Effective Date: 20 May 2018 (v.2)
At Interflora, your privacy is very important to us and we want to assure you that we take the confidentiality and security of your personal data very seriously. Interflora refers to Interflora British Unit, a company registered in England.
2. What personal data do we collect?
We collect personal data from you whenever you interact with our Websites, including when you make purchases, when you browse our Websites, when you use our services or when you sign up to receive any of our services. When providing personal data to us through a form, we indicate which personal data is optional. Please note that, when collection of personal data is required or necessary either as needed for us to fulfil your order or based on legal obligation and you elect not to provide the personal data, we may not be able to accept or fulfil your order.
The types of personal data that we will collect, store, maintain or process includes the following. We provide further details regarding the use of the personal data in Clause 8.
Personal data you provide when you purchase from us
Additional Personal Data provided through the “My Account” feature
Additional Personal Data obtained when you use our Websites
Additional Personal Data obtained through contact with us
Our Websites are not intended for use by persons under the age of 18 and our terms and conditions require that a person be 18 or older when placing an order with us. If you believe we have collected personal data from a person under the age of 18, please notify us at the information provided in Clause 14.
3. How we use the personal data we collect from you?
We will use your personal data for the following purposes:
To fulfil your order:
For customer care purposes:
NOTE: Please note that you will receive communications with respect to fulfilling your order or for customer care purposes even if you opt out of receiving marketing communications.
For marketing purposes:
For marketing through third parties:
If you use our Websites, then you may receive personalised advertisements of our products and services when browsing other Websites using the same computer or device you used to view our Websites. This marketing is enabled through the cookies collecting data of your online browsing behaviour. These cookies are operated either by Interflora or by a third party and the advertisements are provided through a third party. Details of our third party providers are available within Clause 9 of this policy.
For internal business purposes:
We will use any of the personal data collected to help us to understand how many people visit our Websites, how well the Websites are working and to consider any improvements we may need to make to the Websites to improve your online experience. It also helps us determine what products and services you are interested in and what you or other customers might wish to purchase from us in future.
More specifically, we may use your personal data for the following internal business purposes:
4. When may you opt out of marketing communications?
You have the right to opt out of receiving direct marketing communications at any time. We will address your opt out request as soon as possible, but no longer than one month from the date we receive your request.
You may opt out of marketing communications or change your preferences with respect to marketing communications by:
6. How do we protect your personal data?
We are committed to protecting and respecting your privacy rights, and to ensuring that your personal data is safe and secure.
We use administrative, organisational, technical and physical safeguards to protect personal data. Our security controls are designed to protect your personal data from unauthorised alteration, access, disclosure, and use. We regularly test our Websites, data centres, systems, and other assets for security vulnerabilities. In addition, at a minimum, our safeguards involve appropriate technical and organisational measures including, but not limited to, encryption services, review of our data collection, storage and processing practices (including physical security measures, to guard against unauthorised access to systems), scenario planning and crisis management protocols to ensure we are able to respond to cyber security attacks and data security incidents, regular penetration testing of systems, security controls to protect our IT infrastructure from external attack and unauthorised access, and internal policies setting out our data security approach and training for employees.
Interflora handles payment card data in a manner consistent with the Payment Card Industry Data Security Standard (PCI-DSS).
7. What can you do to protect your personal data?
We will never ask you to confirm any bank account or credit card details in writing or via email. If you receive an email or any other written communication claiming to be from us, asking you to provide this data, please ignore it and do not respond.
If you are using a computing device in a public location, you should always log out and close the website browser when you have finished your online session.
If you create an account with us, you must keep your password private and avoid using the same password for multiple online accounts. Any password created should be at least 8 characters long and must include at least one upper case letter, one lower case letter and one symbol. We recommend regularly changing your password, which you can do within your account.
8. Our lawful basis for processing personal data
Interflora relies on different lawful basis for processing personal data. In some cases, more than one lawful basis may apply with respect to the same personal data.
Contract: We collect and process personal data in order to fulfil the order you place with us, and in accordance with our contract with you to fulfil your order. Such personal data includes the items detailed in Clause 3 under the title “To fulfil your order”.
Legitimate Interest: We collect and process personal data for our legitimate interests in fulfilling and processing your order, any customer care issues, to conduct research, to send email and direct marketing to you, handling legal claims, and for fraud identification and prevention checks. Such personal data includes the items detailed in Clause 3 under the title “For customer care purposes”, “For marketing purposes”, “For marketing through third parties” and “For internal business purposes”. With respect to any direct marketing we provide on the basis of a legitimate interest, you can unsubscribe as described in Clause 4.
