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OUR PRIVACY PRINCIPLES

We have 5 Privacy Promises which explain how we use and look after your information. We will:

1. ALWAYS use your personal data in line with data protection law.
2. ALWAYS tell you what information we collect, what we do with it, who we share it with and who to contact if you have any concerns.
3. ALWAYS provide options to say “STOP” if you don’t want marketing communications.
4. ALWAYS take steps to protect your information and make sure no unauthorised person accesses it.
5. ALWAYS respond to questions about your personal data without delay.

OUR PRIVACY POLICY

We are committed to safeguarding your privacy rights and ensuring that your personal data is protected.

This Privacy Policy explains the types of personal data we collect and how we process and protect that data in connection with the services we offer. This includes information collected offline in our stores or through our customer services, and online through our websites, applications (including mobile apps) and third party platforms (“Sites”).

1. WHO IS RESPONSIBLE FOR WHAT HAPPENS WITH YOUR DATA?

Company () are responsible for processing your personal data on our Sites.

2. HOW DO I CONTACT THE DATA PROTECTION OFFICER?

If you have a question in relation to how we process your personal data you can contact our Data Protection Officer via email [email protected].

3. WHAT IS PERSONAL DATA?

Personal Data means information that can directly or indirectly identify you (“Personal Data”). This typically includes information such as your name, address, email address, and telephone number, but can also include other information such as IP address, shopping habits, and information about your lifestyle or preferences such as your hobbies and interests.

4. WHAT HAPPENS WHEN YOU PROVIDE US WITH YOUR PERSONAL DATA OR WHEN WE OTHERWISE RECEIVE YOUR PERSONAL DATA?

We collect your Personal Data directly in a number of ways, for example when you provide us with your information to register as a customer for our Sites, register for prize draws or competitions, subscribe to our newsletter, receive information or mailings, use our applications, buy a product or service from us, complete a survey, make a comment or enquiry or contact our Customer Services Team.

When you provide us with your Personal Data, we will process it in accordance with this Privacy Policy. If you do not wish us to process your Personal Data in this way, please do not provide us with your personal information.

We may also receive your Personal Data from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties. If you do not want us to receive your Personal Data from other sources, please communicate your preferences directly with the relevant sources.

We process your Personal Data to provide you with our services as further explained below. In certain instances, we only process your Personal Data if you have given us permission to do so, for example in most cases where we process your Personal Data for marketing purposes, use cookies or location data or where we process your sensitive personal information. In other instances we may rely on other legal grounds for processing your personal data, such as performance of the contract with you or legitimate interests, like fraud prevention.

You can always opt out of marketing communications without detriment to your loyalty benefits.

Where we process your Personal Data on the basis of your consent, we will ask for your consent explicitly and only for a particular purpose. We will also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy.

5. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

5.1 WE PROCESS THE FOLLOWING CATEGORIES OF PERSONAL DATA FOR THE FOLLOWING PURPOSES:

• Browsing on our Sites
• Purchase/Agreeing to a Service
• Customer Service
• Suggesting products & services which may interest you
• Competitions and prize draws
• Online Shopping

WHAT PERSONAL DATA MAY WE COLLECT?

Information about the type of browser you use when visiting our Sites, your IP and device address, hyperlinks that you have clicked, websites you visited before arriving at our Sites and information collected by cookies or similar tracking devices. Your user name, profile picture, gender, networks and any other information you choose to share when using Third Party Sites (such as when you use the “Like” functionality on Facebook).

WHAT IS THE PURPOSE OF THE PROCESSING?

We (and third party service providers acting on our behalf) use cookies and similar technologies to process data about you when you visit our Sites. We would like to know whether you have visited us before and your preferences to provide you with a tailored experience of our Sites.

See Section 5.2. below for more information about cookies.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

Please check the Cookie Consent Tool to learn about the storage periods for each cookie.

WHAT IS OUR LEGAL BASIS FOR THE PROCESSING?

Your consent when you click “agree and proceed” in our Cookie Consent Tool in our Sites. In some cases, and always when permitted by law, we will infer from your actions that you agree to Cookies. Please note that we need to process certain basic surfing data in order to provide core Sites functionalities such as secure log-in or remember how far you are through an order.

You can always revisit your cookie preferences via our Cookie Consent Tool or by changing your browser settings.

