Privacy Policy
We are committed to protecting and respecting the privacy of your personal data. This privacy policy explains how your data is collected, used, transferred and disclosed by us. It applies to data collected when you use our websites, iOS and android applications, when you interact with us through social media, email, or phone, or when you participate in our competitions or events. It also applies to the extent that someone has referred you to us or purchased an e-gift card on your behalf. It covers:
The personal data we collect
How we collect your data
How we use your data
Marketing preferences, adverts and cookies
Links to other websites and third parties
How we share your data
Your rights
Changes to this privacy notice
How to contact us
OUR COMMITMENT TO YOU
We take the protection of your personal data seriously and will process your personal data fairly, lawfully and transparently. This privacy notice describes the personal data we are collecting about you and how it is used.
We will only collect and use your personal data for the following purposes, to:
keep you up to date with the latest offers and trends
give you a better business experience
help us to make our marketing more relevant to you and your interests
improve our services
meet our legal responsibilities
provide and personalize our website and applications
support, develop, troubleshoot, and debug our website and applications
provide you with information, products, or services that you request from us
create, maintain, customize, and secure your account with us
help maintain the safety, security, and integrity of our websites, applications, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
debug to identify and repair errors that impair existing intended functionality in our websites or applications
internally test, research, analyse, and develop our products and services, including to develop and improve our websites and applications, and to develop, improve, or demonstrate our products and services
carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our terms of use
fulfil any other purpose for which you provide it.
We will also use your personal information in any other way we may describe when you provide the information or for any other purpose with your consent.
HOW WE KEEP YOUR DATA SAFE AND SECURE
We have appropriate organisational safeguards and security measures in place to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.
We require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.
In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so.
THE PERSONAL DATA WE COLLECT
Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed.
The following groups of personal data are collected:
Identity Data includes information such as: first name, last name, title, date of birth, occupation, personal description, photo and gender.
Contact Data includes information such as: email address, delivery address, location, country, telephone number, membership number, and social media id (if you log in by social media).
Financial Data includes information such as: card details and bank account.
Transaction Data includes information such as: details of the fulfilment of your orders (such as title, currency, shipping, number of items, product number, item price, category, tax etc.); payments to you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders, and details of any rewards awarded.
Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
Profile Data includes information such as: orders made by you, product and style interests, preferences, feedback, and survey responses.
Usage Data includes information such as: how and when you use our website/app, how you moved around it, what you searched for; website/app performance statistics, traffic, location, weblogs and other communication data; programme activities; and details of any other products and services used by you.
Marketing and Communications Data includes information such as: 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 may be derived from your personal data but is not considered personal data as this data does 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 notice.
HOW WE COLLECT YOUR DATA
We may collect personal data about you in the following ways:
Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:
Create an account on our website;
Subscribe to our newsletter, discussion boards, social media sites or create wish lists;
Enter a competition;
Join a programme;
Complete a voluntary market research survey;
Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service);
Refer a friend to our website; or
When you log in to our website via social media.
Automated technologies or interactions – as you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.
Third parties – we may receive personal data about you from various third parties, including:
Identity and Contact data from another individual when they order an e-gift card for someone or refer a friend to our website;
Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled ‘Marketing preferences, adverts and cookies’.
Technical Data from affiliate networks through whom you have accessed our website;
Identity and Contact Data from social media platforms when you log in to our website using such social media platforms;
Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
MARKETING PREFERENCES, ADVERTS AND COOKIES
Marketing - your preferences
We may send you marketing communications and promotional offers:
if you have opened an account with us, or registered for a promotion or event, and you have not opted out of receiving that marketing (in accordance with your preferences, as explained below);
by email if you have signed up for email newsletters;
if you have provided us with your details when you entered a competition and you have consented to receiving such marketing (in accordance with your preferences, as explained below).
We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data and Marketing and Communications Data to form a view on what we think you may like, or what may be of interest to you, and to send you details of products and offers which may be relevant for you.
We may check your details with appropriate third parties. This is to ensure your information is accurate.
We will ask you for your preferences in relation to receiving marketing communications by email, post, SMS and other communication channels.
From time to time we may also include with your order, inserts advertising goods, services or offers from other third-party companies that you may be interested in.
You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us (or any third party, if applicable) at any time:
you can unsubscribe or ‘opt-out’ by using the unsubscribe button and following the link included in the footer of any marketing email; or
account holders may withdraw their consent by simply logging in to My Account and editing your ‘Contact Preferences’.
We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.
Cookies
Our website uses cookies to distinguish you from other users of our website and to keep track of your visits. They help us to provide you with the very best experience when you browse our website and to make improvements to our website. They also help us and our advertising networks to make advertising relevant to you and your interests.
