Privacy Policy
Ellesse is committed to protecting our customer's privacy. Please take the time to review this notice (the “Notice”) which explains what personal data (also referred to as “personal information”) we collect about you, how we use it, and your rights.
If you are a resident of California, please also refer to Section 13, “California Privacy Supplement” for information about the categories of personal data we collect and your rights under California privacy laws.
1. Scope of this Policy
Ellesse (“we” or “us”) is the controller of the personal data described in this Notice. This Notice describes the various contexts and circumstances in which we collect personal data, including through our “Online Services.” These Online Services include:
- Digital Interactions: This encompasses your online engagements with us, which may occur through our Online Services, including:
- Our Sites: Any that link to this Policy, such as www.ellesse.com
- Our Mobile Applications
- Social Media: Interactions on our social media pages.
- Other Digital Platforms: Includes interactions such as clicking on our ads on third-party sites and subscribing to our electronic communications.
- Online Customer Services: Including communications with our service representatives or features via chat functions, email, text, or phone.
- Third-Party Information Gathered in the Online Context: This policy also extends to information we may collect about you from third parties related to your use of our Online Services, even in the absence of direct interactions with us.
- This Policy also applies to personal data we collect in the context of online transactions (e.g., purchases, returns, etc.).
Ellesse maintains separate privacy notices for other types of data processing. For example, we maintain separate notices for how we process the personal data of our workforce members (where required). For questions regarding the scope of this Notice, please contact us as set forth in the “Contact Us” section.
2. What personal data we collect and how
We collect personal data from individuals and, in some cases, from other sources.
Personal data we collect directly
We collect personal data from you when you provide it to us directly and through your use of the Site (for the purposes disclosed in section 2), including:
- Registration and profile information, such as information you provide to us when you use our Site e.g., your name, contact details, gender, and any information which you add to your account profile. For example, we may allow you to provide additional (voluntary) information, such as your body type, skin type, hair type, hair condition, training regime, performance goals, height and weight.
- Transaction and billing information, if you make any purchases from us or using our Site e.g. credit/debit card details and delivery and shipping information.
- Records of your communications and interactions with us, such as when you email, call, or otherwise contact us, we collect and maintain a record of your contact details, communications and our responses. We also maintain records of communications and information that you post in chat sessions, forums and in other areas of the Site, and on our social media channels.
- Sweepstakes, contest and promotions information, such as information you provide us when you participate in a competition or promotion.
- Surveys and product reviews, e.g. if you participate in one of our surveys or provide information to us as part of product or service reviews.
- Events, e.g. if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.
- Marketing and communications data, such as records of your preferences about receiving marketing and communications from us.
- Foundation Finder tool, if you choose to use this, we’ll ask you to upload a photograph and answer a few questions so that we can recommend a make-up foundation that matches your skin tone and the style you’re after.
- If you shop in one of our stores, we may combine any information you provide to us in-store (e.g. when you make a purchase or join our mailing list in-store) with the information we otherwise collect about you.
Personal data collected automatically
We automatically collect personal data related to your use of our Site and interactions with us and others, e.g. using cookies and pixel tags, as well as information we derive about you and your use of the Site. This includes:
- Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Site. This can include IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Section 4 “Cookies and Personalisation” below.
- Activities and usage information related to your use of the Site, such as links clicked, searches, features used, items viewed, time spent within the Site, files uploaded, products and items you view and items you add to your basket.
- Location information. We may collect or derive location information about you, such as through your IP address. With your permission, we may also collect geolocation information from your device. You may turn off location data sharing through your device settings.
Personal data we receive from other sources
In some circumstances, we may receive personal data from third parties, including:
- Verification data: e.g. data collected from third party service providers used to verify your identity and prevent fraudulent activity.
- Social media monitoring: If you visit our pages on social media sites, we collect information such as what you click on and view, your comments, likes and reactions, your location (country/region), details of your device and internet connection, your social media profile details and user ID.
- Demographic information: We may receive demographic information from third party advertising partners to help us better personalise ads. See section 4 “Cookies and Personalisation” for more information.
3. Purposes for processing personal data
We use, disclose and otherwise process the personal data we collect as described in this section:
- Online accounts. To register you as a customer and maintain your online account.
- Fulfil orders. To fulfil your order, including managing payments, charges, refunds and returns.
- Respond to your requests. To manage and respond to any queries or complaints to our customer service team.
