What this Policy covers

Hazlemere Window Company Limited (HWC) is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you, and how we protect your data on a day-to-day basis in accordance with your rights under the General Data Protection Regulation (GDPR) 2018.

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

Identity of the data controller

HWC is a group of companies. Your information may pass from one company to the next for administration purposes such as accounting. Companies where your data may be shared are as follows: Hazlemere Windows (Trading Company) and Hazlemere Management Services LLP.

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.

HWC recognises the importance of protecting the personal information and the privacy of data provided by you (and that which may personally identify you).

By accessing or browsing our website, contacting us on social media, working with or for us, offering your goods or services to us, using any of the goods and services that we provide to you or otherwise providing your information to us (including when entering competitions or when attending our events), you confirm that you have read and understood the entirety of this privacy policy.

Categories of personal data we process

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

a. Contact Information

  • Your full name
  • Your address
  • Your contact details such as phone numbers and email addresses

b. Information about the goods or services we provide to you:

  • information needed to provide goods or services to you (including information on account opening forms, details of your order, order history, payment details, delivery address, delivery requirements and restrictions, trade references and tax information, employment status, salary and homeowner status for the purpose of processing finance applications);
  • customer services information; and
  • customer relationship management and marketing information

c. If you choose to use social media in order to contact us or find out about our products or services, your profile information (including your preferences and interactions with us on Facebook, Instagram and Twitter) and information which you post on message boards which are relevant to our business.

As part of our commitment to raising standards, we may monitor and record communications with you (including phone conversations, emails, text and webchat conversations) for quality assurance, legal, compliance and training purposes.

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. When you enter your personal details on our website, we’ll ask you for your name, address, telephone numbers (mobile and land) and email address.

Sources of personal data

We collect personal information relating to you directly from you.

The legal basis we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data. We use Legitimate Interest. In the situations where we collect and process your personal data, we require it to pursue our legitimate interests in a way which might reasonably be expected as part of running our business.

 Our purposes for processing your data

  1. Performing the contract that we have entered in to with you by providing you with the products and services that you have ordered
  2. 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
  3. To issue marketing material to you about the products and services we offer
  4. To process a finance application for you
  5. 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
  6. To comply with relevant legislation and regulations


How we use this information

We collect, use and store your personal information for the following reasons:

  • to allow our advisers, agents and sales representatives to follow up our service, either by email, telephone, text or mail, as part of our customer care procedure;
  • to help us to understand your needs and provide a better service;
  • to help us to improve our products and services;
  • to enable us to occasionally contact you for market research purposes;
  • to enable us to send you information about new products, special offers or other information that we think you may find interesting;
  • to administer our websites;
  • to facilitate our internal record keeping;
  • to enable you to participate in our competitions and promotions;
  • to help to prevent and detect fraud or loss;
  • to process orders which you place for goods or services from us;
  • to prepare before and after photographs of enhancements to your property to use for marketing purposes;
  • to amplify an event to a broader audience and for internal presentation purposes, we may use your photograph or video footage from an event where it is in our legitimate interests for marketing and business development purposes or where we have your consent; and
  • to contact you to invite you to write a news article about our products and services; to invite you to events, send you promotional material and for press releases if you are a journalist, where it is in our legitimate interests.
  • to provide relevant goods or services to you or your employer (including, to confirm and process orders, for administration of your account with us, customer loans, tax and export, billing and debt collection purposes;
  • to deal with any enquiries or issues you have about our goods and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
  • to send you certain communications (including by email or post) about our goods and services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
  • to allow you to attend our events or participate in competitions and to send you photos that you have permitted us to take of you;
  • for health and safety and quality assurance;
  • to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.
  • to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so
  • to process your information in accordance with your rights under the General Data Protection Regulation (GDPR) 2018.

Where appropriate, we will seek your consent to undertake some of these activities.

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 contact details, measurements and products used are retained on our systems for the duration of your guarantee so that we can carry out necessary repairs. If you request that we delete this information it will impact on the repairs/replacements we will be able to offer.

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

As required under the General Data Protection Regulation (GDPR) 2018, 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.

