CONTENTS OF PRIVACY POLICY
- Introduction
- What is Comfort Click Ltd?
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- Combining your data for personalised direct marketing
- How do we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Any questions?
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1. Introduction
Our Privacy Policy sets out the kinds of personal information we might collect when you interact with us. We'll also explain how we store your data, how it's handled, and the steps we take to keep it secure.
We understand there's a fair bit of detail here, but we believe it's important you're fully aware of your rights and how Comfort Click looks after your information. You'll also find details on how we may link data across our websites to get a better understanding of your needs.
We hope the information below clears up any questions you might have. If there's anything more specific you'd like to know, please don't hesitate to get in touch – we're always happy to help.
Our products are intended for adults aged 18 and over.
From time to time, we may need to make updates to this Privacy Policy. Feel free to check back here whenever you like to see the latest changes and improvements.
While you're using any of Comfort Click's websites, Comfort Click Ltd acts as the data controller.
2. What is Comfort Click Ltd?
We refer to Comfort Click Ltd, or 'Comfort Click', as an umbrella structure encompassing a few connected businesses.
This includes companies that share owners with Comfort Click and run a similar business model to support the rest of the group, i.e., Click Leaf Ltd and Wisby Ltd. So, when we reference 'Comfort Click', we include all of these companies.
For ease of reading, when we refer to 'we' or 'us', we mean Comfort Click and all its associated brands.
3. Explaining the legal bases we rely on
The law on data protection sets out several grounds on which a company may obtain, collect and process your personal data, including:
Consent
Sometimes, we may collect and process your data with your permission.
For example, when you tick a box to receive our email newsletters. Whenever we gather your personal data, we'll clearly explain which information is needed for each specific service.
Contractual Obligations
In certain circumstances, we need your personal data to fulfil our contractual responsibilities.
For instance, if you order an item for home delivery, we'll collect your address details so we can send your purchase on its way, passing them to our courier, postal service or fulfilment partner.
Legal Compliance
Where the law requires, we may have to collect and process your data.
For example, if someone is involved in fraud or other criminal activity affecting Comfort Click, we can share their details with the appropriate authorities, relying on our legitimate interest.
Legitimate Interest
In certain situations, we use your data to further our legitimate interests in running the business, provided this doesn't unduly affect your rights or freedoms.
For example, we may use your purchase history to send you personalised offers. We'll send you direct marketing emails if you shop with us and opt out of our emails; this is known as a 'soft opt-in'.
Occasionally, we'll analyse the combined shopping habits of many customers to spot trends, help us meet demand and decide which new products to develop or stock.
With your consent or under that 'soft opt-in' when you with us and do not choose to opt out from receiving our emails, we'll use your details, preferences and transaction history to keep you informed via email, our websites, SMS or phone about special offers, discounts, promotions, competitions and new products we think you'll like.
The law we apply is English law.
4. When do we collect your personal data?
Whenever:
- You visit any of our websites and log in to make a purchase, redeem vouchers or promo codes (either online or by phone);
- You purchase online and use the checkout as a guest (i.e. without logging in);
- You set up an account with us.
- You purchase a product online, and we collect information by using cookies and similar technologies, but you can manage your cookies on our website.
- You place an order by phone without having an account with us (or explicitly choose not to use one).
- You engage with us on social media channels, like Facebook or Instagram.
- You join our loyalty program.
- You subscribe to any of our email newsletters.
- You contact us to ask questions, tell us something, make a complaint or make a suggestion, by any means.
- You enter our prize draws or competitions.
- You complete any surveys we send you.
- You leave comments or reviews about the products or services we provide.
You can always request access to any personal data we may hold about you. If you leave a review that mentions one of our partners, we may share that information with them, so you might ask us for your record. We also collect information from third-party sources, which you permit to share your information with us. We also gather information from publicly available sources where it's lawful for us to access that information, and you have agreed to the use of your information
5. What sort of personal data do we collect?
- Your name, sex, date of birth, billing/delivery address, orders, receipts, email, preferred methods of paying and telephone numbers.