- Provide recommendations. If you use our tools, we use the information you provide to recommend products for you. We’ll also use the image, details of recommended products and any feedback to further improve the functioning of the tool and related services, or to develop similar tools and services.
- Manage our relationship with you. To notify you of service-related matters such as changes to our terms or privacy policy.
- Personalise content and experiences. To personalise the Site and show you content we think you will be most interested in, based on your account information, your purchase history and your browsing activity.
- Operate and improve the Site and our business. To improve and maintain the Site, and monitor its usage, to better understand how users access and use the Site, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our business operations, to develop services and features, and for internal quality control and training purposes.
- Events. If we run or sponsor events we may collect personal data in connection with your attendance.
- Research and customer satisfaction. For market research and surveys, e.g. we may contact you for feedback about our products or for customer satisfaction purposes.
- Marketing and advertising. To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so.
- Security and protection of rights. For security purposes, to prevent, detect, and investigate fraud and other unauthorised activities and access, and where necessary to protect ourselves, our business and third parties.
- Compliance with law and legal process. To comply with the law and our legal and regulatory obligations, to respond to legal process and in relation to legal proceedings.
- Internal business operations. For general business and operational support, e.g. to consider and implement mergers, acquisitions, reorganisations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, record keeping, and legal functions.
4. Legal bases under EU/UK data protection laws
Where relevant under applicable data protection law, we rely on the following legal bases to process your personal data:
- Because the processing is necessary to perform a contract with you, or take steps prior to entering into a contract with you (e.g. where you have made a purchase with us, we use your personal data to process the payment and fulfil your order).
- Because we have obtained your consent (e.g. if you consent to receive marketing from us or agree to the use of non-essential cookies). If you have consented to a processing activity, you can withdraw your consent at any time. We explain how to do this in the Cookies and Personalisation section (section 4) and Marketing section (section 5) of this policy.
- Because it is in our legitimate interests as an e-commerce provider to maintain, promote and protect our business and services. We are always seeking to understand more about our customers in order to offer the best products and customer experience. We use information about you to tailor your view of the Site, to make it more interesting and relevant in respect of the products and offers on view.
5. How do we share personal data?
We may disclose or share personal data with third parties, for the purposes described above. Generally, this includes the following types of sharing:
- With other companies in our group of companies. Your personal data may be processed by Ellesse affiliates for purposes of analytics, research, and demographic studies, and development and improvement of products and services by Ellesse and affiliates. Subject to applicable law, we may also share your personal data (e.g., contact information, characteristics, and usage data) with our affiliates so that they may contact you about their products and services.
- With our suppliers and service providers who process the data on our behalf, e.g., data storage, payment processors and delivery companies. In providing their services, they may access, receive, maintain, or otherwise process personal data on our behalf.
- With our professional and legal advisors.
- With third parties engaged in fraud prevention and detection. We may also disclose your personal data where we believe doing so is necessary to protect our services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; to investigate, prevent, or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the safety or legal rights of Ellesse or any person or third party, or violations of our applicable terms; and to protect the rights, property, or personal safety of Ellesse our customers, or the public.
- With third party platforms, providers and networks. We may disclose or make available personal data to third party platforms and providers that we use to provide our Site and its features. We may also make personal data available to third parties in support of our marketing, analytics, advertising and campaign management. See Section 4 “Cookies and Personalisation” for more information.
- With law enforcement or other governmental authorities, e.g., to report a fraud or in response to a lawful request or order.
- In relation to mergers, acquisitions, investments and asset transfers, personal data will be transferred to the other party to the transaction. We may also share certain personal data as part of the preparation for the transaction with lenders, auditors, and third-party advisors, including lawyers and consultants.
- To comply with legal obligations. We may share personal data with third parties to comply with our legal and compliance obligations and to respond to legal process e.g. in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement and government bodies. This may include responding to national security or law enforcement disclosure requirements and disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.
- Otherwise where we have your consent to, you requested us to, or we are legally permitted to do so.
6. Cookies and Personalisation
Cookies and tracking technologies
We and our third party service providers use cookies, pixels, local storage objects, log files, APIs, and similar technologies to automatically collect browsing activity, device and similar information within our Site. We use this information to provide functionality on the Site, to understand and measure Site performance, to understand how users access, use and interact with others, and to deliver targeted advertising and content on our Site and third party sites. We also use it to identify and resolve bugs and errors in our Site and to assess, secure, protect, optimise and improve the performance of our Site.
