FRESH CLEAN THREADS 

PRIVACY AND COOKIES NOTICE 

Last updated 2023/10/16

FRESH CLEAN THREADS (UK) LIMITED (also referred to in this notice as "we", "us", "our") are committed to protecting and respecting your privacy. We are the data controller for Personal Data  that we collect about you. 

This notice explains how we use any Personal Data (as defined below) we collect from you or that you provide to us when you visit our website, [freshcleanthreads.co.uk], buy or subscribe to our products and services, contact us or otherwise engage with us (together the "Services"). 

Please read this notice carefully.

You should also review our Terms and Conditions to understand other aspects of our relationship with you.

This notice covers:

• Personal Data we collect about you 
• Personal Data you give us
• Personal Data we receive about your use of the Services
• Personal Data we may receive from other sources
• How we use your Personal Data
• Lawful basis for processing Personal Data
• Cookies and other technologies
• Customer match services
• Links to other websites
• Who we share your Personal Data with
• Payment processing
• Processing your Personal Data outside the UK and the EEA
• How we protect your Personal Data
• How long we keep your Personal Data
• Your rights
• Changes to this notice
• Contact us 

Personal Data we collect about you

When you use our Services, engage with us through social media channels or online adverts, or otherwise engage with us, we collect information from you including Personal Data. 'Personal Data' means information from which you may be identified both directly (from that information alone) and indirectly (when different pieces of information are combined). 

We may collect and process the following Personal Data from you in the following ways:

Personal Data you give us

• Name and contact information – we will collect name and contact information you provide to us, such as Personal Data provided to us when you make a purchase, complete a 'contact us' form, submit a question, sign up to receive our marketing communications, or, where you otherwise correspond with us, by email or through our live chat support. We will not be able to fulfil your order unless you provide certain name and contact related information. 
• Order and product details – to process your purchase, we will need to collect your name, billing address, shipping address, phone number (optional) and email. We will generate a unique order ID associated with your purchase.
• Account login details – if you choose to create an account we will collect your name, email address, and your chosen password. Certain login information may also be generated by us, such as a unique customer number which we assign to your account.
• Account profile details – you can provide additional optional personal details such as your preferred clothing 'style' and size. Where you choose to provide such Personal Data, it will be collected.
• Reviews and Surveys – if you leave a review about your experience of our Services or participate in a survey then, in addition to any order details we already hold, we (and our relevant third party service provides) will collect the information and / or photos which you provide in connection with sharing your experiences. For example, we use Okendo to manage our customer reviews. For more information on how they handle your personal data please see Okendo's Privacy Policy.

If you reach out to us via a third party, for example, if you send us a direct message on a social media platform, we may also collect your name and information related to your social media profile which is visible in the message. We will only be able to see the information which you have selected can be displayed to us. Please consult your social media profile settings for more details.

When we take a payment from you, we don't process your financial information. This is handled by a third party but we may be provided with some parts of your financial information related to the transaction such as the last four digits of you card and your billing address. We will not be able to fulfil your order unless you provide certain payment related information. 

We will indicate whether information including Personal Data is required by the Services.

Personal Data we receive about your use of the Services

• Technical information such as the Internet Protocol (IP) address used to connect your device to the Internet, browser type and version, browser plug-in types and versions, operating system, your device make and model. As well as the content of a request we also receive information associated with the request such as time zone setting, date and time and http status code associated with your device.

• Interaction information about your use of the Services including the full Uniform Resource Locators (URL), clickstream to, through and from our Services (including date and time), products and content you viewed or searched for, content response times, download errors, length of visits to certain content, interaction information (such as scrolling, clicks, and hover-overs), time and date of orders and methods used to browse away from content.
• Location data – we may derive your approximate regional location from your IP address.  We do this in order to localise our Services to you (for example, to provide you with your local currency and language), and make sure the products and services displayed to you are accurate for your location as some products and services may not be available in all locations.

