Business privacy policy

*Last update September 2022
Universal Works Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Universal Works Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you register for an account with us or purchase any of our products. 
This website is not intended for children and we do not knowingly collect data relating to children.
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. 

Universal Works Limited is the controller and responsible for your personal data (collectively referred to as “Universal Works”, "we", "us" or "our" in this privacy policy).

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Universal Works Limited 
Email address: 
Postal address: 1 Ashville Close, Nottingham, NG2 1LL
Telephone number: (+44)115 924 9363
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 ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please 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 9 December 2021. 
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
This website 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.

The data we collect about you
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.
• Contact data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you including cred card, debit card and/or any other payment information to process payments and other details of products you have purchased from us directly or through one of our stockists. This also helps us identify and investigate suspected fraudulent transactions and support the security of the business.
• Technical Data includes 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 this website.
• Profile Data includes your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information and how you use your website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties 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 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 our products). In this case, we may have to cancel an order 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:
• Directly from you. You may give us your Identity, Contact and Financial Data by filling in forms or by contacting us by post, phone, email or otherwise. This includes personal data you provide when you:
• place an order with us;
• create an account on our website;
• subscribing to our newsletter;
• enter a promotion or survey; or
• give us feedback or contact us. 
• Automated technologies or interactions. As you interact with our website, 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. Please see our cookie policy [LINK] for further details.
• Through 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
• advertising networks
• search information providers
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Apple Pay, Klarna and Paypal.
• Identity, Transaction, Technical and Marketing and Communications Data which we may receive from our stockists.
• Identity and Contact Data from data brokers or aggregators.

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:
• For performance of a contract - where we need to perform the contract we are about to enter into or have entered into with you so where processing your data is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract i.e. where you place an order with us.
• Legitimate Interest - 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. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Complying with a legal obligation - where it is necessary for compliance 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 although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing 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 below. 
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(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
(a) Identity  (b) Contact  (c) Financial  (d) Transaction  (e) Marketing and Communications
(a) Performance of a contract with you  (b) Necessary for our legitimate interests (to recover debts due to us and process your transaction with our third-party payment processors)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Providing administrative support for your account 
  3. 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)
To enable you to take part 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 see how customers use our products, 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
(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) (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 see how customers use our products, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products, marketing, customer relationships and experiences
(a) Technical  (b) Usage 
Necessary for our legitimate interests (to define types of customers for our products, 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  (f) Marketing and Communications
Necessary for our legitimate interests (to develop our products and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 
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 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 from us and you have not opted out of receiving that marketing.

Third-party marketing 
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out
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 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, product/service experience or other transactions.

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 click here

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.

Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
Service providers including:
• those who help us and our customers with use of our services such as payment processing providers, warehouse team, delivery and courier companies and return services;
• stockists who sell or promote our products to help us enhance your customer experience;
• those who help us with running our business day to day such as website hosting companies, plus other IT and system administration providers.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Marketing companies and online advertising who help us manage our electronic communication and provide marketing and advertising assistance.
• 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. 
    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.

    International transfers
    We do not transfer your personal data outside the UK.

    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.

    Data retention
    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.
    By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
    In some circumstances you can ask us to delete your data: see 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. 

    Your legal rights
    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 
    • 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: 
    a.) If you want us to establish the data's accuracy.
    b.) Where our use of the data is unlawful but you do not want us to erase it.
    c.) 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.
    d.) 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 us.

    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.

    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. 