Personalised advertising
We work with third parties, such as ad networks, social media platforms, analytics and measurement services and others to personalise content and display advertising within our Site, and to manage our advertising on third party sites, mobile apps and online services. For example, you may see ads for our Site on third party websites, including on social media. These ads may be tailored to you using cookies and similar technologies which track your web activity on our Site and across other websites and online services, to enable us to serve ads to customers who have visited our Site.
We may also engage third parties, including social networks to show ads to our customers, or users who match the demographic profile of our customers. This may involve sharing information, such as your name, email address, and other contact and purchase information with these third parties so that we can better target ads and content to you across third party sites, platforms and services. These third parties may also help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns.
If you do not want to see personalised ads you can change your cookie preferences using the tool available on our Site, as explained below, and by adjusting your privacy settings on third party websites and platforms.
Manage your preferences
You can manage your preferences for cookies and personalisation used by us as explained below.
- Cookie preference tool: You can review and update your cookie preferences for our Site and opt out of most cookies and trackers on our Site (other than those that are strictly necessary) within our Cookie Preference Tool accessible via the cookie icon at the bottom left-hand corner of the webpage. Your preferences are browser and device-specific so you need to set the preference for each browser and device you use to access our Site. If you delete or block cookies, you may need to reapply these preferences.
- Industry ad choice programs: You can get more information about personalised advertising and opt out of personalised advertising by participating third party ad companies through industry ad choices programs, including:
- UK/EU: youronlinechoices.eu
- US: aboutads.info
- Canada: youradchoices.ca
- Please note that opting out of cookies and trackers on our Site does not mean that you will no longer see ads from us. You may continue to see generic or “contextual” ads.
- Please see our Cookie Policy here for further information about the use of cookies on our Site and the choices you have.
- Changing Mobile Device Privacy Settings: Your mobile device may collect and share device-level information to facilitate targeted advertising. This is independent of our Services but can affect your overall privacy experience. To better understand and manage these settings, you may refer to the privacy resources provided by your device's operating system. For your convenience, we've included links to informational pages for Google’s Android and Apple’s iOS platforms.
- “Do Not Track” Signals: Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. Like many websites, we do not currently respond to ‘Do Not Track’ browser settings or signals. For more information about DNT, please see eff.org/issues/do-not-track.
- “Global Privacy Control”: Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including the “sharing” of your personal data. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required under applicable law.
7. Marketing
We love to communicate with our customers. Depending on your marketing preferences, we may use your personal data to send you marketing messages by email, SMS, phone, and post. Some of these messages may be tailored to you, based on your previous browsing or purchase activity, and other information we hold about you.
If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (e.g. order and delivery confirmations, and information about your legal rights).
8. Transfers of personal data to other countries
We use service providers, and have group companies, in countries around the world. Your personal data may therefore be processed in countries outside the country in which it was collected, including in countries where you may have fewer legal rights in respect of your personal data than you do under local law. When necessary to comply with applicable law, if we transfer personal data outside the country of origin we will ensure that your privacy rights are adequately protected by appropriate safeguards.
9. Retention
We will keep your personal data in line with our data retention policy, for as long as we need it for the purposes set out above, so this period will vary depending on your interactions with us. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint about a product) for as long as is necessary in connection with any legal claim.
10. Security
We implement appropriate technical and organisational security safeguards to protect your data from loss, misuse, and unauthorised access, disclosure, alteration and destruction. We also maintain ISO 27001 and PCI DSS (Payment Card Industry - Data Security Standard) security certifications. However, please be aware that it is impossible for any company to guarantee the absolute security and integrity of the information that has been transmitted to its website.
11. Children
Our Site is not intended for, and should not be used by, children under the age of 18. We do not knowingly collect personal data from children under 18.
12. Your Rights
You have choices regarding our processing of your personal data as described in this section.
Your rights under data protection laws:
Subject to applicable law, you have the right to:
- Ask for a copy of your personal data, make corrections to your personal data, and in some cases e.g. where our purposes for processing have come to an end, ask us to delete it. If you have an account with us, you may review and update your profile information and communications preferences directly within your account.
- Object to our use of your personal data in certain situations, including where we use your personal data for direct marketing. See section 5 “Marketing” for details of how to opt out of direct marketing.
- Transfer your personal data, in certain circumstances, to another provider, in a commonly used format.
- Complain to the data protection regulator in your country. In the UK this is the Information Commissioner’s Office (www.ico.org.uk).
We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are several limitations to these rights, and there may be circumstances where we are not able to comply with your request.