- For your security, we will maintain an encrypted record of your login password.
- Details of your interactions with us online, in person or by telephone.
For example, we collect notes from conversations with you, any complaints or comments you make, details of purchases you made, items reviewed or added to your basket, all promo code redemptions, brands of interest, web pages visited and how and when you contact us.
- Any items you may have added to your wish list, or rather, a list of items you have shown interest in.
- Copies of any documents you provide to us, to verify your age or identity, where required by law (which includes a copy of your driving licence and/or passport and utility bills). This will include details of your full name, address and date of birth. If you provide a copy of your passport, it will also show your place of birth, gender and nationality.
- Information on your shopping habits/preferences.
For instance, our websites that you select to browse and redeem any promo code vouchers:
- Details about your visits to our websites, as well as which website or search engine you arrived from, to our website.
- Information derived from cookies in your web browser.
We will only request and use the personal data that we collect to provide you with product suggestions of interest and personalise your shopping experience with us. It remains your choice to share any such details with us.
- We will not keep your card data, we will retain your known card/payment method.
- Your product reviews & comments.
- We even capture technical data about your internet connection and your browser, as well as your computer's country, the pages you viewed while you visited our websites, advertisements you clicked, and any search terms you used. We're going even further than that and will collect any simulation videos we may have on you and your shopping experience with us to understand your shopping behaviours and patterns.
- Your social media handle/username if you interacted with us via social media (via all media) to assist us in addressing your feedback, comments or doubts.
6. How and why do we use your personal data?
Our goal is to provide you with the greatest experience possible. One way to do that is to combine the information we have about you to create the most comprehensive and rich picture of who you are.
We then utilise this information to give you offers and goods that are most likely to catch your attention. We will make an effort to provide you with pertinent rewards if you are a member (those who register with us).
The data privacy laws allow this as part of our legitimate interest in knowing our customers and offering the best possible standards of service.
The "What are my rights?" section below contains information if you would like to modify how we use your data.
If you select not to share your personal data with us, or reject certain contact permissions, we might not be able to deliver some services you expect or have asked for.
Here is how and why we will use your personal information:
- To fulfil any orders you place via our websites. We cannot process your order and fulfil our legal responsibilities if we do not obtain your personal information at checkout. To supply or deliver the product you ordered, for instance, your information might need to be given to a third party. We might then retain your information for a fair amount of time in order to fulfil any contractual obligations, like refunds, guarantees, and so forth.
For instance, your information might be required in order for a third party to provide or deliver the good or service you ordered, and we might retain it for a fair amount of time.
- So we can respond to your queries, refunds and complaints promptly. Handling the details you give us lets us get back to you quickly, and we keep a record of our exchanges to ensure nothing slips through the cracks. We do this to meet our contractual and legal duties to you, and because it's in our genuine interest to give you the best service, and learn how to improve it from your website, phone or live-chat feedback.
- So we can send you a reminder if you leave items in your basket. We email you about abandoned carts in our legitimate interest to help you complete your order.
- So we can provide tracking information for your delivery. That way, you can follow your parcel's progress, enhancing your experience and keeping you informed about delivery timings.
- So we can protect our business and your account from fraud or other suspicious activity. We use your data to maintain and secure your account, spot odd log-ins (e.g. via IP checks), and keep our websites running smoothly.
- So we can process payments and prevent fraudulent transactions. This legitimate interest helps keep everyone safe.
- So we can detect or prevent unlawful acts. If our fraud monitoring spots anything sketchy, we'll act to protect you and our business.
- So we can keep you informed (with your consent) about products, personalised offers, discounts, promotions and competitions. You're free to opt out at any time.
- So we can post you relevant, tailored updates and offers. This is done in our legitimate business interest.
- So we can send you mandatory service notices (e.g. policy updates, safety recalls, legal info about your orders). These non-promotional messages ensure we meet legal obligations and don't require your prior consent.
- So we can display the most interesting content on our site. With your consent, cookies or similar tech help us show you items you've viewed, or suggestions based on your history.
- So we can run prize draws or competitions that you enter. We do this based on the consent you provide when entering.