Your rights

As defined by the Information Commissioners Office (ICO) under the General Data Protection Regulation (GDPR) 2018, 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 contact to the Information Commissioners Office (ICO) by visiting their website https://ico.org.uk/.

Automated Decision-Making & Profiling

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

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.

Cookies are completely safe and will expire at a set time at which moment in time they will be removed from your computer. You are completely free to delete any cookies yourself at any time or if you choose to or you can have your browser prevent them being set in the future. Our website allows you to accept or refuse the use of cookies by us during your browsing session.

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 or regarding how HWC uses or stores your data. Please contact Rachel Braham-Hill, Managing Director via email r.braham-hill@hazlemere.co.uk or in writing to our:

Data Department
Hazlemere Window Company Ltd
Wellington Road, Cressex Business Park
High Wycombe, Bucks HP12 3PR

Registered in England and Wales | Company No. 02185969.

Hazlemere Window Company Ltd's Terms & Conditions

1. General

Use by users (“you”/”your”) of www.hazlemere.co.uk (“the Site”) constitutes acceptance by you of the following terms of use. YOUR USE OF THIS SITE WILL BE GOVERNED BY THESE TERMS. PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THE SITE. If you do not agree to all of these terms of use and our Privacy Policy (“terms”), you may not use the Site which is owned and operated by Hazlemere Window Company Limited; ("us"/”our”/”we”).

These terms relate to your use of the Site.

All samples, drawings, descriptions, specifications, illustrations, photographs and advertising or equivalent or otherwise (“Sample(s)”) are issued or published on the Site for the sole purpose of giving an approximate idea of the products represented by or described in them. By using this Site, you appreciate that the colour of the product as they appear in the Samples may not accurately reflect the colour when the product is actually viewed and colour variation may otherwise occur outside of our control or the manufacturer, and whilst we use reasonable endeavours to ensure that the Site Samples match the actual product, we cannot and do not guarantee this. Accordingly, any purchase by you of product based on the Site Samples alone will not be deemed as a sale by sample.

2. Copyright and Trademarks

The information and materials ("Content") appearing on the Site are displayed for personal, non-commercial use only. All software used on the Site and all Content included on the Site (including, without limitation, site design, text, graphics, audio and video, the selection and arrangement thereof and the underlying source code) is our property, or that of our suppliers, and is protected
by international copyright laws. ALL RIGHTS RESERVED.

None of the Content may be downloaded, copied, reproduced, republished, posted, transmitted, stored, sold or distributed without the prior written permission of the copyright holder. This excludes the downloading of one copy of extracts from the Site on any single computer for personal, non-commercial home use only, provided that all copyright and proprietary notices are kept intact. Modification of any of the Content or use of any of the Content for any purpose other than as set out herein (including without limitation on any other website or computer network) is prohibited. If you breach any of the terms of this legal notice, your permission to use the Site automatically terminates and you must immediately destroy any downloaded or printed extracts from the Site. Requests to republish any of the Content and to use quotations or extracts from the Site should be addressed by postal mail to:


Marketing Manager
Hazlemere Window Company
Wellington Road
Cressex Business Park
High Wycombe Buckinghamshire HP12 3PR

All trademarks, service marks and logos used on the Site from time to time are the trademarks, service marks or logos of their respective owners. We have made every effort to secure (where appropriate) licenses and clearances for all third party intellectual property used on the Site. You may notify us of alleged intellectual property rights infringement by contacting us by postal mail to:

Marketing Manager
Hazlemere Window Company
Wellington Road
Cressex Business Park
High Wycombe Buckinghamshire HP12 3PR

3. Links to third party websites

The Site may from time to time include links to third party internet websites which are controlled and maintained by others. Third party web sites includes any web site other than www.hazlemere.co.uk. This Terms Of Use applies to www.hazlemere.co.uk and does not apply to any other dealer web site (please see those respective web sites for their Privacy Policy and Terms of Use guidelines). Links from our Site to any other web site are included solely for your convenience and do not constitute any endorsement by us of the websites linked to or referred to, including the products and/or services featured on those websites, nor do we have any control over, or knowledge of, any privacy practices or content of any such websites. Further, we have not reviewed these third party websites and do not make any representations regarding the availability, content or accuracy of materials on such websites. If you decide to access third party websites through links on the Site, you do so at your own risk. Your use of third party websites is subject to any terms and conditions of use of those websites which you should read immediately prior to submitting personal information to those websites.