You can exercise your rights by contacting us at Ellesse Limited, Ellesse Customer Service, 1-2 The Stables, Gadbrook Park, Northwich, CW9 7RA or call us on 08001510779.
US residents:
If you are a California resident, please review our California Privacy Supplement (section 13) below, for specific information about your rights under California privacy laws and how to exercise them.
Depending on your location and applicable laws and regulations, you may also have data privacy rights regarding Ellesse’s processing of your personal data. Based on the legal requirements applicable to your jurisdiction, and subject to any legal restrictions or exceptions, you may have the choices and rights described below:
- Right to Access: You may request access to the personal data we hold about you. This may include the right to be informed about the categories and specific pieces of personal data we have collected, the sources from which we collected it, the purposes for collecting it, and the third parties with whom we have shared it.
- Right to Correct: You may request that we correct any inaccurate personal data relating to you without undue delay. You may also have the right to request the completion of incomplete personal data by means of a supplementary declaration.
- Right to Delete: You may request the deletion of your personal data, subject to certain exceptions. In certain circumstances, we may not be able to comply, such as when processing is necessary to comply with legal obligations or for the performance of a contract.
- Right to Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format. You may also request that we transfer this information to another data controller, where technically feasible.
- Right to Opt Out of Sale: You may direct us not to sell or share your personal data with third parties.
- Right to Opt Out of Targeted Advertising: You may request that we not disclose, disseminate, or transfer your personal data to a third party for targeted advertising. You can opt out by clicking "Your Privacy Choices" in the site footer.
- Right to Restriction of Processing: You may request that we restrict the processing of your personal data, although we may be unable to comply when processing is necessary for legal obligations.
- Right to Opt Out of Certain Data Processing: You may withdraw consent for processing your data, but it will not affect the lawfulness of processing before withdrawal.
- Right to Opt Out of Automated Individual Decision-Making: You may object to decisions based solely on automated processing, including profiling, under certain circumstances.
- Right Against Discrimination: You have the right not to be discriminated against for exercising your data protection rights.
- Right to Appeal: You may have the right to appeal if we decline to act on your privacy request.
How to exercise your privacy rights:
- You can opt out of targeted advertising on our Site in Section 4 “Cookies and Personalisation” and opt out of direct marketing as set out in Section 5 “Marketing”.
- To appeal our denial, contact us at customer.experience@thehutgroup.com and include "Appeal Privacy Right Request Decision" in the subject line.
- To exercise your other privacy rights, please contact us in writing at Ellesse Limited, Ellesse Customer Service, 1-2 The Stables, Gadbrook Park, Northwich, CW9 7RA or call us on 08001510779.
Identity verification:
We will verify your request by matching the information you provide with what we have in our records. Please provide the necessary information via email and verify your access to the registered email address.
Authorised agents:
You may designate someone as an authorised agent to submit privacy requests on your behalf. Proof of authorisation will be required, and we may require verification from the individual whose data is being requested.
Sensitive Personal Data and Age Restrictions:
We do not sell or share sensitive personal information (including biometric information), nor do we sell or share any personal information about individuals under sixteen (16) years old.
13. Changes to this Privacy Notice
We may update this Privacy Notice from time to time. If we make changes, we will notify you by posting the updated Privacy Notice on our Site and revising the “effective date” at the top of this Notice. We encourage you to review this Privacy Notice regularly for the latest information about our privacy practices.
14. Contact Us
If you have any questions or requests related to this Notice, please contact us:
Ellesse Limited, Ellesse Customer Service, 1-2 The Stables, Gadbrook Park, Northwich, CW9 7RA or use our contact us form.
15. California Privacy Supplement
Consumers residing in California have additional rights in relation to their personal information under California privacy law, including the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you. This section does not address or apply to our handling of publicly available information or other personal information that is exempt under the CCPA.
Categories of personal information collected and disclosed. Whilst our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we may collect, and have in the past twelve months collected, about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.
