Privacy Policy

Purpose of this privacy policy

This privacy policy gives you information on how we collect and process your personal data that you provide and also covers any interaction you may have either on the telephone or in person.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Our websites are intended for persons over the age of 16 and we do not knowingly collect data relating to children.

Controller

ASHI Group Limited trades as Anglian Home Improvements, Everest and Safestyle. We are the controller responsible for your personal data in relation to any Anglian Home Improvements, Everest or Safestyle data gathering systems/applications, such as our websites or Applications and when you enquire about, or purchase any of our products or services, or contact us pre
and/or post installation. A reference to “we”, “us” or “our” in this privacy policy is a reference to the ASHI Group Limited .

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer in the following ways:

Full name of legal entity: ASHI Group Limited

Email address: [email protected] [email protected] [email protected]

Postal address: FREEPOST NC1013, PO Box 65, Norwich, NR6 6BR

Telephone number: Anglian: 0800 988 9398 Everest: 0800 010 121 Safestyle: 0800 083 0107

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.

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

We keep our privacy policy under regular review. This version was last updated on 3rd July 2024.

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.

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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).

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

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. If you visit one of our showrooms, depots or offices, this will include CCTV footage which may be captured of you.
• Contact Data includes billing address, delivery address including delivery requirements and restrictions, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, device, make and model 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(s) or download and use our App.
• Profile Data includes your username and password if you’ve downloaded our App or created an account via our on-line shop, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website(s) or App, products and services
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

We may collect Special Categories of Personal Data about you if there is something we need to know in order to treat you with appropriate care and keep you safe when we visit your home, or deliver and install our products there. For example, you may have a health condition for which we can make reasonable adjustments to our sales and delivery process. We do not collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership 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 or services). In this case, we may have to cancel a product or service you have 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:
  • enquire about or purchase our products or services;
  • book an appointment
  • create an account on our online shop;
  • download and use our App;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
  • Or contact us by any other means
• Automated technologies or interactions. As you interact with our website(s) or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details:

Anglian Home Improvements
https://www.anglianhome.co.uk/legal/cookie-policy

Everest

https://www.everest.co.uk/legal/cookie-policy

Safestyle

https://www.safestyle-windows.co.uk/cookie-policy

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the UK; and
    • advertising networks;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity Data and other incidental personal data from housing associations, councils, new build suppliers, in relation to the installation of our products at the property.
• Identity and Contact Data from publicly available sources such as your publication website if you are a journalist.
• Identity and Contact Data which you make available when you contact us or mention us via our social media pages or write a review using Trustpilot or other relevant review website(s).
• Identity Profile and Contact Data from our affiliate partners.
• Identity and Contact Data from the Post Office’s National Change of Address Database, the National Deceased Register, the Telephone Preference Service, Mail Preference Service, our chosen supplier of personal data accuracy services (see Marketing and Data Accuracy).or any similar external data lists we may cross reference.

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 or take steps at your request before entering into such a contract 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. Where we need to comply with a legal obligation that we are subject to.
• Where we need to comply with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data however we may sometimes ask for your consent to receive certain marketing communications from us. You have the right to withdraw any consent you may give us at any time by contacting us.

Purposes for which we will use your personal data

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 on the following page.

Purposes for which we will use your personal data

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or register your interest in our products and services.	(a) Identity (b) Contact	Performance of a contract with you
To visit your property or arrange a remote consultation in order to provide you with a quote for our products or services	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to follow up on your interest and provide you with the information you need to decide whether you would like to purchase from us)
To process and deliver your order including:  (a) Manage payments, fees and changes (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communication	(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 may 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 (e) Marketing and Communication	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a questionnaire. survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website(s) (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 the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to 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 operate CCTV in our premises including showrooms, operational depots and offices	(a) Identity	Necessary for our legitimate interests (to ensure the safety of you and our people).
To make suggestions and recommendations to you about goods or services provided by us and other companies within our group that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) your consent where applicable (b) Necessary for our legitimate interests (to develop our products/services and grow our business)
To broker credit agreements for the purchase of our products with third party lenders	(a) Identity (b) Contact (c) Financial (d) Marketing and Communications	Necessary for our legitimate interests to assess applications for credit facilities.
To conduct customer research	(a) Identity (b) Contact (c) Transaction (d) Profile (e) Usage	Necessary for our legitimate interests (to use customer research to improve our products and
To display case studies and / or testimonials through any Anglian, Everest or Safestyle Marketing channels	(a) Usage	Your consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We regularly screen the personal data we hold about you against the Telephone Preference Service (TPS) and the Mail Preference Service (MPS), plus our own internal ‘Do Not Contact List’ to ensure that we remain permitted to send marketing communications. If you have given us your consent to send you certain marketing communications your consent to receive those communications overrides the information held on any screening services.

We do not share your personal data with third parties for marketing purposes. If this changes we will get your express opt-in consent before we share your personal data with any such third parties.

Opting out

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 you have not opted out of receiving that marketing.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us during business hours:

Call Anglian Home Improvements: 0800 988 9398
Email Anglian Home Improvements: [email protected]

Call Everest: 0800 010 121
Email Everest: [email protected]

Call Safestyle: 0800 083 0107
Email Safestyle: [email protected]

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.

Cookies

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(s) may become inaccessible or not function properly. For more information about the cookies we use, please see:

Anglian Home Improvements https://www.anglianhome.co.uk/legal/cookie-policy

Everest https://www.everest.co.uk/legal/cookie-policy

Safestyle https://www.safestyle-windows.co.uk/cookie-policy

Data accuracy

We continually strive to ensure the accuracy of the personal data you have provided, such as your contact details, by checking against external data lists such as the Post Office’s National Change of Address Database, the National Deceased Register, and Call Credit using a data accuracy service provider. This helps us to ensure that our records are fully up to date.

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 share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data on page 8 of this privacy policy.

• Service providers who provide IT and system administration services and services platforms.
• Service providers based in the UK to whom we may subcontract the delivery and installation of your product.
• Other companies within our group which provide goods and services which we understand you to be interested in.
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• Our finance partners who provide you with credit via ASHI Group as the credit broker.
• HM Revenue & Customs, regulators and other authorities based in the UK.
• 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 policy.
• Third parties to perform as measurement services on our behalf.

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.

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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

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. 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 reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will 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. 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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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 consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.

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 could 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.

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 could 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.