4. Liability disclaimer

While we endeavour to ensure that the information on the site is correct, to the maximum extent permitted by law, we provide you with the site on an ‘as is’ basis only. You accept that access to the site may be suspended at any time and without notice in the case of systems failure, maintenance or repair or for any other reasons whatsoever, including for reasons beyond our control.

We make no representation or warranties of any kind, express or implied, as to the operation of the site or the information (including samples as defined at clause 1 above), reliability, completeness or timeliness of the content or services available on the site or that the use of the site will be uninterrupted, timely, secure or error-free. You expressly agree that your use of the site is at your own risk.

Further, any other party (whether or not involved in creating, producing, maintaining or delivering the site) including the officers, employees, consultants or agents exclude all liability and responsibility for any amount or kind of loss or damage that may result to you or any third party (including without limitation, any direct, indirect, punitive or consequential loss or damages, or any loss of income, profits, goodwill, data, contracts, use of money or loss or damages arising from or connected in any way to business interpretation and whether in tort (including without negligence) contract, warranty or otherwise in connection with the site in any way or in connection with the use, inability to use or the results of use of the site, any websites linked to the site or the content on the site, including but not limited to loss or damage due to viruses (including logic bombs, trojan horses, worms, harmful components, corrupted data or other malicious software or harmful data) that may infect your computer equipment, software data or other property on account of your access to, use of, or browsing the site or your downloading of any content from the site or any websites linked to the site. Further, we exclude all liability and responsibility as set out above whether or not we are advised of the possibility of such loss or damage.

Nothing in this legal notice shall exclude or limit our (including our employees
 or agents) liability for:-

(a) death, personal injury or fraud caused by our negligence; or
(b) mis-representation as to a fundamental matter; or
(c) any liability which cannot be excluded or limited under applicable law, including:-

(a) conditions and warranties as to title to goods implied by sale of goods legislation and where the customer deals as a consumer; or

(b) conditions as to goods’ description, fitness and quality and implied by sale of goods legislation and conditions as to supply of goods and services legislation

If your use of the content on the site results in the need for servicing, repairing or correction of equipment, software or data you assume all costs thereof.

If you are a consumer this legal notice does not affect your statutory rights which you have under law which cannot be excluded or limited. If you want to know what these rights are, you should contact your local Citizens’ Advice Bureau.

5. Your account

If you have an account with us, then you are responsible for maintaining the confidentiality of this account and any related passwords for your restricting access to your computer and/or account. You agree to accept responsibility for all activities that take place under your account and/or passwords. Currently, only employees, CO dealers and their employees and certain vendors require passwords to access certain portions of the web site. At this time, general consumers do not require passwords to access our Site. In the event that providing you with a password becomes necessary or helpful to your use of our Site, you will be responsible for maintaining the confidentiality of this account and any related passwords for your restricting access to your computer and/or account. You agree to accept responsibility for all activities that take place under your account and/or passwords.

Other than personal data or sensitive personal data about you, which is covered under the terms of our Privacy Policy, any material you transmit or post to the Site shall be considered non confidential and non-proprietary. We shall have no obligations with respect to such material. We and designated third parties shall be free to copy, disclose, distribute, incorporate and otherwise use such material and all data, images, sounds, text and other things embodied therein for any and all commercial or non-commercial purposes. You are prohibited from posting or transmitting to or from the Site any material: that is threatening, defamatory, obscene, indecent, seditious, offensive, pornographic, abusive, liable to incite racial hatred, discriminatory, menacing, scandalous, inflammatory, blasphemous in breach of confidence, in breach of privacy or which may cause annoyance or inconvenience; or for which you have not obtained all necessary licenses and/or approvals; or which constitutes or encourages conduct that would be considered a criminal offence, give rise to civil liability or otherwise be contrary to the law of or infringe the rights of any third party, in the United Kingdom or any other country in the world; or which is technically harmful (including without limitation, computer viruses, logic bombs, Trojan horses, worms, harmful components, corrupted data or other malicious software or harmful data); or which facilitates your misuse of the Site (including, without limitation, hacking)
 We shall fully co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity or locate anyone posting any material in breach of the above prohibitions.