Categories of Personal Information
Categories of Personal Information | Categories of Third Party Disclosures |
---|---|
Identifiers | Includes direct identifiers, such as name, alias, user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • others as required by law or directed by you |
|
Customer Records | Includes e.g. name, account name, user ID, contact information, account number, and financial or payment information that individuals provide us in order to purchase or obtain our products and services. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • internet service providers • operating systems and platforms • others as required by law, or as otherwise directed by you |
|
Commercial Information | Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • others as required by law, or as otherwise directed by you |
|
Internet and Electronic Network Activity Information | Includes browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Site or other online services. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • others as required by law, or as otherwise directed by you |
|
Geolocation Data | Location information about a particular individual or device e.g., derived from your IP address. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • others as required by law, or as otherwise directed by you |
|
Audio, Visual and Other Electronic Data | Includes audio, electronic, visual, thermal or similar information, such as thermal screenings and CCTV footage. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • business customers/clients • others as required by law, or as otherwise directed by you |
|
Professional Information | Includes professional and employment-related information such as current and former employer(s) and position(s), job application information, business contact information and professional memberships. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • others as required by law, or as otherwise directed by you |
|
Profiles and Inferences | Including inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behaviour or attitudes. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • others as required by law, or as otherwise directed by you |
|
Protected Classifications | We collect some information that is considered a protected classification under California/federal law, such as your gender, date of birth, citizenship, and marital status. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • advertising networks • data analytics providers • social networks • internet service providers • operating systems and platforms • others as required by law, or as otherwise directed by you |
|
Sensitive Personal Information | In limited circumstances, we may collect Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. |
• vendors and service providers • advisors and agents • government entities and law enforcement • affiliates and subsidiaries • others as required by law, or as otherwise directed by you |
Sales and Sharing - California privacy laws define a "sale" as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioural advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA): identifiers and internet and electronic network activity information to/with third-party advertising networks, analytics providers, and social networks. We do so in order to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.
Sources of Personal Information
In general, we may collect personal information from the following categories of sources:
- Directly from the individual
- Advertising networks
- Data analytics providers
- Social networks
- Internet service providers
- Operating systems and platforms
- Fraud prevention service providers
- Data brokers
- Business customers/clients
Purposes of Collection, Use and Disclosure
As described in more detail in Section 2 “How we use personal data” and Section 3 “Who do we share personal data with”, we collect, use, disclose and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
- Fulfil orders
- Maintain online accounts
- Respond to your requests
- Provide recommendations
- Manage our relationship with you
- Personalise content, ads, and experiences
- Operate and improve the Site and our business
- Events
- Research and customer satisfaction
- Marketing and advertising
- Security and protection of rights
- Compliance with law and legal process
- Internal business operations
Sensitive Personal Information
Notwithstanding the above, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you. We do not use or disclose your sensitive personal information other than as authorised pursuant to section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)).
Retention
We retain personal information only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection.
Notice of Financial Incentive
We may offer our customers loyalty and other incentive programs that provide certain benefits, such as rewards and exclusive offers. We may also provide other promotional campaigns, such as sweepstakes, contests, or limited-time promotions (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal data, they might be interpreted as a “financial incentive” program under the CCPA. The value of your personal data to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. Participation in a Program is governed by the applicable terms and conditions (including the Official Rules for any sweepstakes or contest or the promotional terms for any short-term promotion), which will also describe the financial incentives associated with the promotion and how to participate. You are not obligated to participate in any contest, sweepstakes, or short-term promotion and may terminate your participation at any time (as described in the survey terms and conditions). You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program terms and conditions.
Shine the Light Disclosure
California Civil Code Section § 1798.83, also known as the “Shine the Light” law, permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for direct marketing purposes in the preceding calendar year, as well as the type of personal data disclosed. To make such a request, please send an email with the subject “Shine the Light Request” to the email address in our Contact Us section.
CCPA Rights
Under the CCPA, California residents have the following rights (subject to certain limitations):
- The right to opt-out of our sale and sharing of your personal information.
- The right to limit our use or disclosure of sensitive personal information to those authorised by the CCPA.
- The right to the deletion of your personal information that we have collected, subject to certain exceptions.
- The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
- The right to correct inaccurate personal information that we maintain about you.
- The right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests
California residents may make requests to access/know, correct and delete their personal information maintained by us online by emailing customer.experience@thehutgroup.com Once we receive your request, we will take steps to verify it by asking you to provide information related to your account or your recent interactions with us, such as information regarding a recent purchase. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. If you would like to use an authorised agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid authorisation to submit requests on your behalf and we may also require that the relevant consumer directly verify their identity and the authority of the authorised agent.
Opt-out Requests
Our Site responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our Site. Note that if you come back to our Site from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/. You can also opt out of online tracking on our Site via the cookie preference tool (see Section 5 for details).
California residents may exercise their right to opt out online by submitting an opt-out request. We will apply your opt-out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request.
For more information about our privacy practices, you may contact us as set out in the Contact Us section here or also find above.