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Privacy Notice

The following information from Clever Retail (Online) Ltd is intended to give you an overview of how your data is processed by E.A. Carey and your rights under data protection law.

If anyone represents you in dealings with us or you provide us with information about other people that is relevant to the services we provide, such as family members or additional card-holders for example, this Privacy Notice also covers how we handle the personal data of those individuals. Please ensure that these individuals are made aware of this Privacy Notice.

1. Contact details of the person responsible for data protection at E.A. Carey

Data Manager
Clever Retail (Online) Ltd
The Old Sheephouse
Dunt Avenue, Hurst
Reading, Berkshire
RG10 0SY
help@E.A. Careyarey.co.uk

2. Which data is used by E.A. Carey?

E.A. Carey processes data that it receives from its business relationship with you. This includes, among other data, personal data, i.e. data that directly identifies you as a client (e.g. name, address, telephone number, etc.), or data which leads to this identification when used in connection with other information (e.g. customer number). In addition to data that E.A. Carey receives directly from you, it may also obtain and process data on you from sources available in the public domain (e.g. Internet, social media).

The following personal data is processed:

  • personal details (name, address and other contact data),
  • order data (e.g. product order),
  • data arising from the fulfilment of obligations (e.g. sales data in payment transactions),
  • advertising and sales data,
  • as well as data comparable with the above-mentioned criteria.

Special category data

E.A. Carey does not knowingly capture special category data and where this may be mentioned during the normal processing of our duties to customers (e.g. generic health conversation), it will not be recorded.

3. For what purpose and on what legal basis does E.A. Carey use your data?

a) For the fulfilment of contractual obligations

The processing of your data allows E.A. Carey to provide the services that you consent for us to provide. The purpose of the data processing is to ensure we are able to fulfil your retail requirements in an accurate and timely manner.

b) Within the context of weighing up interests

To protect its own legitimate interests or interests of third parties, E.A. Carey will also process your data for the following purposes:

  • preventing and investigating criminal acts,
  • testing and optimising processes for direct client contact,
  • recovery of fees and debts due to E.A. Carey,
  • assertion of legal claims and defence against any legal disputes,
  • measures for business management and the further development of services and products,
  • collection of personal data from sources available in the public domain for the purpose of client canvassing.


E.A. Carey would like to use your personal information to tell you about products and services that we think may be of interest to you. We believe that it is necessary for our legitimate interests; i.e. to develop our products and services and to grow our business.

You have the right at any time to ask us to stop sending you marketing messages. To do this please contact us using the contact details at the end of this notice.

4. Who can access your data?

Within E.A. Carey, access is only granted to those personnel who require your data for the fulfilment of E.A. Carey’s contractual and legal obligations (need-to-know principle). Service providers and vicarious agents appointed by E.A. Carey process your data for the same purpose. These may include companies in the areas order fulfilment, IT services, logistics, printing services, document storage, telecommunications, consultancy, as well as sales and marketing.

If E.A. Carey transmits data to external recipients, information on you may only be forwarded by E.A. Carey if this is a legal requirement, or if you have agreed to this.

5. Does E.A. Carey transmit the data abroad?

Where E.A. Carey operates outside the European Economic Area (EEA), for example Guernsey, it will ensure that those jurisdictions are considered by the European Commission to be an adequate jurisdiction for data protection purposes. Your data may be transmitted to entities in other countries if:

  • this is required for the execution of your orders, or
  • it is a statutory requirement

These data transfers are secured through corresponding guarantees of the recipients to ensure appropriate data protection.

6. How long will your data be stored?

E.A. Carey processes and keeps your data only for as long as is necessary to fulfil its order processing obligations to you.

If the data is no longer required for the fulfilment of orders, it will be deleted at regular intervals.

7. What are your rights under data protection law?

Under The Data Protection (Bailiwick of Guernsey) Law 2017 and equivalent legislation you have the following rights.

You can:

  • request access to your personal information which enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • request that this be corrected if it is incorrect;
  • request that this data be deleted if E.A. Carey is not permitted or does not have to store this data;
  • request that the processing of this data be restricted. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
  • object to the processing by E.A. Carey
    • if E.A. Carey only processes the data on the basis of its legitimate interests; in this case it will cease the processing unless this is outweighed by its own interests or it needs to process the data in order to exercise its rights, or
    • if the processing is carried out with a view to direct advertising;
  • request that your personal data which you have provided to E.A. Carey be transmitted to another party in a generally available, machine-readable, and standard format.

You also have a right to complain to the Data Protection Commissioner in your jurisdiction if you believe that E.A. Carey has brE.A. Careyhed the above rights or any other provision of The Data Protection (Bailiwick of Guernsey) Law 2017 or equivalent legislation. The Commissioner can be contacted on +44 (0)1481 742074 and its website, which includes details of how to make a complaint, is www.dataci.org

8. What data do you have to supply?

E.A. Carey requires you to provide the data necessary for the acceptance and execution of a business relationship and the fulfilment of the associated products and services. Unless it has this data, E.A. Carey is usually unable to implement of implement the relationship with you.

9. Is decision-making automated?

As a basic principle, E.A. Carey does not use fully automated decision-making for commencing and conducting the business relationship. If E.A. Carey does apply this procedure as an exception in individual cases, it will inform you separately if this is a statutory requirement.

10. Will your data be automatically processed?

In specific areas, E.A. Carey will process your data on a semi-automatic basis, the aim being to evaluate certain personal criteria (profiling), for example, in the following cases:

  • In order to combat criminal acts such as fraud, E.A. Carey conducts data assessments (e.g. in payment transactions). The aim of these measures is to protect you.
  • E.A. Carey uses assessment tools to provide you with interesting and appropriate information on its products. This enables it to carry out demand-based communication and advertising, including market and opinion research.

11. Where can you find the current privacy policy?

This privacy policy can be adapted at any time in accordance with the corresponding regulations. You can find the respective current version at www.E.A. Careyarey.co.uk.

12. How can you contact E.A. Carey?

If you have any questions about how your data is treated, E.A. Carey’s Data Manager will be happy to assist you.

specific notes in the use of our website

Please also click here to read specific notes about the use of our website.