6. Termination

You agree that we may in our sole discretion and at any time terminate any password and account (or any part thereof) of yours without limitation, if we reasonably believe that you have violated or acted inconsistently with the letter or spirit of these terms.

7. Special offers and finance

Hazlemere Window Company reserve the right to end or change offers featured on our website at any time without prior notice. All others and products are subject to availability. All finance is subject to status and written quotations are available upon request. Hazlemere Window Company is Authorised and regulated by the Financial Conduct Authority. If you have any questions or a complaint about our special offers or finance please contact us by writing to:

Marketing Manager
Hazlemere Window Company
Wellington Road
Cressex Business Park
High Wycombe Buckinghamshire HP12 3PR

or telephone 0800 082 5825

8. Indemnity

You agree to indemnify and hold us, our officers, employees, agents, consultants, licensees, web designer, web personnel and suppliers, harmless from and against any claims, actions or demands, liabilities and settlements including, without limitation, reasonable legal and accounting fees, resulting from or alleged to result from, your use of the Content of the Site in a manner that violates, or is alleged to violate, these terms. We shall provide notice to you promptly of any such claim, suit, or proceeding, and shall reasonably co-operate with you, at your expense, in your defence of any such claim.

9. Force Majeure

We will not be liable for any delay or failure in performance or interruption of the delivery of the Content of the Site. Furthermore, we will not be liable for any delay or failure in performance or interruption of the delivery of the Content of the Site resulting directly or indirectly from any cause or circumstances beyond our reasonable control, including but not limited to failure of equipment or communication lines, telephone or other interconnect problems, computer viruses (including logic bombs, Trojan horses, worms, harmful components, corrupted data or other malicious software or harmful data), unauthorised access, theft, operator errors, severe weather, earthquakes or natural disasters, strikes, or other labour problems, wars or governmental restrictions.

10. Severability and Waiver

If any provision of these terms is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these terms, which shall remain in full force and effect. No waiver of any of these terms shall be deemed a further or continuing waiver of such term or any other term.

11. Access outside England

We are based in England. Access to the Content of the Site may not be legal by certain persons or in certain countries. If you access the Site from outside England you do so at your own risk and are responsible for compliance with the Laws of your jurisdiction. Recognising the global nature of the internet, you agree to comply with all local rules regarding online conduct and acceptable content. Specifically, you agree to comply with all applicable laws regarding the transmission of technical data exported from the country in which you reside.

12. Entire agreement

These terms constitute the entire agreement between you and us and govern your use of the Site, superseding any prior agreements between you and us.

13. Jurisdiction

These terms are governed by, and construed in accordance with, English Law unless you live in Scotland in which case, these terms will be governed by Scots Law and you and us irrevocably agree that the UK Courts shall have non-exclusive jurisdiction to settle any dispute which may arise out of or in connection with these terms or the legal relationship established by them, and for those purposes irrevocably submit all disputes to the non-exclusive jurisdiction of the UK Courts.

14. Notification of changes to these terms and conditions

We reserve the right at our sole discretion to add to or change these terms. If we publish any changes we will let you know by posting such changes to this page and/or by posting notification of change to our Site homepage. Once we have posted any such changes it is then your responsibility as a user to ensure that you are aware of such changes from time to time. Changes will become effective 24 hours after first posting and you will be deemed to have accepted any change if you continue to access the Site after that time.

15. User information

We do collect information on what pages are accessed or visited by you for statistical purposes. Our web site uses web site statistical services that compile statistics on the general geographical locations of users, IP addresses, the time spent on the web site, the pages visited, the screen resolutions and other useful statistical data pertaining to visitors' computers and the pages accessed when visiting the Site. By viewing any page within our Site, your data is collected by our stats services. Other personal information may be volunteered by you, such as your contact details, survey information and/or any site registrations. We use this information for internal review and in order to improve the content of the Site.

