Funky Pigeon

Privacy Notice

Funky Pigeon respects your privacy and is committed to protecting your personal data when you interact with us or visit our website. This Privacy Notice will inform you how we process your personal data and how you can exercise your privacy rights.

Contact Us

Funky Pigeon is the Data Controller and part of the WHSmith PLC group of companies (https://www.whsmithplc.co.uk/).

Address: Funky Pigeon, County Gates, Ashton Road, Bristol, BS3 2JH

Data Protection Officer: data.privacy@whsmith.co.uk

We are registered with the United Kingdom Information Commissioner’s Office and the Data Protection Commission of Ireland.

Please see the My Funky Rewards Privacy Notice for more information regarding the processing of your data when using My Funky Rewards.

Purpose for Which We Will Use Your Personal Data

In most instances we will process your personal data to respond to your purchase or enquiry about our products or services, including:

• To register you as a new customer and process and deliver your order(s)

• To managing payments, fees and charges and collect money owed to us

• To manage our relationship with you including dealing with enquiries and complaints

• To request feedback on our service and products through surveys and reviews

• To inform you about important new updates/services and changes to existing services

• To offers prize draws and competitions

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

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

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

• With your consent, send our newsletters and other promotional updates

• To send reminders if you abandon (exit the website) after a search, product view, or do not complete your order

• To verify your age when you purchase a product with age restrictions associated to it e.g. alcohol. In order to do this, your data will be shared with GBG plc, who may use the following systems to verify your identity: UK Edited Electoral Roll, UK Credit Bureau, UK Credit Header Database, UK Births Registry Database & UK National Identity Register. Please refer to our Terms and Conditions for information relating to age restriction when creating a Funky Pigeon account.

How is Your Personal Data Collected?

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

Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes information you provide when you purchase any of our products or services, create an account on our website, subscribe to our newsletters or other publications, enter a competition or provided 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 and other similar technologies. When you first visit our website, you will be given the opportunity to consent to non-essential cookies. You can update your preferences at any time.

Information provided by third parties. We receive age verification information from GBG plc and delivery confirmation from our contracted delivery partners.

Data We Collect About You

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 data).

When you complete an online form, register or shop with us online, we may process your personal data including your name, date of birth, billing/delivery address, e-mail address and telephone number. We may also collect and retain information about your interactions with us either online or through our contact centres so that we can process your transactions and deal with any future queries.

We process aggregated data such as statistical or demographic data for the purpose of understanding our customers and their preferences.

We do not collect any Special Categories of Personal Data or information about criminal convictions and offences.

Legal Basis for Processing

In most instances our legal basis for processing your data relates to our contractual obligations in respect of your order or enquiry about an order.

When you provide the personal data of third-party recipients such as photographs and address details for delivery purposes, we process the information to meet our contractual obligation to provide the product and delivery service. You should ensure that third parties are aware that you have provided their details to us.

Where it is necessary for our legitimate interests (or those of a third party), we carry out balancing tests and risk assessments to protect your fundamental rights.

We also process personal data to meet our legal obligations e.g. VAT records.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 via our dedicated Contact page or by emailing us at wecare@funkypigeon.com; updating your preferences on your 'My Account' section of the website; by 'opting out' of marketing communications in any marketing e-mail sent to you or by following the instructions in any SMS we send. Opting out of marketing communications will not affect necessary communications with you in connection with your order.

When collecting your personal data, we will always make clear which data is necessary in connection with a particular contractual or legal requirement. We may process your personal data without your knowledge or consent (for example, in relation to fraud management or to assist with investigations by the police or other regulatory bodies) where required or permitted by law.

Data Sharing

To enable us to meet our contractual and legal obligations we share data with third parties, including:

• GBG plc for the purpose of age verification https://www.gbgplc.com/en/legal-and-regulatory/privacy-policy/

• WHSmith group entities, details of which can be found in our Annual Reports

• Courier and delivery service providers to manage your order (Royal Mail https://www.royalmail.com/privacy-notice, Yodel https://www.yodel.co.uk/privacy-cookies-policy, DHL https://www.dhl.com/gb-en/home/footer/privacy-notice.html, DPD https://www.dpdlocal.co.uk/dpd-local-dpo-privacy-notice.jsp, Evri https://www.evri.com/privacy-policy)

• Payment processing providers (PayPal Braintree https://www.paypal.com/us/legalhub/privacy-full, Revolut https://www.revolut.com/privacy-policy/, Apple Pay ( https://www.apple.com/uk/privacy/, Google Pay https://policies.google.com/privacy, DNA Pay By Bank App https://dnapayments.com/page/privacy-policy, Klarna https://www.klarna.com/uk/privacy-and-security/, Clearpay https://www.clearpay.co.uk/en-GB/applicant-privacy

• We use a variety of printing partners for fulfilling and despatching your order

• If we expand, reduce or sell Funky Pigeon and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party and you will be notified of the change.

