PRIVACY POLICY

Annoushka Limited (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and ongoing compliance with the relevant National and European data protection Regulation and laws, namely the Data Protection Act 2018 and the GDPR, effective as of 25th May 2018. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

Annoushka Limited’s registered office is at 41 Cadogan Gardens, London SW3 2TB and we are a company registered in England and Wales under company number 6370631. We are registered on the Information Commissioner’s Office Register; registration number Z1471775, and act as the data controller when processing your data.

Annoushka Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

When you register for our services, you may provide us with:

• Your personal details including your billing and postal address, email address, phone numbers, date of birth and title.
• Your account login details such as username and password that you have chosen

When you shop with us online or browse our websites, we may collect:

• Information about your online purchases E.g. what you have bought, when and where you bought it and the method it was paid with
• Information about your online browsing behaviour on our websites including when you click on one of our adverts or those shown on other organisations’ websites
• Information surrounded the devices you use to access our website and services including IP address, the make, model and operating system, browser type and mobile device identifiers

When you use an Annoushka gift card or voucher, we may collect:

• Transaction information including whether the purchase was made in store or online, personal details including your billing and postal address, email address, phone numbers and title.

When you contact us or we contact you with promotions, competitions or reviews about our services, we may collect:

• Personal data you have provided when you have contacted us about our services E.g. name, username and contact details. This can come via phone, email, post or correspondence through social media
• Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
• Your feedback on our services to customer services or our boutique representatives

When you visit our boutiques or stores:

• Footage of you may be recorded on our CCTV systems

We may use personal data from other sources such as online media channels including websites, social media sites and our retail partners. This personal data helps us to:

• Improve and measure the effectiveness of our marketing communications
• Review and improve the accuracy of the data we hold

We collect information in the below ways:

• Website orders
• Newsletter sign up
• Employment CVs
• Livechat, Whatsapp and Hero queries
• Catalogue request online form
• Contact us online form
• Chain letters request online form
• Competition entry forms
• Customer service emails and calls

Annoushka Limited takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing

you with promotional offers and marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data are detailed below: -

We use personal data to make our services available to you:

• Manage the accounts you hold with us
• Process your orders and refunds

Why do we process your personal data in this way?

We need to process your data so we are able to manage your customer accounts, provide you with the services and goods you want to buy and help you with any orders and refunds you may ask for.

Manage and improve our day-to day operations

• Manage and improve our websites

Why do we process your personal data in this way?

We use cookies and similar technologies on our websites to improve your customer experience. Some of these cookies are necessary; however others can be disabled should you wish to disable them. Please bear in mind that this may affect your overall customer experience. For more information on cookies and the ones we use, please see below under the ‘Cookie Notice’ section.

• To help develop and improve our services, stores, product range, information technology systems, know-how and the way we communicate with you.

Why do we process your personal data in this way?

We use your personal data to carry out internal research and development as well as market research, and to improve our product range, services, stores and information technology systems (including security). This allows us to serve you better as a customer.

• To detect and prevent fraud or other crime

Why do we process your personal data in this way?

It is crucial for us to monitor how our services are used to detect and prevent fraud, misuse of services and crime. This helps us to ensure you can safely use our services.

• We use your online browsing behaviour, online and in store purchases to help us better understand you as a customer and to provide you with personalised offers and services.

Why do we process your personal data in this way??

Looking over your purchases and browsing behaviour allows us to personalise our services and offers to you, thus further meeting your needs as a customer.?

• Provide you with relevant marketing communications including online advertising, post and emails/newsletters relating to our products and services. As part of this, online advertising may be displayed on websites across other organisations’ websites and online media channels. We may also measure the effectiveness of our marketing communications.

Why do we process your personal data in this way?

We want to ensure we provide you with marketing communications and online advertising that are relevant to your interests. To do so, we measure your responses to marketing communications relating to services and products we offer which in turn, helps us to offer you better suited products and services to meet your needs as customer. You can change your marketing preferences at any time. You also have choices when it comes to online advertising. You also have choices when it comes to online advertising. We set out below your choices when it comes to cookies under our ‘Cookie policy’ section, and how you can control your online behavioural advertising preferences.