For more information about how we process this information, please see our Cookies and other technologies section.

Personal Data we may receive from other sources

• Social media platforms such as Facebook, Instagram, and Twitter. If you interact with us through third party sites, such as social media platforms, we may collect Personal Data from you. For example, if you tag us in a social media post or otherwise interact with our social media adverts, accounts and posts (for example, by liking or providing a comment on our post on a social media platform), we may collect Personal Data such as your social media profile name and picture, as well as the pictures or content you post (including likes and reactions to your posts). We will only be able to see the content you post to your social media account if your profile is set to "public" or if we are "following" you.

• We may also receive your Personal Data from third party providers and partners which we work with, including our advertising partners and networks. For more information about how we process this Personal Data, please see our Cookies and other technologies section.

How we use your Personal Data

We will use your Personal Data to:

• deliver our Services to you as requested, including the display of our website
• take steps to fulfil a contract which you have requested (e.g., sending our products to you)
• administer our Services, including any account you may have with us
• manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• keep our Services safe and secure
• measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
• improve our products and Services 
• ensure that content is presented in the most effective manner for you and for your computer
• allow you to participate in interactive features of our service, when you choose to do so
• analyse your use of the Services and interaction with us
• provide you with information or a service you request (for example, send you an e-gift card or to reply to a customer service question)
• work with third parties (which will include sharing your Personal Data) as described below
• understand where you are accessing our Services from to deliver location specific content to you
• facilitate payment to be taken from you (payment processed by a third party) and record the transaction in our records
• interact and facilitate user generated content to be administered on the Services
• enable Cookies and other similar technologies to work (together with third parties)
• send you promotional emails
• deliver personalised recommendations of products 
• analyse your interaction with social media platforms and our content 
• advertise to you when you visit social media platforms such as Instagram, including by using customer match services as further described below

We may combine Personal Data collected directly from you (including automatically collected information) with Personal Data collected from other sources for these purposes. 

Lawful basis for processing Personal Data

We process your Personal Data where we have a lawful basis under UK data protection law for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interests of others.

Where we need your Personal Data to fulfil a contract with you (or take steps to fulfil that contract), if you do not provide some Personal Data we may not be able to progress or fulfil that contract with you.

"Legitimate interests" is a legal term used in UK data protection law. When we rely on legitimate interests, we mean in pursuing our own interests we have considered your rights and interests at the same time, and concluded that these are not overridden by your rights.

If we rely on your consent to process your Personal Data, we will ask for this before processing.

Below we set out examples of why we process your Personal Data and lawful bases for doing so:

• to take steps to enter into any contract or carry out our obligations arising out of a contract with you, such as:

• process your order or subscription;
• provide you with the product you requested from us 
• administer your account with us
• notify you about changes to our Services
• keep a record of orders you place, including recording receipt of payment, returns or refunds
• fulfil the terms of our loyalty scheme or competitions or promotions we run
• fulfil the terms of our gift cards or vouchers

Where information is required to conclude the contract, this will be indicated to you.

• to ensure in our legitimate interests that:

• content from our Services is presented in the most effective manner for you and your device 
• we provide relevant and tailored content to you
• we are able to improve the Services
• we can understand how you engage with us 
• we can analyse how the Services are used and which products and services are most popular, for example
• we provide the information you request from us, including responding to any queries you have submitted

Where permitted in our legitimate interest, or with your prior consent where required by law, we will use your Personal Data for marketing analysis or to provide you with promotional update communications by email and SMS about our products, events, newsletters and services. 

Where required, when you give your consent (for example, for us to send you our marketing communications and deliver certain Cookies). Please see "Your rights" section below for further information.

Cookies and other technologies

We use cookies and other similar technologies to collect and store certain information about you which includes Personal Data. These technologies include cookies, pixels, web beacons and JavaScript (together "Cookies"), they typically involve storing pieces of information or code transferred to or accessed from your device to store and, sometimes, record information about your interaction with online services from your device. 