5.2 COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies (“Cookies”) to improve our products and your experience on our Sites by collecting information on how you use our Sites. Some of the Cookies we use are required to enable core site functionality, for example to provide secure log-in or to remember how far you are through an order, but we also use Cookies that allow us to analyse site usage (so we can measure and improve performance), and advertisement Cookies which are used by advertising companies to serve ads that are relevant to your interests.

We may also tailor our Sites and our products to your interests and needs, by collecting information about your device and linking this to your Personal Data so as to ensure that our Sites present the best web experience for you.

Where we use Google Analytics, we have set up the service to anonymise your IP address as soon as data is received by the Analytics Collection Network, before any storage or processing takes place.

You can view more information on the Cookies we use and adjust your preferences via the Cookie Consent Tool on our Sites. Please note, however, that without cookies you may not be able to use all of the features of our Sites or online services.

6. WHO WE SHARE YOUR PERSONAL DATA WITH?

6.1 OUR SERVICE PROVIDERS

We share your Personal Data with with the following data processors (i.e. service providers that help us to perform the above tasks):

• Trusted third parties to help us process and analyse your Personal Data for us, to support us when suggesting products & services which may interest you in line with Section 5.1 above.
• If you order a product or service from us, trusted third parties to allow payment and delivery of the products and services you have ordered. Unless you provided consent, any such trusted third parties are not authorised by us to use your Personal Data in any other way and will be required by us to implement adequate technical and organizational measures to protect your Personal Data.

These processors are bound by us to strict requirements as required under applicable data protection laws to only handle your Personal Data for us and to comply with high IT security standards.

6.2 OTHER RECIPIENTS

We share your Personal Data with the following third parties that process your Personal Data for their own purposes (i.e. these third parties are no processors; they rather use your Personal Data because they have their own interest or because you had consented):

Law enforcement or other agencies if we are required to do so by law, or by a warrant, subpoena or court order to disclose your Personal Data.

Please note that we never share your Personal Data with social media platforms. When we engage in audience building or customer matching activities with social media platforms like Facebook or Google, your Personal Data is always anonymised before the transfer. If there are any changes in the future and we have to share your Personal Data with a social media platform, we will ask for your consent.

6.3 SHARING YOUR SITE USAGE INFORMATION

With your consent, we will share Site usage information with trusted third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you tailored content which may be of interest to you based on your prior activity on our Site. These trusted third parties may set and access their own Cookies, web beacons and similar tracking technologies on your device in order to help us deliver customised content and advertising to you when you visit our relevant Sites. Please see Section 5.2 for more information about Cookies and how to opt out.

Please note that even if you opt out, you may still receive advertisements from us that are not customised based on your Site usage information.

7. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired as further described in Section 5.1.

8. WHAT ARE YOUR RIGHTS?

If certain requirements are fulfilled, you have the right to:

• Obtain from us confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data;
• Rectification of inaccurate Personal Data;
• Erasure of Personal Data;
• Objection to the processing of Personal Data;
• Restriction of processing of Personal Data;
• Portability of Personal Data – receive the Personal Data you have provided to us in a structured, commonly used and machine-readable form and transmit it to another data controller.

You can learn more about these rights from the GDPR provides the following rights for individuals:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

To exercise your rights, please contact the Data Protection Officer (see Section 1 for contact details) or get in touch with our Customer Services Team on the details set out below.

Note that you do not need to contact our Data Protection Officer to excerise your rights to stop receiving marketing communications from us. You can opt out of receiving such communications by going to the Marketing Preferences of your ‘My Account’ if you have an account with us, directly from the communications we send you or by contacting our Customer Services Team or by sending an email to.

9. CAN YOU WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL DATA?

Where your consent is the legal basis for the processing of your Personal Data, you can withdraw your consent for:

• Marketing communications: by logging into your account under Marketing Preferences or using the unsubscribe link in any of our marketing communications.
• Use of Cookies: via our Cookie Consent Tool at the bottom of our Sites.
• Other purposes: by sending us an emai or by contacting our Customer Services as listed in Section 8

Please note that withdrawing your consent will not affect the lawfulness of the processing before the withdrawal.

10. CAN YOU COMPLAIN WITH THE DATA PROTECTION AUTHORITIES?

If you think that the processing of Personal Data by us violates data protection laws, you can lodge a complaint with the Information Commissioner.

11. HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain appropriate technical and organisational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data.

12. CAN WE CHANGE OUR PRIVACY POLICY?

We may change this Privacy Policy from time to time by posting the updated version of the Privacy Policy here. We encourage you to visit this area frequently to stay informed.