Introduction

In our mission to make commerce better for everyone at homimprove, we collect and use information about you, our

• merchants using homimprove to power your business
• customers who shop at a homimprove powered business
• partners who refer potential entrepreneurs to homimprove, or help merchants operate or improve their homimprove powered business
• users of homimprove Customer Portal
• visitors to homimprove’s website, or anyone contacting homimprove support

This Privacy Policy will help you better understand how we collect, use, and share your personal information. If we change our privacy practices, we may update this privacy policy. If any changes are significant, we will let you know (for example, through the homimprove admin or by email).

Our values

Trust is the foundation of the homimprove platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy.

Your information belongs to you

We carefully analyse what types of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our products, our engineers work closely with our privacy and security teams to build with privacy in mind. In all of this work our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.

We protect your information from others

If a third party requests your personal information, we will refuse to share it unless you give us permission or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden.

We help merchants and partners meet their privacy obligations

Many of the merchants and partners using homimprove do not have the benefit of a dedicated privacy team, and it is important to us to help them meet their privacy obligations. To do this, we try to build our products and services so they can easily be used in a privacy-friendly way. We also respond to privacy-related questions we receive.

Why we process your information

We generally process your information when we need to do so to fulfil a contractual obligation (for example, to process your subscription payments to use the homimprove platform), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). Laws in the United Kingdom (“UK”) call these reasons “legitimate interests.” These “legitimate interests” include:

• preventing risk and fraud
• answering questions or providing other types of support
• providing and improving our products and services
• providing reporting and analytics
• testing out features or additional services
• assisting with marketing, advertising, or other communications

We only process personal information for these “legitimate interests” after considering the potential risks to your privacy and balancing any risks with certain measures — for example, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

We may also process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where you direct us to transfer information to a third party, where we receive your data from a third party is sourced and it already comes with consent or where we are required by law to ask for your consent (including in the context of some of our sales and marketing activities). At any time, you have a right to withdraw your consent by changing your communication choices, opting out from our communications or by contacting us.

Your rights over your information

We believe you should be able to access and control your personal information no matter where you live. Depending on how you use homimprove, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information. We will not charge you more or provide you with a different level of service if you exercise any of these rights. Please note that a number of these rights apply only in certain circumstances, and all of these rights may be limited by law.

If you buy something from or otherwise provide your information to a homimprove powered store and wish to exercise these rights over information about your purchase or interaction, you need to directly contact the merchant you interacted with. We are a processor and process information on their behalf. We will of course help our merchants to fulfil these requests to the extent required by law, such as by giving them the tools to do so and by answering their questions.

If you are a merchant, partner, homimprove Customer Portal user, homimprove employee, website visitor or other individual that homimprove has a direct relationship with, please submit your data subject request through our online portal. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may use a third party to collect and verify identification documents.

If you are not happy with our response to a request, you can contact us to resolve the issue.

Finally, because there is no common understanding about what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.

How long do we retain your information

We will retain your personal data only for as long as necessary to fulfil the purposes for which we have collected it. To determine the appropriate retention period, we consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorized 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 will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our policies. If you stop using our services or if you delete your account with us, we will delete your information or store your information in an aggregated and anonymised format.