Cookies and similar technologies enable you to be remembered when using that device to interact with online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content. They allow us to distinguish you from other users of our Services which helps us to provide you with a good user experience and also allows us to improve our Services and see how they are performing. Cookies also allow us to secure areas of our Services, remember items in your shopping cart, deliver your preferences and personalised content and deliver ads to you online. 

A number of Cookies and similar technologies we use last only for the duration of your online session and expire when you close your browser. Others are used to remember you when you return to our Services and will last for longer. Some Cookies will also record where you came to our Services from and where you visit once you have left. 

We use Cookies and/or other similar technologies, either alone or in combination with each other, to create a unique ID which corresponds to you. 

When you first interact with our Services, you will be notified that we use Cookies and we will ask for your consent to use non-essential Cookies. This banner will also allow you to decide which non-essential Cookies you want to accept. We also give you information about how to disable Cookies below. Where you change your browser settings to generally disable all Cookies, you may not be able to take full advantage of our Services and some aspects may not work without some Cookies being used.

We use these Cookies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), or where you have consented to their use.

We use the following types of Cookies:  

We work with the below third-party providers to deliver Cookies:

• Google Analytics, DoubleClick and AdWords – we use Google Analytics to distinguish visitors to our Services, to measure traffic on Services, deliver a secure service and ensure that we can deliver our content to you. We also use Google Cookies to deliver our ads to you. This also helps us understand the high-level demographics of visitors to our Services and helps us understand how many users click on our ads, go on to buy our products, etc. Your Google preferences may also be stored by these Cookies, for example, preferred language and number of search results you see per page. We also use Google to help determine how ads perform within certain market segments. You can learn more here including about how to opt-out at the below links:

• https://policies.google.com/privacy   
• https://tools.google.com/dlpage/gaoptout  
• https://adssettings.google.com 

• Segment.com – we use Segment.com to serve Cookies to improve our understanding of how users interact with the Services– more information can be found at https://segment.com/docs/legal/privacy/.
• Count.ly – we use Count.ly to understand how users interact with our Services. We use this information to compile reports to understand how the Services is used so that we can make improvements https://count.ly/legal/privacy-policy.
• Shopify – we partner with Shopify to administer our Services, allowing you to purchase online and across multiple jurisdictions. We also use Shopify Cookies to deliver our ads to you online. To understand more about Shopify Cookies, please see here https://www.shopify.co.uk/legal/Cookies.   

• Facebook – we use Facebook Cookies and pixels to help deliver our advertising on Facebook. This means you may see our ads when you use Facebook because you have visited our site and then visited Facebook. These Cookies also tell us if you come to our site after having clicked on an advert on Facebook. We also work with Facebook to deliver our ads to Facebook users who match against certain criteria which Facebook identifies.  We use other Facebook advertising services as set out below. Please visit your Facebook privacy settings to learn more and see here https://www.facebook.com/policy.php. 

• Microsoft Clarity – we use Microsoft Clarity for statistical analysis of the use of our website, in particular to help create market segments of customers which we think may be interested in our products. We use this information along with our advertising partners to show online advertisements to you and users who may share similar characteristics with you on other websites. To learn more, please visit Microsoft's Privacy Statement . 
• Twitter – we use Twitter Cookies to deliver our ads on the Twitter platform to you and to those other Twitter users who might be interested in our Services based on their online activities including on the Twitter platform. Please visit your own Twitter privacy settings to configure how ads are displayed to you and also see here https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
• LiveIntent – these Cookies are used in email campaigns which display our ads to you and help us understand how you interact with the ad, if you visit our Services and purchase products from us and to help us to understand how to better design and deliver our advertising. To understand more about these Cookies and for information about how you opt-out please see here https://liveintent.com/ad-choices/.
• Klaviyo – we use Klaviyo to [send you our direct marketing communications by email and SMS]. We will only send such communications in accordance with this privacy notice. To learn more, please visit Klavyio's Privacy Notice.
• Attentive – we use Attentive to [automatically send you direct marketing messages via SMS]. To learn more, please visit Attentive's Privacy Policy.
• Wair Fit Finder – we use Wair Fit Finder to [assist you in choosing the correct clothing size based on measurements you provide and your desired fit]. To learn more, please visit Wair's Privacy Policy. 
• Wunderkind – we use Wunderkind's [behavioural marketing platform to identify customer purchasing trends, interests, and other Products offered by us that may be of interest]. To learn more please visit Wunderkind Privacy Policy. Please also note that Wunderkind offers opt-out features that let you opt-out of use of your information for interest-based advertising, to learn how to opt out please visit Wunderkind's 'Your Ad Choice'.Gorgias – we use Gorgias to [manage our customer contacts]. To learn more, please visit Gorgia's Privacy Policy.

