M&S CUSTOMER PRIVACY POLICY

Al-Futtaim Trading Company L.L.C trading as Marks and Spencer PLC or M&S, or any subsidiaries and affiliates of the Al-Futtaim Group (collectively “Al-Futtaim”, “we”, “our”, “us”) maintains this mobile application (the “App”). This includes all the App’s information, communication, software, scripting, photos, texts, videos, graphics, music, sounds, images, other materials and services (collectively ‘Content’). Our Content is provided as a form of convenience for its mobile visitors, customers, employees and the public (collectively “user”, “users”, “you”, “your”, “yours”).

OVERVIEW

Maintaining the security of your data is a priority at M&S, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. M&S is also dedicated to being transparent about what data we collect about you and how we use it.

This policy, which applies to personal data collected via the M&S App (the “App”) aimed at customers in Singapore whether, you use your mobile device or via online, provides you with information about:

  • how we use your data;
  • what personal data we collect;
  • how we ensure your privacy is maintained; and
  • your legal rights relating to your personal data.
  • HOW WE USE YOUR DATA

    General

    M&S (and trusted partners acting on our behalf) uses your personal data:
    • to provide goods and services to you;
    • to make a tailored app available to you;
    • to manage any registered account(s) that you hold with us;
    • to verify your identity;
    • for crime and fraud prevention, detection and related purposes;
    • with your consent, to contact you electronically about promotional offers and products and services which we think may interest you;
    • for market research purposes - to better understand your needs; and
    • to enable M&S to manage customer service interactions with you.
    Marketing

    Promotional communications

    M&S uses your personal data for electronic marketing purposes (with your consent) and may send you postal mail to update you on the latest M&S offers.

    If you have consented to receive marketing communications from us, your personal contact details and information about your transactions on this App will be shared by M&S with Al-Futtaim Group for marketing purposes and customer research and analysis.

    M&S and Al-Futtaim Group aim to update you about products & services which are of interest and relevance to you as an individual.

    Sharing data with third parties

    Our service providers and suppliers

    In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.

    M&S only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to M&S and to you, and for no other purposes.

    Other third parties

    Aside from our service providers, M&S will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.

    We may share your data with:

    • our carefully selected partners who provide ‘M&S’ branded products and services including Al-Futtaim Group, if we have your consent to do so;
    • credit reference agencies and payment card issuers (such as Visa and Mastercard) where necessary for card payments;
    • governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so under applicable law: -
    • to comply with our legal obligations;
    • to exercise our legal rights (for example in court cases);
    • for the prevention, detection, investigation of crime or prosecution of offenders; and
    • for the protection of our employees and customers.
    How long do we keep your data?

    We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years from the last active transaction date from your account.

  • WHAT PERSONAL DATA DO WE COLLECT?

    M&S may collect the following information about you:

    • your name, age/date of birth and gender;
    • your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
    • purchases and orders made by you;
    • your on-line browsing activities on M&S websites;
    • your password(s);
    • when you make a purchase or place an order with us, your payment card details;
    • your communication and marketing preferences;
    • your interests, preferences, feedback and survey responses;
    • your location;
    • your correspondence and communications with M&S; and
    • other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).

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

    This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an account on our App, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.

  • HOW TO REQUEST FOR DATA DELETION

    You have the right to request for the deletion of your personal data, particularly where we are no longer legally required to store them. To do this, please send an email to mands.sg.customerservice@alfuttaim.com.

  • HOW WE PROTECT YOUR DATA
    Our controls

    M&S is committed to keeping your personal data safe and secure.

    Our security measures include: -

    • encryption of data;
    • regular cyber security assessments of all service providers who may handle your personal data;
    • regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
    • daily penetration testing of systems;
    • security controls which protect the entire M&S IT infrastructure from external attack and unauthorised access; and
    • internal policies setting out our data security approach and training for employees.
  • WHAT YOU CAN DO TO HELP PROTECT YOUR DATA

    M&S will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from M&S asking you to do so, please ignore it and do not respond.

    If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.

    In addition, we recommend that you take the following security measures to enhance your online safety both in relation to M&S and more generally –

    • Keep your account passwords private. Remember, anybody who knows your password may access your account.
    • When creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password. You can do this accessing your account, tapping on ‘Personal details’ and then tapping on ‘Change password’.
    • Avoid using the same password for multiple online accounts.
  • YOUR RIGHTS

    You have the following rights:

    1. The right to ask for a copy of personal data that we hold about you (the right of access);
    2. The right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);
    3. The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);
    4. The right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object);
    5. The right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
    6. The right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).

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

  • LEGAL BASIS FOR USING DATA

    We are required to set out the legal basis for our ‘processing’ of personal data.

    Click here for further information

    Legal basis for M&S processing customer personal data

    General

    M&S collects and uses customers’ personal data because is it necessary for:

    • the pursuit of our legitimate interests (as set out below);
    • the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
    • complying with our legal obligations.

    In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email or text message.

    Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

    Our legitimate interests

    The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of M&S, including –

    • selling and supplying goods and services to our customers;
    • protecting customers, employees and other individuals and maintaining their safety, health and welfare;
    • promoting, marketing and advertising our products and services;
    • sending promotional communications which are relevant and tailored to individual customers (including administering the Sparks loyalty scheme);
    • understanding our customers’ behaviour, activities, preferences, and needs;
    • improving existing products and services and developing new products and services;
    • complying with our legal and regulatory obligations;
    • handling customer contacts, queries, complaints or disputes;
    • managing insurance claims by customers;
    • effectively handling any legal claims or regulatory enforcement actions taken against M&S; and
    • fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
  • CONTACT INFORMATION

    If you have any questions about how M&S uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:

    When contacting us, please remember to quote your name and contact details along with any M&S account number or correspondence reference you may have.