- What personal information do we collect and how do we use it?
Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law. In particular, we use your personal information for the following purposes:
- Fulfilment of products and services
We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. We use the contact and payment details you have provided to us so that we can fulfil the supply of products and services you have ordered from our Site. This includes your purchase of products, your attendance at events hosted by us or our third party partners, personal shopping appointments, alterations to products and customisations to products, such as engraving and monogramming, processing of returns and refunds and tax free rebates.
Who do we share your personal information with for this purpose?
We may share your personal information with the following categories of third parties:
- To verify card payments and process refunds – credit card companies and other payment providers;
- To deliver products and process returns – delivery and courier companies;
- Events – any applicable third party hosting the event; ticketing companies such as Eventbrite;
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.
- Client service enquiries
Our Site uses various user interfaces to allow you to request information about our products and services: these include electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.
Who do we share your personal information with for this purpose?
We do not share your personal information for this purpose.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.
- Your feedback about our products and services
From time to we will contact you to invite you to provide feedback about our products and services in the form of online, postal or in-store surveys. We use this information to help us improve the quality of service provided by our staff and in our stores. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.
Who do we share your personal information with for these purposes?
We do not share your personal information for this purpose.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
- Customer insight and analysis
We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services in our stores, such as the products and services you have purchased or viewed.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:
- an IP address to monitor Sites traffic and volume;
- a session ID to track usage statistics on our Sites;
- information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.
- Cookie policy
Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of offers our registered users like to see.
We also use this information to help us with the selection of future product and service lines, store and websites design and to remember your shopping preferences such as garment size.
We also use this information for marketing purposes (see the marketing section below for further details).
Who do we share your personal information with for these purposes?
We may share your personal information with a variety of third party service providers to assist us with customer insight analytics. These providers include those described in our cookie policy.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.
We will only use your location data for customer insight purposes where we have your consent to do so.
- Marketing communications.
We carry out the following marketing activities using your personal information:
- Online personalised advertising.
We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products [and services in our stores] (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized online advertising.
Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party service providers who assist us with our online personalised advertising campaigns. These providers are described in our cookie policy.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
- Social media remarketing
We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our stores (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services.
We do this using Facebook Customer Audiences and/or Google Customer Match respectively [others?]. Please note that such activity is also subject to the privacy choices you have elected to make on such services.
Who do we share your personal information with for these purposes?
We share your email address with third party service providers who assist us with social media remarketing campaigns.
Your encrypted email address is also shared by us or our third party service providers with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match services respectively.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only engage in social media remarketing where you have consented to us [using your email address] [sharing your email address in an encrypted format with Facebook and/or Google respectively] for marketing purposes.
- Social media insight
Where you are a registered user of Facebook, or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:
- information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our stores (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and
- the information Facebook and/or Google hold about you.
We do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.
Who do we share your personal information with for these purposes?
We share your email address with third party service providers who assist us with social media remarketing campaigns.
Your encrypted email address is also shared by us or our third party marketing consultancies with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match respectively.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
- Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- protect rights of third parties; and
- in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so.
- Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
- How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
- at the time we collect your personal information following the instructions provided; or
- by informing us by e-mail or post using the contact details set out in this Privacy
- Our use of cookies and similar technologies
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our cookie policy to find out more about the cookies we use and how to manage and delete cookies.
- Third Party Links and Services
Our Sites contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.
Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.
- How long do we keep your personal information for?
We keep your personal information for a period of three (3) years from the date of our last interaction with you.
If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
- Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
- How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
- Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing.
- Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
- Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
- Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113
- Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18. It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by e-mail or post using the contact details set out in this Privacy Policy.
- Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time.
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.
Privacy Policy Effective Date: December, 2022