Legal Obligations: Interflora is required to comply with applicable laws, rules and regulations as well as industry standards and orders by courts with jurisdiction over Interflora. In doing so, we may collect and retain personal data. For example, Interflora creates and maintains records of your orders to maintain the tax and accounting records required by applicable laws, and to share such records with the tax authorities as and when required.
9. When might we share your personal data with third parties?
We will share your personal data with certain third parties in order to fulfil and process your order, enable us to perform our contract to provide your purchase to you, provide our Websites and to provide you with marketing. The following is a list of types of third parties that may receive your personal data. Our third party providers are required to handle your personal data in accordance with appropriate data protection and security controls.
In addition to the reasons identified above, we may provide your personal data to third parties in the following circumstances:
10. How long do we keep your personal data?
We will only retain your personal data for the purposes set out in this policy and for as long as we have a legal or business requirement to do so. Different retention periods apply for different types of personal data, however, the longest we will normally hold any personal data is 7 years after the last contact with such person or purchase by such person. The time period for retention will depend on applicable laws, rules or regulations that we are required to follow, whether there is an ongoing request or query or other type of legal claim or dispute, the type of information we are holding and whether we are asked by you or a regulatory authority to keep the personal data.
11. When might we transfer your personal data abroad?
Your personal data may be sent outside the European Economic Area (EEA), as we share some personal data with our parent company FTD, certain third party providers for the purpose of: (a) fulfilling orders placed for national and international delivery by you, (b) customer care, and (c) as otherwise outlined in Clause 9.
Consequently, personal data may be processed in what are considered “third countries”. It is important to understand that “third countries” are not automatically deemed by the European Commission to have adequate legal protections for personal data or individual data subject rights. We have implemented appropriate technical and organisational measures and adequate safeguards to protect personal data by entering into standard contractual clauses with data recipients in such “third countries”. We are committed to continuously developing and improving the measures we already have in place.
Some of the organisations that we share personal data with may process it overseas. If any disclosures of personal data mean that your personal data will be transferred outside the European Economic Area, we will only make that transfer if: (a) the country to which the personal data is to be transferred ensures an adequate level of protection for personal data; (b) we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract; (c) the transfer is necessary for one of the reasons specified in Clause 8, such as fulfilment of an international order under the contract between us and you; or (d) you consent to the transfer.
12. Your rights to access your data and rectify any inaccuracies in your personal data
We fully respect that your personal data is owned by you and that you have certain rights with respect to the personal data. Our goal is to respect your rights. Please understand that we may have certain obligations to maintain personal data records despite your requests to exercise the following rights, such as for legal and accounting purposes. We ask that you read these rights carefully.
13. Your additional rights with respect to your personal data
You may have the following additional rights, detailed below:
Please note that if we erase all information about you and you make a future purchase or otherwise become a future customer, then we will not be aware of your prior requests or objections.
In respect of the additional rights outlined above, we request that you contact us via the Contact Details shown in Clause 14 below and we will provide you with additional information regarding your rights in connection with your specific request.
14. Contact details
We have appointed a Data Protection Officer whose role is to inform and advise us about and to ensure that we remain compliant with data protection laws. The Data Protection Officer should be your first point of contact if you have any queries or concerns about personal data. Our Data Protection Officer can be contacted at:
Data Protection Officer
15. Updates to this policy
We may use technology to track the patterns of behaviour of registered and non-registered visitors to our site. This can include using a "cookie" which is a small file stored on your browser. The information collected in this way can be used to identify you unless you modify your browser to prevent this happening - guidance for which is set out below. We also aggregate this data to perform statistical analyses of the characteristics and behaviour of visitors to our Websites. Cookies are also used as a further means of ensuring private and secure purchase sessions are operated within the Websites.
We may use third party advertising companies to serve advertisements on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. Your browser can be modified to not accept cookies - guidance for which is provided in the paragraph below.
You have the ability to accept or decline cookies by modifying the settings in your browser (for example, using Internet Explorer select 'internet options' from the 'tools' menu, then click 'security', followed by 'custom level' and select 'disable cookies'). However, you may not be able to use all the interactive features of our Websites if cookies are disabled. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.