    Pixlee Privacy Statement:


    What to consider before agreeing to our user generated content license terms.
    You have to be the owner of all the rights with regard to the Content. So only give us your consent if you have taken the picture yourself or have the permission of the copyright owner to allow Universal Works the use according to the following Licence Terms. 
    You need the permission of all the people appearing in the Content and have their explicit consent to have their image and/or name used by Us. In the event, that any people pictured or mentioned are minors, you must obtain the express permission of their parents or guardian to have their image and/or name used by Us. So before obtaining their permission make sure to inform them about these Licence Terms. 
    Make sure that the Content does not violate any law or other regulation and is not inappropriate or otherwise objectionable or offensive in any way.
    If you can’t grant all of these topics and/or you disagree with the following Licence Terms, don’t reply to Our usage request.
    Licence Terms
    1. Definitions
    When it is referred to “Us” or “Our” or “We” in these Licence Terms it refers to Universal Works, 1 Ashville Close, Nottingham, NG21LL, UK.
    When We refer to ‘Content’ in these Licence Terms We mean your photo/image, including but not limited to your Instagram handle and any caption or comment in connection with the photo/image that We asked you to use.
    2. Granting of rights
    By responding with @universal_works or #uwapproved on Our usage request or by otherwise agreeing to Our use of the Content as may be available (e.g. by direct message), you grant Us the free of charge, non-exclusive, royalty-free, worldwide, irrevocable, unlimited in time right to use the Content for any non-commercial and commercial purposes, including but not limited to point-of-sale-advertisement, trade fairs, exhibitions, sales events, festivals, competitions, events or in connection with any other advertising or promotional purposes, as We see fit.  Without limiting the foregoing, Content submitted or posted on the galleries (directly by you or by Universal Works following your consent), may in any form on the website and/or shared within Our promotional channels, including Facebook, Twitter, Pinterest, Instagram and email channels and used otherwise for marketing or general business purposes in any format.  
    You also grant the right for Universal Works to make a statement around the Content in any format.
    The right to use shall include the right to:
    • Store, (re)publish, broadcast and distribute the Content, intact or in parts, in any printed or electronic form and media, including on the internet, e.g. on websites, in social networks, social media channels , as well as in applications or other services including those provided for mobile devices. 
    • Reproduce, process, copy, change, transform, adapt, combine and modify the Content, intact or in parts, including its digital processing; 
    • Grant sublicences to Our affiliated entities and to have service providers commissioned by Us conduct tasks related to aforesaid means of use. 
    Universal Works also have the right to disclose yOur identity to any third party who is claiming that any Content posted or uploaded by you or by Us following yOur consent, constitutes a violation of their intellectual property rights, or of their right to privacy.
    3. Storage And Removal Of Content
    We reserve the right to use, not use, or discontinue using any Content in Our sole discretion at any time.
    We reserve the right to remove or modify Content for any reason; including Content that We believe violates these Terms or Our policies at any time.
    If  Content is removed from our galleries, in whole or part, including for data protection purposes, to the extent permissible by law, We may keep your Content for a commercially reasonable period of time for backup, training, archiving purposes and audit purposes.
    Furthermore, Universal Works and its users may retain and continue to use, store, display, reproduce in any format, modify, create derivative works, perform, and distribute any of your Content that other users have stored or shared through the galleries.
    You agree to assist Universal Works in the removal of Content as may be required.
    4. Representations, Liability, Warranty
    You hereby represent and warrant that you are of legal age and that you have all necessary right and title, and particularly have obtained all necessary consent as described above, to grant the above rights to Us without violating any rights of third parties and in compliance with applicable laws. 
    You hereby represent and warrant that the Content is free of any virus, worm, corrupt file or other forms of malicious code or Content that may cause harm to a website or electronic device. 
    You agree to indemnify, defend and hold Us harmless from any claim or cause of actions related to your violation of any of these terms, including but not limited to any claims arising out of an alleged violation of any third party rights. 
    You will inform Us without undue delay in case you get aware of any third party asserting any claim, actions or similar demand against you or Us as a result of Our use of the Content.
    5. Data Protection
    When you agree to the Licence Terms and the Content provided by you contains personal data (e.g. image, name etc. of you and/or other natural person, We and, if applicable, Our affiliated entities  may process this personal data accordingly when exercising the right of use granted to the Content as described in section 2 of the Licence Terms.
    6. Applicable Law
    The laws of the United Kingdom shall apply. Statutory provisions limiting the choice of law and the applicability of mandatory provisions, in particular those of the country in which you as a consumer have yOur habitual residence, remain unaffected by the aforesaid.