We gather personal information necessary to fulfil your order such as your name, telephone number, email address and postal address and any enquiries that you provide voluntarily when you contact us by e-mail, by phone or complete any on-line forms. In order to provide you and other Site users with a personalised and valuable service we operate a voluntary personal information submission process. During submission a user is required to give contact information as described above. We may ask you to provide us with information regarding your contact preferences in order to provide you with further correspondence about our products and services. You are not obliged to provide this information and you can opt out of this correspondence during registration. Further, without prejudice to the above, we shall at all times process your information obtained via your access and use of the Site and/or otherwise in accordance with our Privacy Policy. Where we collect from you and you voluntarily submit to us your information whilst using this site, our use of your information will be governed by these terms including our Privacy Policy. Please read these terms of use and our Privacy Policy carefully before using the site.

16. Our contact details

If you have any comments suggestions or questions about these terms and/or the Site and/or us generally, please contact us by writing to:

Marketing Manager
Hazlemere Window Company
Wellington Road
Cressex Business Park
High Wycombe Buckinghamshire HP12 3PR

17. Monitoring phone calls

We may monitor and record phone calls. This will help us to improve our service and make sure we keep to our practices and procedures. Also, by recording phone calls, we can provide evidence of any agreements you enter into over the phone. Any phones calls recorded will be deleted after 30 days.

18. Complaints procedures

Hazlemere Window Company Ltd is committed to providing high-quality customer services. Where a customer has experienced dissatisfaction, we value the opportunity to remedy the situation where possible, and we then use such information to help us improve.

19. Company information

This site is the property of:

HAZLEMERE WINDOW COMPANY LIMITED
WELLINGTON ROAD
CRESSEX BUSINESS PARK
HIGH WYCOMBE
BUCKINGHAMSHIRE
HP12 3PR
Company No. 02185969

How we deal with enquiries and complaints

Hazlemere Window Company Ltd is committed to providing high-quality customer services. Following is our customer complaints procedure as we appreciate feedback from our customers. Where a customer has experienced dissatisfaction, we value the opportunity to remedy the situation where possible, and we then use such information to help us improve.

How Do I Complain?

If you are dissatisfied with an element of workmanship or customer service, then we would encourage you to speak to the individual/department concerned. They can then try to resolve any problems on the spot.

Our Main Switchboard 01494 536000 is open 9am to 5pm on weekdays (excluding Bank Holidays). Alternatively, you can complain in writing to:

The Managing Director
Hazlemere Window Company Limited
Cressex Business Park
Wellington Road
High Wycombe
Buckinghamshire HP12 3PR

When complaining, tell us:

  • Your full name and address and contract number (where applicable).
  • As much as you can about the complaint.
  • What has gone wrong.
  • How you want us to resolve the matter.

What Happens When You Have Complained?

Stage 1: Frontline Resolution
Frontline resolution aims to quickly resolve straightforward complaints that require little or no investigation.

Stage 2: Investigation
The investigation stage deals with three types of complaint: Cases that have not been resolved at Stage 1; Cases that are complex in nature and or where it is immediately apparent that detailed investigation is required;

When using Stage 2 we will:

  • Acknowledge receipt of your complaint within five working days.
  • Where appropriate, discuss your complaint with you to understand why you remain dissatisfied and what outcome you are looking for.
  • Provide a full response, verbally or in writing.