• For the purposes of our review service, a specific Trustpilot email address is added using 'Bcc' function to all of Funky Pigeon's order confirmation emails or similar - please see T&Cs for full details.

• Marketing companies to show you products, special offers or services, from Funky Pigeon that might interest you while you are browsing the internet.

• Data insight companies to ensure your details are up to date and accurate.

We require all third-party service providers to undergo a due diligence process to ensure that they meet our required standards for data security and data compliance. We ensure that data processing or data sharing agreements are in place which set out our expectations and the obligations of the service providers.

My Funky Rewards

My Funky Rewards is an online cashback programme operated by Funky Pigeon and managed on our behalf by Webloyalty International Sarl, a third party entity outside the WHSmith/Funky Pigeon group. You can find their privacy policy here: https://www.myfunkyrewards.com/privacy-policy

Your Rights

Data protection legislation provides individual rights in respect of your personal data, these include:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 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.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. If we have a legal or other obligation requiring us to retain the data, we will inform you.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You have the right to withdraw consent at any time where we are relying on consent to process your personal data.

If you make a request, we have one month to respond to you, if your request is complex or you have made a number of requests, we might require additional time (up to an additional two months). In this case, we will notify you within one month of the request.

We may request identity information for security purposes. We may also contact you to request further information or clarification to speed up our response.

Please contact us at data.privacy@whsmith.co.uk if you wish to make a request.

To exercise your rights, please contact our Customer Happiness team via our contact form.

International Data Transfers

Some of our service providers are located outside of the EEA and UK and we ensure that our contracts with these suppliers include appropriate data transfer safeguards such as the EU Standard Contractual Clauses and the UK Addendum.

Data Security

We have appropriate organisational and technical measures in place to ensure the security of your personal data. We have procedures in place 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.

Data Retention

We 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. We generally anonymise customer data 4 years from the last order or interaction with us.

In some circumstances we may anonymise your personal for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If You Fail To Provide Your 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 or services). In this case, we may have to cancel a product or service order, but we will notify you if this is the case at the time.

Marketing

We may send you marketing about our own goods and services if either you have opted in to receive our marketing messages, or you have previously bought or enquired about similar goods or services from us and you have not opted out from receiving our marketing messages.

You can unsubscribe from all our marketing material at any time by clicking the 'unsubscribe' link in any marketing email we send, updating your 'My Account' section on our website, or using our preference centre. You can also contact us via our contact form at any point to opt out of any or all marketing communications.

Off Site Marketing

Whilst browsing other websites you may see Funky Pigeon promotional messages, these will be displayed based on cookies placed during your recent visit to our website. Please see our Cookie Notice for more detail. We may share your data (which may include email address, name, address and your purchase history) with social media platforms (for example Meta) and Google, in order to serve marketing to you. You can opt-out of this data sharing by contacting our Data Protection Officer: data.privacy@whsmith.co.uk

Third Party Marketing

You are in control of any information we share with third parties for marketing purposes. As you go through our checkout or account creation processes you will be asked to advise us which contacts you wish to receive. If you have opted in to receive marketing, you can opt out of these marketing communications at any time by contacting us or by unsubscribing from marketing communications in any e-mail sent to you.

Third Party Links

Clicking on links to third-party websites, plug-ins and applications contained within this website, or enabling those connections, may allow third parties to collect or share data about you. We do not control these third-party websites. When you leave our website, we encourage you to read the privacy notice of every website you visit

Cookies

When you visit our website you will be offered a choice regarding the loading of cookies. Our preference centre can be accessed at any time through the Cookie Setting section to change your preferences. Please note that non-essential cookies are required for the functioning of our website to process your order, or when communicating with us. More information can be found in our Cookie Notice.

How To Complain

Data Protection Officer

data.privacy@whsmith.co.uk

WHSmith, Greenbridge Road, Swindon SN3 3LD

If you are not satisfied with the response you have received, you have the right to raise a complaint with the regulator:

UK and Rest of the World

United Kingdom Information Commissioner's Office

http://www.ico.org.uk/concerns

Helpline number: 0303 123 1113

EEA

Data Protection Commission of Ireland

https://dataprotection.ie/en/contact/how-contact-us

Helpline number: (01) 765 01 00 and 1800 437 737

General

It is likely that we will need to update this Privacy Notice from time to time, the version number and last update date will be noted here.