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Customer Privacy Notice


What this Notice covers

Hydropool North West are committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you.

This notice does not form part of any agreement or contract and may be updated at any time.


Identity of the data controller The data controller is the business which captures the data from individuals and/ or decides how it is to be used and processed. For your customer and employees, you will be the data controller.


We are a data controller for any personal information that you provide to us. This means that we are responsible for determining how information relating to you is used, stored and shared.


Categories of personal data we process


We will collect, store, and use the following categories of personal information about you:


  • Your full name

  • Your address

  • Your contact details such as phone numbers and email addresses

  • Your employment status, salary and homeowner status (financing only)

  • Garden Access, and Property Details (for installation purposes)


Sources of personal data


We collect personal information relating to you directly from you. If any customer information is obtained from other sources these must be stated here.


Our lawful bases for processing your data  


We will use your personal information in the following circumstances:


  • Where we need to perform the contract we have entered into 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

  • To comply with relevant legislation and regulations


Our purposes for processing your data


  • Performing the contract that we have entered in to with you by providing you with the products and services that you have ordered

  • To provide you with a quote and the details of all available payment methods when you have shown an interest in our products and services

  • To issue marketing material to you about the products and services we offer

  • To process a finance application for you

  • If you use customer data for any other purposes then these must be listed here


Sensitive Personal Data

There may be instances where it is necessary for you to share information with us containing special categories of personal information or ‘sensitive personal data’. This relates to things such as details of medical conditions which you may need to share with us so we are able to meet your specific requirements when providing our goods and services.

Due to the sensitive nature of this information, we will only take it from you if you have given us your explicit consent and it is necessary for us to do so. We will also inform you of what we will do with this information and who we will share it with.

Use of Cookies

If you visit our website, we may use cookies where appropriate to gather information about your computer and your general interests to enable us to improve our website and target marketing appropriately.

Cookies are stored on your computer’s hard drive and cannot be used to identify you personally as they contain no personal information.


Who has access to your data


We may share your personal information with third parties where required by law, where it is necessary to administer the contract we have entered in to you with you, or where we have another legitimate interest in doing so.


Recipients of your data may include third-party service providers, other related business entities, a regulator, or to otherwise comply with the law.


If you choose to fund your purchase with us using one of the finance products we offer to our customers as a credit broker on behalf of lenders, we will share your data with the relevant lender so they are able to process your finance application.


Where we do so, we will require third parties to respect the security of your data and to treat it in accordance with the law.


Security of your data


We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.


We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


How we decide how long to retain your data


We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or contractual requirements.


To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and any applicable legal or contractual requirements.


Your Rights


You have the right to:


  • Request access to, and a copy of, your personal information that we hold.

  • Request correction of the personal information that we hold about you if you believe it is incomplete or inaccurate

  • Request erasure of your personal information in specific circumstances, such as; if our processing of your personal information is based upon legitimate interests and you believe it is no longer necessary; or if you believe we have processed your personal data unlawfully or not for the purposes which it was intended.

  • Object to processing of your personal information 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.

  • Request to restrict the processing of your personal information in specific circumstances, such as; you have requested that your personal information is corrected and want to restrict processing whilst we correct it; where you believe our processing is unlawful but do not want us to erase your personal information; where we no longer need to store your personal information but you require us to do so to enable you to exercise or defend a legal claim.

  • Data Portability in particular circumstances meaning that you can request for your personal information to be securely moved, copied or transferred from our IT environment to another. This only applies if our lawful basis for processing your data is consent or performance of a contract, and we are processing your data by automated means.


If you believe we have not complied with your rights, you can complain to the Information Commissioner by visiting their website


Automated decision-making & Profiling

Automated decision making is where a decision is made by a computer without human intervention. In instances where this happens, individuals have the right to request human intervention and review. It is unlikely that you are conducting automated decision-making activities, but if you are then amend this section accordingly.

We do not conduct any automated decision-making or profiling activities whilst processing your personal information.


Changes to this Privacy Notice

The Company reserves the right to update this privacy notice at any time. You can request the most up to date version from us at any time by contacting us on the contact details below.


Contacting Us

Please do not hesitate to contact us regarding any matter relating to this Privacy notice via 0161 292 6649

Complaints Procedure


If you're not completely happy with our service we'd like to hear about it, that way we can put it right. We do everything we can to make sure our customers get the best products and the best service possible, however, sometimes we may not get things right first time.


We want to:

- Make it easy for you to tell us what went wrong

- Give your complaint the attention it deserves

- Resolve your complaint fairly and without delay

- Make sure you are satisfied with how your complaint was handled

How and where to complain

If you are not satisfied with any aspect of our/product service you can tell us about your complaint in
the following ways:

- In person:

Cabins & Spas Ltd - Hydropool Northwest

Notcutts Garden Centre

Lord Sheldon Way



- In writing: write to us at the address above, please address your letter to The Complaints

- By Telephone:0161 524 4192

- By email:

How long will it take?
We will aim to resolve your complaint straight away but if we can't we will write to you within 5
business days to tell you:

- Why we have not resolved your complaint

- Who is dealing with your complaint

- When we will contact you again

If a customer raises a complaint which we believe both our business and a 3rd party (such as a
lender) are responsible for, we will:

- Write to you within 5 days and explain which parts of the complaints our business is
responsible for and which parts the 3rd party is responsible for.