In the unlikely event of unresolved complaints Hazlemere Windows are GGF members so you can write to

The Conciliation Manager
Glass and Glazing Federation
40 Rushworth Street
London, SE1 0RB 

This Glass and Glazing Federation Conciliation Scheme is a confidential correspondence based process that exists to ensure all GGF Member Companies fulfil their agreed obligations to customers and is free to use for customers who have used a GGF Member for a domestic installation. If in a rare case a complaint is not able to be resolved by the Federation’s Conciliation Scheme, then a low-cost independent alternative dispute resolution (ADR) service is available provided through The Chartered Institute of Arbitrators. The consumer may choose to opt for this service only after at least 56 calendar days have elapsed since their complaint was first raised with the GGF Conciliation Manager. This arbitration scheme is legally binding on both the GGF Member Company and the Customer (fees are involved on both sides for this service)

Contact Details:

Hazlemere Window Company Limited
Cressex Business Park
Wellington Road
High Wycombe
Buckinghamshire HP12 3PR

Telephone: 08000 825 825

Find out about Hazlemere's Vulnerable Persons Policy

Hazlemere Window Company Ltd realises that sometimes our customers may be vulnerable as a consequence of mental or physical infirmity, age, credulity, learning difficulties, illiteracy or if their first language is not English.

Should this situation arise and it becomes obvious that the information we provide to the customer is not being understood then we will seek the involvement of a trusted friend or relative. We will re-appoint and arrange for a trusted friend or relative to be present during the next visit to the customer’s home. In addition, Hazlemere Window Company Ltd are Glass and Glazing Federation Members, which requires all its members to comply and adhere to its strict Consumer Code of Conduct, which has been approved by the Trading Standards Institute.

A separate detailed Guide to dealing with vulnerable consumers is issued to code members (see pages 2-4 below). A short summary is listed below.

Companies will take the necessary effort and time to make sure that vulnerable consumers understand all aspects of signing a contract for goods and services. Where appropriate, members must suggest the involvement of a trusted friend or relative.

Vulnerable consumers are those whose circumstances put them at risk of making an incorrect or inappropriate decision, or who are at risk of receiving inferior goods or services. Vulnerable consumers include but are not limited to those:

With a physical (or mental) disability or health problems

Who are elderly

With poor literacy or numeracy skills

Who are purchasing something at a time of particular stress or distress

Whose first language is not English, and English is the only language in which sales material is available

In addition, companies are prohibited from generating sales enquiries or new orders from the creation, obtaining, distribution, maintenance or use of lists of specific consumers that are susceptible to responding to cold calling approaches.

GGF Guidance to code members on dealing with vulnerable consumers

Code members are to attempt to identify consumers who are vulnerable or potentially vulnerable, and deal with them sympathetically and appropriately. Vulnerable consumers are those whose attributes mean they are at risk of making an incorrect or inappropriate decision, or who are at risk of receiving unsuitable or unnecessary goods or services.

Members are to take the necessary time and effort to ensure that vulnerable consumers are provided with the best possible service and extra care and support when required. Because selling in the home is common in our industry, it is important that vulnerable consumers understand all aspects of signing a contract for goods and services, including the financial implications.

Where appropriate, members must suggest the involvement of a trusted friend or relative, to assist the potential consumer before a contract is signed, and check that no undue pressure is being exerted.

Code members must:-

identify consumers who may be vulnerable

give extra support in helping them make informed choices

ensure that vulnerable consumers understand important documents such as the quotation, the contract and the guarantee.

A consumer may be vulnerable for any reason that makes it more difficult for them to fully understand the information they need in order to make an informed decision about your company’s products and service. Vulnerable consumers include, but are not limited to, those:

With a physical disability or health problems

Who are elderly

With poor literacy or numeracy skills

Who are purchasing something at a time of particular stress or distress

Whose first language is not English, and English is the only language in which sales material is available

Code members are tasked to try to identify whether a potential consumer is vulnerable or potentially vulnerable using the above list as a rough guide. Enquiries will need to be made with the consumer in a sensitive manner. Reasonable adjustments are to be made to accommodate them so they can fully understand the information they need in order to make an informed decision about your company’s products and service.

Sales visits will need to be re-scheduled if the sales agent finds on visiting that the consumer is vulnerable (which was not identified before the visit) and would like a trusted friend or relative to attend the sales presentation and assist.

Training

All code members must ensure that their employees and agents who have dealings with potential consumers have been trained in how to identify and deal with consumers who are vulnerable or potentially vulnerable.

They must be trained to carefully consider that a consumer’s vulnerability may not always be obvious immediately, as will tend to be the case when there is sight impairment, physical or mental disability, or age-related vulnerability.

