Privacy policy
Introduction
Nirvana Brands Ltd ("Nirvana", "we", "us" or "our") operates www.lauraashleybeauty.com and www.lauraashleybeauty.co.uk (the "websites"). This privacy policy gives you information about how Nirvana collects and uses your personal data through your use of this website, including any data you may provide when you make a purchase and information we receive as a result of cookies that you have accepted. It also sets out how we may share your personal data. The websites are not intended for children and we do not knowingly collect data relating to children.
This policy is split into three parts:
· Part 1: General Information – which sets out a general description of the personal data we collect and how we will use it.
· Part 2: UK/EEA Information – which sets out additional information and your rights when the UK and/or EU GDPR applies to our processing of your personal data.
· Part 3: US Information - which sets out additional information and your rights where US law applies.
Part 1: General Information
1. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, any previous names, username or similar identifier title and date of birth.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the websites.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you interact with and use our websites, products and services, and social media channels, including any communications between you and us. These social media channels include @lauraashleybeauty through Instagram, pinterest and Tiktok or @laurashleyparfum on Instagram.
· Marketing and Communications Data includes your preferences in receiving marketing from us and any third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our websites to help improve the websites and our service offering.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· Purchase any products or begin to purchase any products.
· Create an account on a website.
· Request marketing to be sent to you.
· Enter a competition, promotion or survey.
· Give us feedback or contact or interact with us, including through any social media channels.
· Automated technologies or interactions. As you interact with our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Further details about the cookies that we use are set out below.
· Third parties or publicly available sources.
We collect and process personal data through the following third-party service providers to operate our website, process transactions, and improve our services:
· Shopify – E-commerce platform and hosting provider
· Google Analytics – Website analytics and performance tracking
· Google Ads - Advertising and remarketing services
· Meta Ads – Advertising and remarketing services
· Shopify Payments - Payment processing service
· PayPal – Payment processing service
· Klarna – Buy Now, Pay Later payment services (UK)
· Klaviyo – Email and SMS marketing automation
· Royal Mail (UK) – Order fulfilment and delivery service
· FedEx – Order fulfilment and delivery service
· Ontrac (US) – Order fulfilment and delivery services
· Okendo – Customer review and feedback services
· CookieYes – Cookie consent management and tracking compliance tool
3. How we use your personal data
Purposes for which we will use your personal data
We shall use your personal data for the following purposes:
· To register you as a new customer.
· To process and deliver your order including to manage payments, collect and recover money owed to us.
· To manage our relationship with you which will include:
o Notifying you about changes to our terms or privacy policy.
o Dealing with your requests, complaints and queries.
o Any interactions with you on social media channels that we operate under the "Laura Ashley" brand.
· To enable you to partake in a prize draw, competition or complete a survey.
· To administer and protect our business and the websites (including troubleshooting, data analysis, testing, system maintenance, support, security, fraud prevention, reporting and hosting of data).
· To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
· To use data analytics to improve our websites, products/services, customer relationships and experiences, including through the relevant social media channels, and to measure the effectiveness of our communications and marketing.
· To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data.
· To carry out market research through your voluntary participation in surveys.
· To share your personal data with Laura Ashley IP Holdings LLC, from whom we licence the "Laura Ashley" brand and who own the relevant "Laura Ashley" social media channels that we operate and Marquee Brands Intermediate Holdings II LLC, who own the websites. To see how Laura Ashley IP Holdings LLC processes your personal data, please review their privacy policy available at https://www.lauraashley.com/content/privacy-policy
You will receive marketing communications from us if you have opted to do so.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Marketing from Laura Ashley and other third parties
We will get your express consent before we share your personal data with any Laura Ashley companies or any third party, so that they can send their own direct marketing to you.
4. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out above.
· Laura Ashley IP Holdings LLC, from whom we licence the "Laura Ashley" brand and who will own the social medial channels through which we might interact with you, in particular. To see how Laura Ashley IP Holdings LLC processes your personal data, including information on how they may share your personal data, please review their privacy policy available at https://www.lauraashley.com/content/privacy-policy
· Marquee Brands Intermediate Holdings II LLC, who own the websites, www.lauraashleybeauty.com and www.lauraashleybeauty.co.uk.
· Contractors, service providers, professional advisers and other third parties (sometimes referred to as processors) we use to support our business and who are bound by contractual obligations to keep personal data confidential and who use it only for the purposes for which we disclose it to them.
· Third parties 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 policy.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
· To comply with any court order, law or legal process, including to respond to any government or regulatory request.