- So we can develop, test and improve our systems, services and products. For example, storing your Session ID helps us troubleshoot feedback about site issues.
- So we can comply with court orders or legal requests from law enforcement agencies. We share data when required by law.
- So we can send you surveys or feedback requests (non-promotional) to help us refine our offerings. This is a legitimate interest that makes our products and services more relevant to you.
- So we can build a fuller picture of who you are and what you like. With your consent, we combine data from across our business, third parties and public sources to personalise your experience and identify regional trends.
- So we can tailor your logged-in area with algorithms (when you've consented). This helps us offer rewards matching your shopping habits; you can opt out at any time, though some features may be limited.
- So we can share your details with third parties (e.g. delivery couriers). Without this, we couldn't fulfil timed or date-specific delivery requests.
- So we can inform our decisions about which third-party sites to partner with for advertising. This ensures our ads reach the right customers across Ireland and Europe.
- So we can track how often and how much you shop with us. Under legitimate interest, we build a profile to influence the offers and rewards you receive.
- So we can pass your contact details to manufacturers or suppliers for delivery or warranties. This fulfils our contractual commitments. If they wish to share your data further, they must inform you and, where required, obtain your consent; you can contact them directly for clarity.
In order to better understand your preferences and adjust our offers and rewards, we also monitor your interactions with Comfort Click, including how frequently you shop and how much you spend. All of this is done out of a genuine desire to provide you with a more customised experience.
We will give the manufacturer or supplier your contact information when you order an item that is shipped directly from them, so they can fulfil your order and uphold any warranties. In this manner, we fulfil our obligations under the contract.
Should those manufacturers or suppliers wish to pass your details on to anyone else or use them for another purpose, they must let you know who they’re sharing with and why, and in many cases, will need your consent first. If you ever have any concerns that your information has been shared without your permission, you’re entitled to get in touch with them directly for clarification.
7. Combining your data for personalised direct marketing
We want to send you promotions and offers that are relevant to your interests at the appropriate times. We combine the data you provide to us on our websites, such as your past purchases, with any information you have consented to third parties (like the Land Registry) sharing in order to better understand you as a customer. This enables us to make sure our suggestions and offers are accurate for you.
8. How do we protect your personal data
We understand how important data security is to each and every one of our clients. In light of this, we will take every precaution to safeguard your data and treat it with the highest care.
We use SSL certification, also referred to as "https" technology, to secure access to all transactional areas of our websites.
Your personal information is password-protected, and sensitive information, including credit card numbers, is tokenised and secured to guarantee security.
In order to find ways to improve security, we routinely check our system for potential flaws and attacks.
9. How long will we keep your personal data?
Whenever we gather your personal data, we'll only retain it for as long as is necessary for the purpose for which it was collected.
When the retention period ends, your data will either be anonymised or deleted completely, for example by aggregation with other data so that it can be used in an anonymous way for business planning and statistical analysis.
Examples of data retention periods;
Orders
When you place an order with us, we'll hold onto the personal details you provide for five years so we can meet our legal and contractual requirements. For certain items, like electrical products, we'll retain your information for ten years.
Warranties
In case your order includes a warranty, we will keep the associated personal data until the warranty expires.
10. Who do we share your personal data with?
We only share your personal details with carefully selected partners to deal with things like delivery, fraud prevention, complaint handling or tailoring offers just for you.
Here's the rule we apply to those third parties to keep your data safe and to protect your privacy:
- We only give them the information they need to carry out their specific task.
- They can only use your data for the purposes we agree to in our contract with them.
- We work hand in glove with them to keep your data secure and your privacy protected.
- If we no longer use their services, they'll either delete your data or strip out any identifiable details so it's anonymous.
Examples of the third parties we work with include:
- Tech companies that keep our website and back-office systems running smoothly.
- Delivery partners, couriers, postal firms and fulfilment centres that pick, pack and post your order.
- Marketing agencies that help us send you emails and other electronic updates.
- Google and Facebook, so we can show you products you might like as you surf the web (with your cookie consent or marketing opt-in - see our Cookies Notice for more).