- Provide the name and contact details of the 3rd party business.

- Refer the relevant parts of the complaint to the 3rd party within 5 days by getting in
touch with them; and

- Handle the parts of the complaint which we are responsible for as per our BAU process.

If a customer raises a complaint which we believe is against a 3rd party (such as a lender) are
responsible for, we will:

- Write to you within 5 days and explain to why the complaints has been handed off to
the 3rd party.

- Provide the name and contact details of the 3rd party business.

- Refer the relevant parts of the complaint to the 3rd party within 5 days by getting in touch with them.

We will usually resolve your complaint quickly, but if it is complex it may take longer. We will keep
you informed on a regular basis but if you need an update please call us on the number above and
ask to speak to the person dealing with your complaint.

If we cannot reach agreement with you:

If we can't agree a solution within 8 weeks and your complaint relates to our credit brokerage
service we will:

- Send a letter giving our reasons for the delay and an indication of when we expect to
provide a final decision

- Issue our final decision letter which will explain our final position

Our aim is to resolve all credit brokerage related complaints internally. However, if after receiving
our final decision letter or 8 weeks have passed you may have the right to refer your complaint to
the Financial Ombudsman Service (FOS).

If you want the FOS to look into your complaint you must contact them within six months of the date of our final response letter.

Financial Ombudsman Service
Exchange Tower
E14 9SR

Telephone: 0800 0234567

Further helpful information can be obtained from visiting their web site at:

Vulnerable Customer

Vulnerable Customer Statement

1. Policy statement


We are committed to identifying, assessing, and managing vulnerable customers in accordance with our own objectives and policy, as well as any regulations and guidelines set out by our regulators.


Implemented are several identification and assessment tools within the procedure section of this document, aimed at identifying, assessing, and dealing with all Vulnerable Customer situations and to consistently ensure that our staff are aware of, and knowledgeable about Vulnerable Customers, including how to handle all situations.


2. Regulatory References 

PRIN 2.1.1, FG21/1 Guidance for firms on the fair treatment of vulnerable customers

3. Purpose


We are committed to ensuring that all our customers are treated fairly, and we meet all of their needs to the best of our ability.

We appreciate that sometimes our customers may be vulnerable because of a physical or mental health condition suffered by themselves or a family member, age, illiteracy, or if their first language is not English.

This means that we may have to treat vulnerable customers according to their individual circumstances. In order to do so we have employed staff with experience of sales and customer service and given them the necessary training to enable them to identify the signs of vulnerability and how to proceed with that customer.

We ensure that our staff have the necessary training, knowledge, understanding and support to be able to identify the potential signs of a vulnerable customer in their dealings with them, and then tailor their approach accordingly.


4. Scope and definition


Vulnerability is an extremely subjective area, however our staff are constantly on the lookout for potential signs, such as, a lack of understanding, communication issues and unusual or erratic behaviour.

The FCA defines a Vulnerable Customer as: – “Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

The vast majority of our communication with customers is face to face and, in some instances, over the phone, which does however make it easier for our staff to be able to identify both short term causes of vulnerability, such as short-term illnesses or a bereavement, as well as long-term causes, such as mental illness or a disability.

There are several risk factors that contribute to consumer vulnerability so these should be considered whenever dealing with an existing or potential customer. 

The nature and scale of characteristics of vulnerability that exist in our customer base are:

  • Low literacy or numeracy skills – unable to complete forms or read/understand information.

  • Communication difficulties – struggle with speech or hearing, or English is not their first language.

  • A clear lack of understanding – ask you to repeat yourself or ask questions out of context.

  • Appearing confused or unfamiliar with finance or finance applications 

  • Low income with high value purchases/ finance applications.

  • A change in circumstances – e.g. pregnancy or bereavement.

  • Severe or long-term illness.

  • Mental health problems.

  • Low income and/or debt.

  • Change in circumstances (e.g. job loss, bereavement, divorce).


These characteristics may affect the customers’ ability to make an informed decisions on what is best for them and knowingly enter into contract/ credit agreements.

5. Processes and procedures


If a member of staff believes that a customer could potentially be vulnerable then they will ask non-intrusive questions to understand the customer’s circumstances, allowing them to identify if the customer is in fact vulnerable and how our approach will need to be tailored for that customer.

Any information gathered will be processed in line with GDPR and the Data Protection Act 2018. Where necessary, explicit consent will be obtained from a customer to enable us to process the details of their vulnerability accordingly. Customers will also be fully informed of how we will process this information.