· To enforce our agreements, including for billing and collection.
· If disclosure is necessary or appropriate to protect the rights, property, or safety of Nirvana, our customers or others (including Laura Ashley). This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Our websites uses cookies to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our sites. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.
We may use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our websites. These essential cookies are always enabled because our websites won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our websites. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our websites.
Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
Functional cookies. These are used to recognise you when you return to our websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting and Marketing cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|
Cookie Name |
Provider |
Type |
Purpose / Function |
Duration |
|
_ga / ga |
Google Analytics |
Analytics |
Tracks user behaviour across pages for performance analysis |
2 years |
|
localisation |
Shopify |
Functional |
Stores user language/region preferences to improve browsing experience |
1 year |
|
cart_currency |
Shopify |
Functional |
Stores selected currency based on user location/session |
14 days |
|
_shopify_y |
Shopify |
Analytics |
Shopify analytics cookie used for visitor tracking and reporting |
1 year |
|
_shopify_s |
Shopify |
Analytics |
Shopify session-based analytics cookie used to track page visits |
1 hour |
|
__kla_id |
Klaviyo |
Analytics |
Tracks visitor behaviour and email engagement for analytics and marketing attribution |
1 year |
|
_fbp |
Meta (Facebook) |
Marketing |
Tracks user interactions for advertising and retargeting |
3 months |
|
_shopify_marketing |
Shopify |
Marketing |
Used for marketing attribution and advertising performance tracking |
1 year |
|
shopify_client_id |
Shopify |
Functional |
Stores a unique identifier for session continuity and storefront functionality |
1 year |
|
gt-no-cache |
Unknown / Third-party (under review) |
Functional |
Prevents caching to ensure updated content delivery |
1 day |
We have put in place appropriate administrative, technical, and physical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please bear in mind, however, that we cannot guarantee that submission of information over the internet is 100 percent secure and you therefore submit any such information at your own risk. Furthermore, you are responsible for keeping your device access and login information confidential. You are also encouraged to install anti-virus and anti-malware software on your devices and keep all software updated to avoid security risks.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
· Email address: hello@lauraashleybeauty.com
· Postal address: Amertrans Park, Bushey Mill Lane, Watford, Hertfordshire, WD24 7JG, UK
9. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review, and it may therefore change from time to time; your continued use of our websites after we make changes is deemed to be acceptance of those changes. We therefore recommend that you check this privacy policy regularly for updates. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
The websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave a website, we encourage you to read the privacy policy of every website you visit.
Part 2: UK/EEA Information
Under the EU and UK GDPR, Nirvana is the controller in connection to the websites.
Under the EU and UK GDPR, the law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter, agree to cookies or to receive marketing from us or any other party.
We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|
Purpose/Use |
Type of data |
Legal basis |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you
|
|
To process and deliver your order including: (a) Manage payments (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction
|
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
|
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries (c) Any interactions with you on social media channels that we operate under the "Laura Ashley" brand |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Usage |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
|
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Consent
|
|
To administer and protect our business and the websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|
|
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent
|
|
To use data analytics to improve our websites, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
|
|
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) (b) Consent
|
|
To carry out market research through your voluntary participation in surveys |
|
(a) Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services)(b) Consent
|
|
To share your personal data with Laura Ashley IP Holdings LLC, who we licence the "Laura Ashley" brand from and Marquee Brands Intermediate Holdings II LLC, who own the websites.
|
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
(a) Necessary for our legitimate interests (to work with Laura Ashley IP Holdings LLC in connection to the websites and social medial channels as the brand owner and to allow Laura Ashley IP Holdings LLC to use the data for their own purposes, as a separate controller)(b) Consent |
13. TRANSFERS OUTSIDE OF THE uk AND EEA
Where we transfer your personal data to Laura Ashley IP Holdings LLC [or Marquee Brands Intermediate Holdings II LLC], this will involve a transfer of your personal data to the United States. We may also transfer your personal data to service providers that carry out certain functions on our behalf or to other third parties. This may involve transferring personal data outside the UK and/or European Economic Area (“EEA”) to countries which have laws that do not provide the same level of data protection as the UK or EEA. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
· We will only transfer your personal data to countries that have been deemed under applicable EEA or UK law to provide an adequate level of protection for personal data.
· We may use specific standard contractual terms approved for use under UK and EEA law which gives the transferred personal data the same protection as it has in the UK and EEA.
14. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
· Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data (see the table above for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
· If you want us to establish the data's accuracy;
· Where our use of the data is unlawful but you do not want us to erase it;
· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us the above Contact details.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can find our complaints form here [LINK].[PMC3]
Part 3: US Information
16. APPLICABILITY
In the United States, consumer privacy is governed by federal privacy laws covering specific types of data and/or data uses and state privacy laws providing general consumer-privacy rights. The following terms supplement the terms set forth above and apply only to residents of states within the United States that have comprehensive privacy laws. Solely with regard to those individuals, if there is a conflict between the rights set forth in this Part 3 and either Part 1 or Part 2, this Part 3 will control.
17. definitions
The definitions that may apply to our processing of your Personal Data (as defined below) may differ compared to those used in the UK/EEA context. As used in this Part 3, the following definitions apply:
· “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household. Personal Data falls within certain categories, for example:
· Identifiers (e.g., name; email; telephone number; address; username; account identifiers; social-media handles; IP address);
· Sensitive Personal Data (e.g., government identification number; precise geolocation; racial or ethnic origin; national origin; citizenship or immigration status; religious beliefs; mental or physical condition or diagnosis; sexual orientation; status as transgender or non-binary; status as a victim of crime; contents of messages when we are not the recipient; in some cases, information about a known child);
· Legally protected information (e.g., race, citizenship, marital status, sex);
· Employment-related information (e.g., current or past employment);
· Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
· Biometrics (e.g., DNA, face/voice prints, retinal or iris pattern, gait, health data) and audio, electronic, visual, thermal, or olfactory information;
· Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behaviour, attitudes, intelligence, and aptitudes;
· Commercial/transactional information (e.g., products or services purchased, obtained, or considered; purchasing or consuming histories or tendencies; collection-related records);
· Internet, network, or other similar activity (e.g., device information; log data; browsing history; content interactions); and
· Approximate location (e.g., general location derived from IP address).
Not all personal information is protected as Personal Data. Publicly available information, aggregated information (meaning data summaries or reports with Personal Data removed), and anonymized or deidentified information that cannot be linked back to an individual are generally not subject to legal protections.
Regarding Sensitive Personal Data, we do not seek to collect Sensitive Personal Data about any individual. Please do not provide any Sensitive Personal Data to us. In any event, we do not disclose any Sensitive Personal Data for the purpose of inferring characteristics about you or otherwise use your Sensitive Personal Data without your consent. If this ever changes in the future, we will update this privacy policy and, to the extent permitted by applicable law, provide you with methods to opt-out or limit our use and disclosure of Sensitive Personal Data.
18. Data Collected
During the preceding 12 months, we have collected the following:
· Identifiers:
· Name, email, telephone number, address, username, social-media handles.
· Commercial history:
· Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
· Internet or similar activity:
· Browsing history, content interactions.
· Financial and Transaction Data:
· Bank account and payment card details, details about payments to and from you.
· Profile Data:
· Username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Marketing and Communications Data:
· Preferences in receiving marketing from us and any third parties and your communication preferences.
19. Sources of personal data collected
As disclosed above, we use Google Analytics. The following supplemental information regarding Google Analytics is relevant for United States residents:
We use Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our websites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You may be able to prohibit Google from collecting and analysing the cookie-generated data about your use of the websites (including your IP address) by downloading and installing the browser plugin available here http://tools.google.com/dlpage/gaoptout?hl=en. You may opt-out of certain Google service features, such as through your device advertising settings, or by following the instructions provided by Google in its Privacy Policy: https://policies.google.com/technologies/partner-sites. For more information on the privacy practices of Google more generally, visit the Google Privacy Terms web page: http://www.google.com/policies/privacy/.
20. YOUR CHOICES
We give you the ability to directly control the Personal Data we collect and hold about you through our Services:
· Our Emails. We may send you informational or support emails related to your purchases or marketing emails based on your stated communication preferences. You can unsubscribe or change your email preferences at any time by using the links provided in our emails or by sending a request to the contacts listed above. Note that if you opt-out of marketing emails, we may still send you messages about your product orders or other administrative topics.
· Device Settings and Cookie Manager. You can control the data we collect through cookies and related technologies by adjusting your device settings and using our cookie manager.
· Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Our websites are compatible with browser “do-not-track” requests.
· Opt-Out of Interest Based Ads. You may limit our use of information collected from or about you and your devices for purposes of serving online behavioural advertising by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt-Out of Interest-Based Ads” (for Android devices). Our websites are also compatible with a global opt-out mechanism.
· Resetting Advertising ID. You can reset your device Ad Id at any time through your device settings. This may allow you to limit the use of information collected about you for targeted advertising.