Sometimes a consumer can be vulnerable due to a recent tragic event, such as a   bereavement.

The Mental Capacity Act 2005 Code of Practice is a useful reference document for code members.

Responsibilities to vulnerable or potentially vulnerable consumers

For any vulnerability which relates to physical or mental disabilities, the code member must consider the effect of the disability on the consumer’s capacity to make an informed decision on whether the products on offer are affordable and suitable for them.

Each such consumer is to be provided with details of each stage of the transaction so that an informed decision can be made. This can involve reading the contract terms and conditions to the consumer, explain clearly their right to cancel, and explaining deposit and payment terms.

Code members’ employees and agents are to be trained to take their obligations with regard to vulnerable consumers seriously, plus ensure that suitable arrangements are made in order that the consumer is provided with the best guidance and advice suitable for their needs.

Suitable products fit for purpose

Code members must ensure, via their salespersons and surveyors, that vulnerable consumers receive products that are fit for purpose in respect of their disability. Examples would be:-

An elderly person with poor reach should have window styles recommended where the window openers are within reach wherever possible, especially where a window is over a kitchen sink

The threshold height of an external door should not pose a trip hazard to a person affected by poor mobility

Sales activity

GGF Code Members are prohibited from generating sales enquiries or new orders from the creation, obtaining, distribution, maintenance or use of lists of specific consumers that are susceptible to responding to cold calling approaches.

Details of Hazlemere's Anti-Money Laundering Policy

Introduction

This policy covers the Anti-Money Laundering (AML) guidance and procedures for Hazlemere Window Company Limited

Policy Aims

To do all we can to prevent the company and its staff being exposed to Money Laundering and financial crime, to identify the potential areas where it may occur, and to comply with all legal and regulatory requirements.

Definition of Money Laundering

Money Laundering is the process by which criminals attempt to conceal the true ownership of the proceeds of their criminal activities to make it appear they have come from legitimate sources.

The Money Laundering Reporting Officer (MLRO)

The designated MLRO is Mrs Rachel Braham-Hill and can be contacted on 01494 536000 or 01494 897600 and by email r.braham-hill@hazlemere.co.uk

Responsibilities of the MLRO

To act as a control point for procedures, legislation, inspection, reporting, training

To provide guidance and training to staff on Money Laundering issues

To retain accurate and thorough records.

Awareness Raising and Staff Training

An overview of anti-money laundering responsibilities is provided to all employees handling financial applications in relation to our credit brokerage services in the first two weeks of joining the company. On an annual basis all appropriate staff are provided with refresher training to ensure they remain aware of their responsibilities.

Identifying Risk

Where a customer’s credit application is outside what we would usually expect or is unnecessarily complicated.

We must also pay regard to the size and source of an applicant’s deposit and the size of the transaction they wish to carry out.

Retention of Records All files, including evidence of verification of identity and transaction information, must be retained for six years after our business relationship has ended. If an investigation is in progress then the records must be retained until the authorities confirm the case has been closed. Records may be retained on paper of electronic medium.

Retention of Records

All files, including evidence of verification of identity and transaction information, must be retained for six years after our business relationship has ended. If an investigation is in progress then the records must be retained until the authorities confirm the case has been closed.  Records may be retained on paper of electronic medium.

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© 2019 Hazlemere Window Company Ltd.

Credit is subject to status and affordability. Terms and conditions apply. Finance on windows & doors is available to a maximum loan value of £50,000 with zero deposit. Finance on conservatories is available to a maximum loan value of £30,000 with a 15% deposit. £1,000 minimum order value applies to all finance options. Authorised and regulated by the Financial Conduct Authority. Hazlemere Window Company Limited at Cressex Business Park, Wellington Road, High Wycombe, Buckinghamshire HP12 3PR (Financial Services Registered No. 796507) is a credit broker and is authorised and regulated by the Financial Conduct Authority. Credit provided by Hitachi Personal Finance, a trading style of Hitachi Capital (UK) PLC, authorised and regulated by the Financial Conduct Authority (Registered No. 704348).