• PushOwl – we use PushOwl to [provide notifications to customers]. To learn more, please visit PushOwl's Privacy Policy.

You may choose to disable some Cookies. The effect of disabling Cookies depends on which Cookies you disable. As set out above, if you disable all Cookies, certain features of our Services may not work and you may be unable to complete a purchase on our Services. You will have already had the opportunity to reject Cookies when you first arrived at the Services but if you want to update your choices at any time, you can access and update your existing cookie preferences  updating your device browser settings.

Customer match services

We work with third parties to serve targeted advertisements to our customers, and individuals who share similar characteristics which our advertising partners such as Facebook, Instagram, Tiktok, Criteo and Google identify and we select as being relevant to prospective customers. We also use Tatari.

In order to deliver these ads: 

• We will share Personal Data with our social media and digital advertising partners about you, your purchase, age, gender and interests so that they can better understand what you are interested in and so we can deliver ads to you and to lookalike audiences which we think might be of interest. 

• For example, we may share locally hashed customer and website visitor information and transmit the resulting hashed data to third parties, or we may incorporate a third-party pixel onto our site, or otherwise share Personal Data with third parties. From these data sets third parties are able to identify common data.

• Using this Personal Data, we work with social media platforms to create “custom audiences”, where targeted ads are sent to people who have already been on our Services. "Custom audiences" are created by matching data we collect with the data third parties have.

• We also use this Personal Data to identify a "lookalike audience". We deliver our targeted ads to people on social media platforms who have similar characteristics, determined by us and / or a social medium platform, to our customers and website visitors. Lookalike Audiences may also include current customers and website visitors if they also display those same characteristics identified by us and / or a social media platform.

• Separately to any Personal Data we collect from you, we may also work with social media platforms to display our ads to you on their platform. To do this, we identify characteristics with the social media platform, which we think aligns to our business. Even if you have disabled certain Cookies or unsubscribe from us, our adverts may still be displayed to you through this channel, if the social media platform identifies you as displaying those similar characteristics.

• You can review and update how social media platforms use and share your data for these purposes. Please visit your social media platform privacy settings for more information. 

Links to other websites 

Our Services may, from time to time, contain links to external websites, plug-ins and applications including social media platforms such as Facebook and Google. This notice does not apply to such third-party services and we are not responsible for the privacy policies or practices or the content of any third party. Please review third-party privacy policies and, where applicable, your privacy settings of such third parties.

See third party sources for more information about Personal Data we may collect through third parties, including information we may receive as a result of your engagement with social media channels. 

Who we share your Personal Data with

We may make Personal Data available to:

• Our group companies, who may also process your Personal Data for the purposes set out in this notice. If any of these parties are using your Personal Data for direct marketing purposes, we will only transfer the Personal Data to them for that purpose with your prior consent.
• Organisations who process your Personal Data on our behalf and in accordance with our instructions. This includes supporting our services, in particular data hosting services, fulfilment services, communications providers, fraud detection services, advertising services, marketing services, facilitating feedback on our Services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your Personal Data to the extent necessary to perform their support functions. For example, we work closely with Shopify to deliver our website and provide our products to you. For some categories of data, Shopify also handles your data for their own limited purposes such as for risk and fraud screening and related uses. For information about how Shopify handles your Personal Data visit https://www.shopify.com/legal/privacy. 
• Analytics and search engine providers that assist us in the improvement and optimisation of our Services and advertising and are subject to our Cookies notice.
• Other third parties such as professional advisors, including banks, accountants, and lawyers. 
• Payment processing providers who provide secure payment processing services. Note, as above, your payment card details are not shared with us by the provider.