21. PRIVACY RIGHTS AND REQUESTS
Privacy Rights
Depending on where you reside, you may be entitled to additional controls over your Personal Data. Please review the additional privacy rights listed below and contact us if you have questions about exercising your privacy rights. Residents of applicable states (each a “Consumer”) can exercise their privacy rights by submitting a Privacy Request (as defined below). Please note that the list below may contain rights that are not applicable in all states.
· Right to Correct. You have the right to request that we correct inaccurate Personal Data about you. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
· Right to Deletion. You have the right to request that we delete your Personal Data, with certain exceptions.
· Right to Know/Right to Access. You have the right to request confirmation regarding whether we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and readily usable format. Please note that we may be prohibited by law from disclosing certain pieces of Personal Data, and we may be limited in the number or frequency of requests we must fulfil.
· Right to Disclosure. You may request that we disclose information to you about our collection and use of your Personal Data, such as: (a) the categories of Personal Data we have collected about you; (b) the categories of sources for the Personal Data we have collected about you; (c) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (d) the categories of third parties (and in some jurisdictions, the specific third parties) with whom we share that Personal Data; and (e) if we sold or shared your Personal Data for cross-contextual behavioural advertising (as defined by applicable law), two separate lists stating: (i) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfil.
· Limited Use and Disclosure of Sensitive Personal Data. You have the right to opt-out or limit our use of your Sensitive Personal Data, but please note that we do not seek to collect Sensitive Personal Data from any consumer. If you choose to provide us with Sensitive Personal Data, we will only use it to provide you with the products and services you request. In no event do we disclose any Sensitive Personal Data for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this privacy policy and provide you with methods to limit our use and disclosure of your Sensitive Personal Data.
· Opt-Out of Selling and Sharing. Some states entitle consumers to opt-out of the sale or sharing of Personal Data and/or targeted advertising practices. With the exception of Sensitive Personal Data, we may share Personal Data we collect for targeted and cross-contextual behavioural advertising purposes. We may also use certain third parties for analytics, and this has been interpreted to be a "sale" by some privacy regulators. We are therefore disclosing that we may sell your Personal Data to third parties. We engage in these practices to market our products to existing and potential new customers and to optimize your experience on our websites. You may opt-out of sharing or selling your Personal Data for these purposes by submitting a request at Do Not Sell or Share My Personal Information [BS4] or by email to the contacts listed above. If you submit your request by email, please put "OPT-OUT REQUEST" in the subject line. You may also stop future collection of your Personal Data for these purposes via our cookie manager.
· Right to Opt-Out of Profiling. You have the right to opt-out of certain automated profiling, particularly if the profiling is done in connection with access to critical goods or services (e.g., essential goods or services or employment opportunities). We use a third-party tracking beacon to analyse your activity on the websites to predict your interests and preferences. To opt out, you can block tracking beacons via a third-party browser extension such as an adblocker. If you need support, please contact us at the contacts listed above.
· Right to Non-Discrimination. We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services; (c) provide you a different level or quality of goods or services; (d) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (e) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.
· Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Data sharing with affiliates and/or third parties for marketing purposes.
· Right to Appeal. If, after submitting a Privacy Request under this Part 3, you believe we have refused to act according to applicable law, you may appeal our action or inaction by using the following appeal process:
· Send us a notice at the contacts listed above with "Privacy Rights Appeal Notice" in the subject line (“Appeal Notice”) within 60 days of the earlier of either (a) our rejection of, or failure to fully comply with, your Privacy Request or (b) if we have not responded to your Privacy Request, when you initially submitted your Privacy Request.
· The Appeal Notice must contain information sufficient for us to verify your state of residence, identity/authority to act on behalf of the Consumer, and evaluate your appeal.
· We will either approve or deny your appeal within 45 days of your Appeal Notice, and will notify you in writing (which may be by email), of our decision and the reason(s) for our decision.
· If we deny your appeal, our notice may provide you with contact information for the attorney general in your jurisdiction so you may submit a complaint to them.
Privacy Requests
To exercise your rights under applicable privacy laws, express concerns, revoke your consent, lodge a complaint, or request information, please contact us at the contacts listed above, or submit a request through our online form (each, a “Privacy Request”).
We may only legally fulfil a request when we have information sufficient to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. Any Personal Data we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We endeavour to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction. If we do not fulfil your request within the legally required timeline, you can appeal by contacting us at the contacts listed above.
LAST UPDATED: 1 May 2026
LAST REVIEWED: 1 May 2026