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Privacy Notice

Let's talk about privacy 

At Boots, we believe in making things easy for our customers. We know there’s nothing more offputting than the sight of a lot of boring small print, so we’ve written our Privacy Policy to make it clear, simple and easy to read.  

This policy explains how Boots uses your personal data, when you are using a Boots Photo Kiosk, Boots Photo App or the Boots Photo Website (“Boots Photo Services”).  

To find out how Boots uses your personal data when using other Boots services such as when you’re shopping on boots.com, having your eyes tested at Boots Opticians or having a prescription made up at your local Boots pharmacy please visit the privacy policy found on Boots.com.

Our promise to you 

Boots is committed to protecting your privacy. We believe in using your personal information to make things simpler and better for you. We’ll always keep your personal information safe and will never sell it to third parties. We’ll be clear and open with you about why we collect your personal information and how we use it. Where you have choices or rights, we’ll explain them to you and respect your wishes. We’ve written this Privacy Policy in plain English to tell you how and why we use your personal information. We hope you’ll find it clear and simple but if you have any concerns or questions please feel free to contact using the details found below. 

‘We’ or ‘Boots’ means companies within the Walgreens Boots Alliance Group, including subsidiaries, affiliates, joint ventures and franchises. We share your personal information among these companies in order to provide, and keep you informed about our products and services, to handle any complaints or queries, and to give you the best customer service we possibly can. 

The Boots Photo Services are brought to you by a third party, CEWE who are acting as Data

Processor on behalf of Boots. To find out more information about CEWE please visit their website. 

1.  How we process your personal data 

Collecting information about you 

Please see below examples of personal data collected from you via the Boots Photo Services;

 

Identity Data 

First name, last name, title and date of birth.

Contact Data 

Billing address, delivery address, email address (personal and/or business) and landline and mobile telephone numbers (personal and/or business).

Image Data  

Photographic images received from you and/or uploaded to one of our services by you, and any images captured as a result of our use of CCTV in store.

Financial Data 

Bank account and payment card details, Boots does not have access to this data, however CEWE will process this data on our behalf. 

Transaction Data 

Details about payments to and from you and details of products and services you have purchased

Technical Data 

Internet protocol (IP) address, your 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 Boots photo services. 

Profile Data  

Your username, purchases or orders made by you, your interests, preferences, feedback and survey responses (your password is encrypted and therefore not seen by Boots or CEWE staff).

Usage Data 

Information about how you use our website, products and services.

Marketing and Communications Data 

Your preferences in receiving marketing from Boots Photo Services

 

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data as this data does 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 notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health 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.

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 Identity, Contact information and Images, by filling in forms, using any of our Boots Photo Services or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our photographic products;
  • use one of our Boots Photo Services
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.

Automated technologies or interactions. As you interact with the Boots Photo 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. Please see our cookie policy for further details. We segment our customer data based on purchase history to provide the best possible experience.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • analytics providers such as Google Analytics/Adobe Analytics based both inside AND outside the EU.
  • advertising networks such as Google Display Network based both inside AND outside the EU.
  • search information providers such as Google based both inside AND outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Customer Service Support, Delivery Networks and Payment Gateway Providers based both inside AND outside the EU.

For details on any of the third parties, please contact us using the contact details provided below.

2.  How we use your personal data

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 a contract, we are about to enter into or have entered into with you to provide you with photo services.
  • 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 or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or post. You have the right to withdraw consent to marketing at any time as referred to further under the Marketing paragraph below.

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 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.

We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. If you need details about the specific legal basis, please contact us using the details provided. 

 

Purpose/Activity

Type of data

Lawful basis for processing  

To register you as a new customer and process any enquiries you may have.

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Keep you informed as to the progress of your order and dispatch information

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and

Communications

(f) Image

(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 will 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

(d) Marketing and

Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our 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 survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and

Communications

(a) Performance of a contract with you

(b) 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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Image

(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, for the security of our premises and staff)

(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 make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To correspond with you and discuss potential contractual arrangements for the supply of goods and/or services

(a) Identity

(b) Contact

Necessary for our legitimate interests (to develop our products and grow our business)

If you choose to use your Advantage Card when purchasing via a Boots Photo Service, please visit Boots.com to find out more information on how your personal data is processed via the Advantage Card loyalty programme.  

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, contact us using the details provided.

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.

3.  Keeping in touch  

We strive to provide our customers with choices regarding certain personal data uses, particularly around marketing and advertising we send via email and post. We have established a privacy centre within the My Account area on the website where you can view and make certain decisions about your personal data. Any changes to your account area will be communicated to you.

Promotional offers from Boots Photo Services

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 opted in to receive marketing communications.

Please note, your marketing preferences for Boots Photo Service are independent of other Boots services, therefore if you opt in to receive marketing from Boots Photo Services this will not opt you in to receive marketing from other Boots services such as the Advantage Card. 

Opting out

You can ask us to stop sending you marketing messages at any time by logging into the Boots Photo website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you at any time.

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 purchase, warranty registration, product experience or other transactions.

Please be aware that as our marketing campaigns are prepared well in advance, you may still receive material by post for up to two months, and by e-mail or text for up to 28 days after updating your preferences. 

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookies page .

Third-party links

Boots Photo Services 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 the Boots photo website, kiosk or app, we encourage you to read the privacy notice of every website you visit.