Contact and interact with you

• Contact you about our products and services either by phone, email, post or by responding to social media posts directed at us.

Why do we process your personal data in this way?

In order to serve you better as a customer we use your data to provide assistance in response to your communications or to provide further clarification surrounding your orders and queries.

• Manage competitions you take part in as well as to manage promotions

Why do we process your personal data in this way?

We need to process this data so we can manage the competitions and promotions you choose to enter.

• Invite you to partake in customer reviews, surveys and other market research activities to further improve your customer experience.

Why do we process your personal data in this way?

We carry out market research to improve our products and services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our services.

• In order to resolve disputes or legal claims involving you or us

Why do we process your personal data in this way?

If you have any accident or there is an incident in our stores, this could include medical reports.

• To monitor the safety of our boutiques and concessions in order to prevent and detect anti-social behaviour and detect crime.

Why do we process your personal data in this way?

In order to protect our customers, colleagues, the local community and to protect our business.

To further help us to better understand you as a customer and to be able to provide you with services and marketing communications, including online advertising that are relevant to your interests we also combine personal data we collect when you make purchases in store with personal data collected from our websites and other sources.

In relation to the headings mentioned in the section above (“how and why we use your personal data”), our legal basis for processing your personal data is:

Make our Services available to you

Legal Basis:

• Contractual Necessity – at the time we collect it:
• Purchase & transaction data;
• Contact details;
• Profile details;
• Delivery/collection details.

We will not be able to provide you with your products or services if you do not provide us with this data.

• Legitimate Interests - following fulfilment of your order for the other personal data in that section.
• Manage and improve our day-to-day operation
• Personalise your Annoushka experience
• Contact and interact with you
• Claims
• Bringing or Defending Legal Claims
• CCTV
• Medical Necessity

Our Legitimate interests in using your personal data

Where we have mentioned above our use of your personal data is based on our “legitimate interests”, there are:

• To service your needs, including delivering our services and products
• To promote and market our services and products
• To service your account, manage complaints and resolve disputes
• To understand our customers including their patterns and behaviours including likes and dislikes
• To protect and support our shareholders, customers, colleagues and business
• To prevent and detect anti-social behaviour, fraud and other crime
• To test and develop new products and services as well as improve existing ones

We do not share or disclose any of your personal information without your consent, other than for the purposes

specified in this notice or where there is a legal requirement. Annoushka Limited uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

• Adyen

Adyen are our online payment gateway who perform our security checks and act as a processor on our behalf. The only information we provide them with is your name, address and order details to meet business and legal requirements.

For more information about Adyen, please read their Privacy Notice at

https://www.adyen.com/policies-and-disclaimer/privacy-policy

• Ometria

Ometria act as our content relationship manager and email distributor acting on our behalf to send our emails and newsletters, as well as manage our customer data. The only information we provide them with is your name, email, address, order history and details to meet business and legal requirements.

For more information about Ometria, please read their Privacy Notice at

https://www.ometria.com/privacy-policy/

• Couriers and Delivery Providers

We have a number of couriers and delivery providers that act on our behalf delivering your order from our door to yours. These include; Prestige Cars and Couriers, DHL, FedEx, and Royal Mail. The only information we provide them with is your name, phone number and delivery address, as well as the details surrounding your order.

For more information on each individual courier, please refer to their Privacy Notices.

• Tryzens

Tryzens act as our system integrator assisting with website updates and integrations. Though they do not directly handle customer data, they do have visibility to the information surrounding your orders.

For more information about Tryzens, please read their Privacy Notice at http://tryzens.com/privacy-policy/

• Hero

Hero act as our online personal shoppers whereby the system has access to your IP address, name should you wish to give this, telephone number or email.

For more information about Hero, please read their Privacy Notice at https://www.usehero.com/privacy/

• NMPi

NMPi run our Google shopping feed, display ads, paid social and PPC. To run and build campaigns, the data used is sourced from Google and Facebook data. In rare cases, we may share emails with them in order to run specific campaigns.