We will always:

  • Ask for a customer’s explicit consent to record, store or process the details of their vulnerability, where it is necessary and appropriate to do so.

  • Clearly explain to the customer why we need to record, store, or process the details of their vulnerability.

  • Clearly explain to the customer who the details of their vulnerability will be shared with


To assist with obtaining consent, we will use the TEXAS model:

(T) Thank the customer for providing the information regarding their vulnerability.

(E) Explain to them how you are going to use this information (it will assist in processing their order and meeting their needs, etc).

(X) Explicit consent - you need to obtain their consent to store the information relating to their vulnerability. Ask for permission to store it, explain who will have access to it and how long you will store it for.

(A) Ask how their vulnerability affects their ability to understand the information you are providing, their ability to manage their own finances and if they need a friend or family member present.

(S) Signpost - if you have any concerns or believe that the customer needs expert help or support then signpost them to the relevant help, or advise them to talk to a friend or family member.

To allow us to tailor the needs of the customer we have adopted IDEA to allow us to manage more in-depth conversation:


Ask what they are finding hard. What the impact does it have on their personal and financial situation.



When did this start to happen?



How is the client experiencing this vulnerability? Is it something that fluctuates?



Is there anything else we should know about support, treatment or care you are receiving? 

Does the customer need any further support from us or from a third party to ensure they have the right support in place when making a decision. 


Typically, we would only look to process the details of a customer’s vulnerability where we may need to tailor our approach during our communications with them, or when we are entering their home for the purposes of a sales consultation or installation. We would therefore only share the details of the vulnerability with the relevant staff and representatives.

The various methods for customers to contact us considers the product designs and are clearly visible on all communications and our website and provide a choice of ways to communicate with us

o Post

o Email

o Face to Face

o Telephone

All our communications verbally or written material is clear, to the point and jargon free.

Where applicable, we try our best to ensure the products/services that we offer are flexible and made to suit the customers’ needs and requirements and where possible deal with the customer’s authorised third-party in a helpful and transparent manner.

All sales visits are followed up with a telephone call and in writing and the benefits and consequences of any product/service are fully explained along with any legal implications. 

Where we feel it is needed, additional time is provided between the sales call, written follow up and contractual agreement to allow the customer time to communicate with a third-party and understand the content of the product/service offered.

We ensure that all of our customers do not make a purchase with us or enter into a credit agreement with one of our lender partners without fully understanding what they are entering in to. 

When presenting finance options to our customers we do so using our electronic choice of funding software (eCOF) which describes the products clearly and displays the breakdown of each product to the customer. A copy of the bespoke choice of funding is the emailed directly to the customer. Sales representatives also talk through this with customers and explain verbally the information which has been emailed to them.

If we believe that the customer is not fully aware of what they are entering in to then we will:

  • Not continue with the sale of any products or services.

  • Not continue with any application for credit to fund a purchase.

  • If a friend or family member is available to assist the customer, or we will arrange a follow-up appointment when a friend or family member is available.

  • Provide the customer with all relevant information in a clear, fair and not misleading manner, allowing them to make an informed decision.

  • Not refuse to deal with an individual due to their vulnerability. Instead, we will aim to understand the customer’s need to enable us to work with them, tailor our approach, and  ensure they are treated fairly.

  • We may tailor or communication to meet the customer’s needs, for example, increasing the font size on our written communications. 

  • Not label different demographics or individuals as vulnerable without understanding their situation. We accept that no two people are the same and each individual should be handled on a case-by-case basis. 

  • Where appropriate, we may also signpost customers to agencies such as Citizens Advice or Age Concern UK to seek further guidance and support. 

  • Should we be made aware via a third party that a customer has passed away we will act with empathy and respect. We will then decide on the best way for all parties involved how to move forward. 


6. Monitoring and reviews

As per our compliance monitoring plan, the Company carries out regular internal audits and gap analysis monitoring to understand if we have met the needs of customers with characteristics of vulnerability on all business practices and procedures to ensure that our customers, not just those of vulnerable customers objectives are being met.

Regular reviews of the audit results are held with senior management and an ongoing record of gaps, actions and improvements are maintained. We analyse if we have met the needs of our vulnerable customers through identifying common trends and making changes where applicable.

7. Product Design


When it comes to product design, the financial products will be available to all customers and when making changes to any financial products, we will ensure this is in line with customer needs.


When creating or amending any informative or promotional material, we will ensure that we that the needs of our vulnerable customers are considered.


8. Responsibilities

The Company ensure that all staff are provided with the time, resources, and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices. Senior Management are responsible for a top-down approach and in ensuring that all staff are included. 

All staff are provided with the training and tools to identify, understand, and deal with vulnerabilities and vulnerable customers, this training is delivered on commencement of employment and is refreshed annually. 

We understand that at times, employees may experience situations with vulnerable customers which affect them emotionally, for example if they have suffered from a similar experience with a family member or themselves. In these scenarios, we will offer support to the individual and make considerations with regards to their exposure to such situations moving forward. 

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