• Partners that we work with on joint campaigns (for example, to run specific promotions).

We will also disclose your Personal Data to third parties in the event that:

• we sell our business or assets, in which case we will disclose your Personal Data to the prospective buyer of such business or assets subject to the terms of this privacy notice.

Payment processing

Payments are made through a payment processing provider, for example, we use Braintree, Stripe, Shopify Pay, PayPal, and Amazon Pay. You will be providing credit or debit card information directly to such payment providers, which operate a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to these third parties is not within our control and is subject to their own privacy notice and terms and conditions. We may retain a tokenised version of your credit card number and / or the last for digits of your card number for our own records.

For more information please see here:

• Braintree's Privacy Statement
• Stripe's Privacy Policy and Privacy Center
• Shopify's Privacy Policy
• Paypal's Privacy Statement 
• Amazon's Privacy Notice 

Processing your Personal Data outside the UK and EEA

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom ("UK") and European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law. 

Where your Personal Data is transferred to partners, suppliers, our group companies and other third parties who process your Personal Data outside the UK and EEA, including in the U.S., we will take steps to ensure that your Personal Data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, or approved standard contractual clauses for transfers, and that it is treated securely and in accordance with this privacy notice. 

How we protect your Personal Data

We use technical and organisational measures to safeguard your Personal Data

• Personal Data you provide to us in relation to the Services is stored on our secure servers. 
• Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
• We take steps to limit access to your Personal Data only by those who need access to process your Personal Data in accordance with this privacy notice.
• We take steps to contractually require our service providers to protect any Personal Data they process on our behalf.

How long we keep your Personal Data

We retain Personal Data:

• for as long as we are legally required or otherwise permitted to meet our reason for collection (for example, for as long as we are providing Services to you and as necessary after that to anticipate, resolve or document any issues); and
• relating to any account or transactions with us, in order to meet our contractual obligations to you and / or any purchase of products to identify any issues, resolve any legal proceedings and for tax and accounting purposes.

Child safety

Protecting the safety of children when they use the Internet is important to us. 

The services are intended for use by those who are at least 13 years of age.  If you are under the age of 13 your parent or guardian must first consent on your behalf where we ask for consent in relation to the use of your Personal Data.

Your rights

If you have any questions about our processing of your Personal Data, please contact us at support@freshcleantees.co.uk and state "Privacy Query" in the subject line.

You have the right under certain circumstances:

• to find out what Personal Data we hold about you;
• to be provided with a copy of your Personal Data;
• to request the correction or deletion of your Personal Data;
• to request that we restrict the processing of your Personal Data (while we verify or investigate your concerns with this Personal Data, for example);
• to object to the further processing of your Personal Data; and
• to request that your provided Personal Data be moved to a third party.

Your right to withdraw consent

Where the processing of your Personal Data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at support@freshcleantees.co.uk and state "Privacy Query" in the subject line. 

You can change your preferences and object to receiving further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to support@freshcleantees.co.uk and state "Privacy Query" in the subject line.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. 

The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your Personal Data, as well as deal with any complaints that you have about our processing of your Personal Data.

Changes to this notice

Any changes we make to our privacy notice in future will be posted on this page and, in relation to substantive changes, will be notified to you by email (where this is possible). This notice was last updated on the date shown at the beginning of it.

Contact us 

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to:

support@freshcleantees.co.uk

[5 New Street Square, London, EC4A 3TW]