- Data-insight specialists to make sure your details stay accurate and up to date.
- Fraud-prevention teams, where we share details of suspected dodgy activity in our systems or premises - sometimes even with law enforcement if needed.
- Regulatory or law-enforcement bodies, whether in Ireland or overseas, if they make a valid request (we assess each one carefully to protect your privacy).
- Potential buyers or new owners, if we ever merge, sell or transfer any part of our business, your data would move under the same privacy terms.
If you'd like to know more, just give us a call!
11. Where your personal data may be processed
Comfort Click is based in the UK, so we'll transfer your data there, which is outside the EU. We may also need to share your personal information with partners and suppliers outside the European Economic Area (EEA).
Protecting your data outside Ireland
- We might need to transfer the personal data we collect from you to third-party data processors in countries outside of Ireland.
- For example, this could be necessary to fulfil your order, process your payment details, or provide support.
- If this happens, we have measures in place to ensure your data is protected just as it would be if it were processed in Ireland.
- Any transfer of your personal data will be done in accordance with applicable laws, and we will treat your information following the principles outlined in this Privacy Policy.
12. What are your rights over your personal data?
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data if it’s incorrect, out of date, or incomplete.
- The deletion of the data we hold about you, in certain situations. For example, if you withdraw consent or object, and we have no legitimate overriding interest, or once the reason we hold the data has ended (like after a warranty expires).
- A computer file in a common format (such as CSV, GSheet, PDF, or similar) containing the personal data you’ve previously provided to us, and the right to have it transferred to another entity where this is technically possible.
- A restriction on the use of your personal data in certain circumstances, typically while we are reviewing an objection you’ve raised.
- We stop processing your personal data in certain cases, like when you withdraw consent or object for personal reasons.
- We stop using your personal data for direct marketing, either through specific channels or all channels.
- We stop any consent-based processing of your personal data after you’ve withdrawn consent.
- A review of any decision made solely based on automatic processing of your data (meaning no human has reviewed the outcome and the criteria for the decision).
- You can contact us at any time to exercise these rights.
- If we decide not to act on your request, we will explain why we have made that decision.
If you’ve given permission for us to use your personal data, you’re free to change your mind at any time and pull back that consent.
When We Rely on Legitimate InterestIf we’re using your data because it’s in our legitimate interest, you can ask us to stop for reasons specific to your situation. We’ll comply unless there’s a compelling reason — like administering a warranty extension or health and safety requirements — that means we must keep processing your information.
Direct MarketingYou’re fully entitled to opt out of direct marketing, whether by all channels or just certain ones. Just let us know, and we’ll take care of it straight away.
Verifying Your IdentityTo keep your information secure, we’ll ask you to confirm your identity before handling any request under this Privacy Policy. If you’ve asked someone else to act on your behalf, we’ll also need proof you’ve authorized them to do so.
13. How can you stop the use of your personal data for direct marketing?
Here are a few methods by which you can stop direct marketing communications from our end:
- In any of the emails we send you, simply click the 'unsubscribe' button. From that time onwards, you will stop receiving any further emails from that particular brand of our business.
- You can also log in and change your preferences in case you have an account with us.
- Write to us at Comfort Click, No 7 Dr Croke Place, Clonmel, Co. Tipperary, E91 E7D0 Ireland.
Please note that after changing your preferences, you may continue receiving emails or direct marketing communications for a little while till our systems are updated.
If you believe your data hasn't been handled correctly, or you're unhappy with our response to any request about your personal information, you have the right to lodge a complaint with Ireland's Data Protection Commission (DPC).
You can contact them by calling these numbers - (01) 765 01 00 or 1800 437 437
Or visit - https://forms.dataprotection.ie/contact
14. Any questions?
We hope this Privacy Policy has given you a clear picture of how we handle your personal data and the ways you can manage it.
If you have any questions, please get in touch with our Data Protection Officer - they'll be more than happy to help:
Email us at the address info@comfortclick.eu
This policy was last updated on 25th April 2025.