4.  Sharing your personal data

We share your personal information with companies that provide services on our behalf. We always ensure these companies give your information the same level of care and security we do.  If your information is to be sent outside of the UK or EEA (European Economic Area), we make sure it’ll be subject to standards of protection and security that are as high as those Boots uses here in the UK. 

Examples of the functions that may be carried out by external companies: 

  • Account set up and photo orders
  • Mailing houses and printers
  • Online and social media advertising
  • Delivery services such as couriers
  • Market research
  • Manufacturers or suppliers
  • Payment providers
  • Content providers, competitions,
  • Fraud and money laundering checks
  • IT services & support inclusive of web hosting, data storage, data cleansing, content providers
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

5.  International transfers

If your information is to be sent outside of the UK or EEA (European Economic Area), we make sure it’ll be subject to standards of protection and security that are as high as those Boots uses here in the UK. 

We’ll always conduct a full review of our suppliers’ processes and procedures including storage solutions for our data. To ensure adequacy when sending your data outside of the UK and EEA, we put in place contracts based on the Standard EU Model Contract Clauses to guarantee adequacy, we also use alternative safeguards where Standard EU Model Contract Clauses are not suitable

6.  Data security

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.

7.  Data retention

How long will you use my personal data for?

We will only 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.

Image data received as a result of new customer orders are stored for as long as you remain an active customer. If you become inactive i.e. you have not logged into to your Boots Photo account in the last 12months your images will be deleted. We will of course email to let you know and to give you plenty of notice. .

Image data captured by our CCTV cameras within a Boots store is held for no more than 30 days.

By law we have to keep basic information about our customers who have ordered products via Boots and CEWE (including Contact, Identity, Financial and Transaction Data) for tax purposes. Any additional customer data is deleted 36 months following the date of the last completed order with us.

In some circumstances we may 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.

8.  Staying in control of your information: Your rights 

We respect the fact that your personal information is your information, and we’ll make it easy for you to update or change your personal details or marketing permissions. Please help us to help you by letting us know if your contact details change, or if you spot any errors in the information we hold about you. 

 

What information am I entitled to? 

Your data rights are explained below, all of which are free of charge and should be concluded within a 30-day time frame. We may require you to provide identification in order to fulfil your request. 

Access

You have a right to obtain a copy of all the information that Boots holds about you, such as personal details, correspondence, marketing preferences, consent information, complaints, queries and Advantage Card history.

Portability

You can request that Boots moves your data to another service provider. This is not an automatic right, this depends on the type of data that Boots holds abouuutt you and the reason Boots process the data.

Processing

You have a right to request that Boots stop certain data processing activities that involve your personal data. This isn’t an automatic right, what Boots are able to do will depend on the type of data that Boots hold about you and why

Deletion

You have a right to request that Boots deletes your personal data it holds. This isn’t an automatic right, what Boots are able to delete will depend on the type of data and the reason for processing.  

CCTV  

 

In our stores, we use video and, in some places, audio recording to prevent and detect crime and anti-social behaviour. Where we do this we display clear signage, comply with the Information Commissioner’s Surveillance Camera Code of Conduct, and have internal processes in place to minimise the impact on your privacy.   

If you require access to CCTV footage, we’ll ask the date and approximate time of the incident you wish to view and as much detail as you can to help us locate the correct footage. 

 

CCTV is held for a 30-day period. We’ll do our best to help, but there are situations in which we may be unable to make CCTV footage available to you, such as where the incident occurred some time ago or if we believe taallowing you to view it would breach someone else’s privacy.  

 

Technologies associated with our CCTV systems will be used for the purpose of collecting non-identifiable analytical data e.g. to understand how long our customers wait in queues when making a purchase or using services within our stores. You cannot be identified by the use of these technologies.  

Social Media

 

If you raise a query or a complaint through Boots’ social media pages, we will of course have a record of your user name. This is used only to enable us to correspond with you and resolve the matter you’ve raised. 

 

9.  About this Policy

If the arrangement to operate Boots Photo Services via CEWE is terminated, we may transfer your personal information to a third-party ecommerce retailer or service provider acting on Boots Photo Services in accordance with data protection laws. The legal basis on which we process your information in these circumstances is Boots Photo Services legitimate interest to ensure that the Boots Photo online business can be continued by the relevant third party. You will be informed of this and have the opportunity to opt out prior to the data being transferred. If you object to our use of personal information in this way, the relevant business may not be able to continue to provide the Services to you.

 

Who to contact

For all questions relating to this policy please contact bootsphoto@cewe.co.uk or 01926 463 605. 

Your right to complain to the ICO 

Although we hope it never comes to this, you do have the right to complain to the Information

Commissioners Office (ICO) about any of Boots processing activities at casework@ico.org.uk 

Changes to our business 

If ownership of all or part of our business changes, or we undergo a reorganisation (including a merger or transfer between Walgreens Boots Alliance companies), we’ll transfer your personal information to the new owner or successor company, so we can continue to provide the services. 

Changes to this Privacy Policy 

This Privacy Policy was updated in March 2020.  We may update it from time to time, so we recommend that you check back here occasionally.  If we make changes we think may affect you significantly, particularly if they could have an impact on the choices you have made or your marketing preferences, we’ll provide you with a prominent notice.