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 our website may become inaccessible or not function properly.
For detailed information on the cookies which we and our third-party providers use and the reasons why we use them, please refer to our Cookie Policy.
Online ads
We may use online advertising to keep you aware of what we’re up to and to help you find our products and services. Like many companies, we may target banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage and Profile Data. We may do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience Service.
Our use of analytics and targeted advertising tools
We may use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps (as described above) to you, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we may use tools such as Google Analytics to analyse Google's interest-based advertising data and/or third-party audience data (such as age, marital status, life event, gender and interests) to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties, such as Facebook, Content Square, Adroll, Bloomreach, Criteo and Bing to perform similar tasks, using your Contact, Technical, Usage and Profile Data.
In order to opt out of targeted advertising you need to disable your ‘cookies’ in your browser settings (see Cookie Policy for details) or opt-out of the relevant third-party Ad Settings.
LINKS TO OTHER WEBSITES AND THIRD PARTIES
Our website may include links to and from the websites of our partner networks, advertisers and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.
HOW WE SHARE YOUR DATA
We may disclose and share your personal data with the parties set out below:
where you have consented for us to do so. For example, if you have consented to receive marketing materials from third parties, or in respect of third parties’ (including co-branded or jointly promoted) products and services, we may pass your data on to the relevant third parties for the purpose of sending you such marketing communications;
to business partners, suppliers, sub-contractors and other third parties that we use in connection with the running of our business for the purposes set out in the above section ‘How we use your data’, such as:
third party service providers that we engage to provide IT systems and software, and to host our website;
third party payment processing services. These third party payment providers process your data as a data controller;
third party service providers that we engage to deliver and process your e-gift card orders
third party service providers that we engage to deliver goods you have ordered and to manage any returns;
third party service providers that we engage to send emails and postal mail on our behalf including marketing communications, to provide data cleansing services and to provide marketing and advertising services;
analytics and search engine providers that assist us in the improvement and optimisation of our website;
affiliate networks through whom you have accessed our website;
to any third party 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 notice.
to protect our customers, company and website from fraud and theft, we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your age, name and location), together with account information, with other companies and with third party organisations (including law enforcement agencies), involved in fraud prevention and detection;
we may share your personal data with fraud prevention and analysis service providers, in order to carry out fraud prevention checks on our behalf.
Please note that these third parties may retain a record of the information that we provide to them for this purpose;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
to our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
ACCESSING, CORRECTING, AND DELETING YOUR PERSONAL DATA
You can review and change your personal data by logging into your account and visiting your account profile page. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change or delete your personal data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.
JURISDICTION-SPECIFIC PRIVACY RIGHTS
The law in some jurisdictions may provide you with additional rights regarding our use of personal data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your state that is attached to this privacy notice.
YOUR GDPR PRIVACY RIGHTS
If you are a resident of the European Economic Area, Switzerland, or the United Kingdom, you have the additional rights described in our GDPR Privacy Addendum.
Changes to this privacy notice
From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, applications or let you know by email.
GDPR PRIVACY ADDENDUM
This GDPR Privacy Addendum (the “GDPR Privacy Addendum”) supplements the information contained in our privacy notice and applies solely to customers and users of our websites, iOS and android applications, individuals who interact with us through social media, email, or phone, and individuals that participate in our competition and events that are located in the European Economic Area, the United Kingdom, or Switzerland. We adopt this GDPR Privacy Addendum to comply with the European Union’s General Data Protection Regulation, and any laws implementing the foregoing by any member states of the European Economic Area, the United Kingdom (including the UK Data Protection Act and the UK-GDPR), and or Switzerland (collectively, the “GDPR”). Unless otherwise defined in this GDPR Privacy Addendum, any terms defined in the GDPR or our privacy notice have the same meaning when used in this GDPR Privacy Addendum. When this GDPR Privacy Addendum is applicable to you, it takes precedence over anything contradictory in our privacy notice.
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 we wish 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. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law.
How long we keep your data for
We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.
YOUR DATA AND COUNTRIES OUTSIDE OF THE UK
The personal data we collect from you may be transferred to, and stored at, destinations outside the UK using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.
Whenever we transfer personal data outside the UK, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place. We will be able to transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
YOUR RIGHTS
You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to:
request access to your personal data
request correction of your personal data
request erasure of your personal data
request restriction of processing of your personal data
request the transfer of your personal data
object to processing of your personal data
request human intervention for automated decision making
We will try to respond to all legitimate requests within one month. Occasionally, it may 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. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
CHANGES TO THIS PRIVACY NOTICE
From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, applications or let you know by email.