For more information about NMPi, please read their Privacy Notice at https://nmpidigital.com/privacy-policy/

• Rakuten

Rakuten are our affiliate network, though there is no email sharing between us and them, they can view sales that they have brought to the business, data of which is anonymised on their side.

For more information about Rakuten , please visit their website at https://www.rakuten.com/

• Hotjar

Hotjar acts as an analytical system that reads our customer behaviour, heatmapping most popular areas across our site that have been clicked on by the customer. You can opt out via their ‘Do not track’ feature however this can affect your overall personal experience.

For more information about Hotjar , please read their Privacy Notice at https://www.hotjar.com/legal/policies/privacy

• Google Analytics

Google Analytics tracks customer behaviour and is used in order to help us personalise our services and marketing to our customers.

For more information surrounding Google, please read their Privacy Notice at https://policies.google.com/privacy?hl=en&gl=uk

We may share your personal data with other organisations in the following circumstances:

• If the law or a public authority says we must share the personal data or for the administration of justice
• If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud)
• Where we restructure, sell or transfer our business (or part of it). For example in connection with a merger or takeover.

Annoushka Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: -

• Physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data;
• We protect the security of your information while it is being transmitted by encrypting it;
• We use computer safeguards such as firewalls and data encryption to keep this data safe;
• We only authorise access to employees and trusted partners who need it to carry out their responsibilities;
• We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security;
• We will ask for proof of identity before we share your personal data with you

The personal data that we collect from you may be transferred to and stored at a destination outside the EEA (European Economic Area). It may also be processed by companies operating outside the EEA who work for us or one of our service providers. If we do this, we ensure that your privacy rights are respected in line with this policy.

You are not obligated to provide your personal information to Annoushka Limited however, as this information is required for us to provide you with our services, deliver your products and legitimate interests, we will not be able to offer our services without it.

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your

personal information under the legitimate interests’ legal basis. Where this is the case, we have

carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your

interests and any risk posed to you against our own interests; ensuring that they are proportionate

and appropriate.

Annoushka Limited will occasionally send you products, services and promotions by email or post that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.

If you would prefer not to receive above-mentioned marketing and offers, please contact us directly or by unsubscribing from our newsletters.

Annoushka Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such data until

you notify us otherwise and/or withdraw your consent.

Occasionally, Annoushka Limited would like to contact you with products, services and promotions that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting Annoushka Limited directly via phone or in writing.

We also like to hear your views to help us to improve our Services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings,

however if you disable cookies you may find this affects your ability to use certain parts of our website or services.

- CART: The association with your shopping cart.
- CURRENCY: Your preferred currency.
- CUSTOMER: An encrypted version of your customer ID with the store.
- CUSTOMER_AUTH: An indicator if you are currently logged into the store.
- EXTERNAL_NO_CACHE: A flag, which indicates whether caching is disabled or not.
- FRONTEND: Your session ID on the server.
- GUEST_VIEW: Allows guests to edit their orders.
- LAST_CATEGORY: The last category you visited.
- LAST_PRODUCT: The most recent product you have viewed.
- NO_CACHE: Indicates whether it is allowed to use cache.
- STF: Information on products emailed to friends.
- USER_ALLOWED_SAVE_COOKIE: Indicates whether a customer has granted permission to use cookies.
- VIEWED_PRODUCT_IDs: The products that you have recently viewed.
- WISHLIST: An encrypted list of products added to your wishlist.
- WISHLIST_CNT: The number of items in your wishlist.

For more information about cookies visit https://www.aboutcookies.org.

Your choices when it comes to Cookies

You can use your browser settings to reject or accept new cookies and to replace /delete existing cookies. You can also set your browser to notify you each time new cookies are placed on your computer or other device. You can find more detailed information about how you can manage cookies through your browser's help function. You can disable cookies using this tool: http://optout.aboutads.info/

If you choose to disable some or all Cookies, you may not be able to make full use of our website. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

You have the right to access any personal information that Annoushka Limited processes about you and to request information about:

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us

to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

If you have any questions about how we collect, store and use your personal data please contact us at subjectaccessrequests@annoushka.com