
become inaccessible or not function properly. For more information about the cookies we use, please
see our cookies policy at

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with
the original purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.


We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 4 above:

•           External Third Parties (as set out in the Glossary); and

•           Third parties to whom we may choose to sell, transfer, or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with

them.  If  a  change  happens  to  our  business,  then  the  new  owners  may  use  your personal
data in the same way as set out in this privacy notice.

We require  all  third  parties  to  respect  the security  of  your  personal  data  and  to treat
 it  in accordance with the law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.


Many  of  our  external  third  parties  are  based  outside  the  EEA  so  their  processing  of 
your personal data will involve a transfer of data outside the EEA.

Whenever  we  transfer  your  personal  data  out  of  the  EEA,  we  ensure  a  similar  degree 
of protection is afforded to it by ensuring at least one of the following safeguards is

•           We will only transfer your personal data to countries that have been deemed to provide
an adequate level of protection for personal data by the European Commission. For further  details,
 see European  Commission:  Adequacy  of  the  protection  of  personal data in non-EU countries.

•           Where we use certain service providers, we may use specific contracts approved by the 
European  Commission  which  give  personal  data  the  same  protection  it  has  in Europe.  For 
further  details,  see European  Commission:  Model  contracts  for  the transfer of personal data
to third countries.

•           Where we use providers based in the US, we may transfer data to them if they are part
of the Privacy Shield which requires them to provide similar protection to personal data shared
between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.

7.         DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed, such as the
implementation of appropriate security measures to protect our IT infrastructure. In addition, we
limit access to your personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on our instructions and
they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.


How long will you use my personal data for?

We  will  only  retain  your  personal  data  for  as  long  as  necessary  to  fulfil  the 
purposes  we collected  it  for,  including  for  the  purposes  of  satisfying  any  legal, 
accounting,  or  reporting requirements.

To  determine  the  appropriate retention  period for  personal  data,  we  consider the  amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data and whether
we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity,
Financial  and  Transaction  Data)  for  six  years  after  they  cease  being  customers  for  tax

In some circumstances you can ask us to delete your data: see request erasure below for further

In some circumstances we may anonymise your personal data (so that it can no longer be associated 
with  you)  for  research  or  statistical  purposes  in  which  case  we  may  use  this
information indefinitely without further notice to you.


Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please click on the links below to find out more about these rights:

•           Request access to your personal data

•           Request correction of your personal data

•           Request erasure of your personal data

•           Object to processing of your personal data

•           Request restriction of processing your personal data

•           Request transfer of your personal data

•           Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights).  However,  we  may  charge  a  reasonable  fee  if  your  request  is  clearly  unfounded,
repetitive  or  excessive.  Alternatively,  we  may  refuse to  comply  with  your  request  in 
these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.


Legitimate  Interest  means  the  interest  of  our  business  in  conducting  and  managing  our
business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and  negative)  and
 your  rights  before  we  process  your  personal  data  for  our  legitimate interests. We do not
use your personal data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by  law).  You  can  obtain 
further  information  about  how  we  assess  our  legitimate  interests against any potential
impact on you in respect of specific activities by contacting us.

Performance  of  Contract  means  processing  your  data  where  it  is  necessary  for  the
performance of a contract to which you are a party or to take steps at your request before entering
into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.


We employ other companies to perform functions on our behalf such as:

•           Service  providers  acting  as  processors  based  inside  and  outside  the  EEA. 
These services  may  include  fulfilling  orders  for  products,  providing  customer  relationship
management, marketing assistance and supporting our website and IT functionality.

Our service providers include:

•           Microsoft, for services such as Outlook; and

•           Mailchimp, who we use to distribute our newsletters.

These service providers may be supplied with or have access to your personal data solely for the
purpose of providing these services to us on our behalf. Browns Builders Merchants Limited is the
data controller and will remain accountable for your personal data.

•           Professional  advisers  acting  as  processors  or  joint  controllers  including 
lawyers, bankers,  auditors  and  insurers  based  inside  the  EEA  who  provide  consultancy,
banking, legal, insurance and accounting services.

•           HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom who require reporting of processing activities in certain


You have the right to:

•           Request access to your personal data (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal data we hold about you and to check
that we are lawfully processing it.

•           Request correction of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate data we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.

•           Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have  the 
right  to  ask  us  to  delete  or  remove  your  personal  data  where  you  have successfully
exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with local
law. Note, however, that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time of your request.

•           Object to  processing of  your  personal  data  where  we  are relying  on a 
legitimate interest (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel it impacts on
your fundamental rights and freedoms. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which override your rights and freedoms.

•           Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us to
establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to
erase it; (c) where you need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use it.

•           Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly used, 
machine-readable  format.  Note  that  this  right  only  applies  to  automated information which
you initially provided consent for us to use or where we used the information to perform a contract
with you.

•           Withdraw  consent  at  any  time  where  we  are relying  on consent  to  process  your
personal data. However, this will not affect the lawfulness of any processing carried out before
you withdraw your consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time you withdraw your

Browns Builders Merchants Limited

VAT No. GB 780620828