Contents

Introduction. 2

Who is iClothing. 2

Clothing Privacy Notice. 2

Information collected and its purpose. 2

Securing our users’ information. 3

Sharing our users’ information. 4

Marketing messages. 4

Direct marketing. 5

Retention period for holding our users’ information. 5

Our users’ data privacy rights. 5

Cookies use. 6

Changes to privacy protection. 6

Links. 6

Introduction

Here at iClothing we take privacy and security of personal data very seriously and are committed to protecting and respecting the privacy and security to our users (collectively, “our users” or “they” or “their” or “them”). The Privacy Notice below explains how we collect and use personal data. It applies to personal data collected when our users use our website, our app and when they interact with us through email, social media, customer support chat or when they participate in our competitions or events.

By personal data we mean ‘personally identifiable information’. This is any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains. This includes but is not limited to: name; address; phone number; email; personal identification number; and credit card information. Personally identifiable information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual.

For all our services, the data controller (the entity responsible for collecting and managing their data privacy) is ABJB Ltd. – trading as www.iclothing.com (collectively, "iClothing” or “we” or “us” or “our”).

If you are one of our users and have any questions about how we protect your data privacy and security, please get in touch at privacy@iclothing.com.

Who is iClothing

iClothing is an Irish-based online fashion retail company. We design, source, market and sell clothing, shoes and accessories to consumers in Ireland, the UK, Europe and beyond.

Clothing Privacy Notice

Information collected and its purpose

The personal data that we collect and use from our users is detailed below:

Name & contact details

We use our users’ name and contact details to:

Deliver purchases to them – this is necessary to perform our sales contract with them.
Send them messages related to their deliveries – we generally do this by email but we may also send texts for delivery updates. This is necessary to perform our sales contract with them.
Send them information about new products and services – we do this by email or text to keep them informed. We send this to our users based on their consent and so we only send it with their permission.
Monitor fraudulent activity – this is to prevent and detect fraud against either our users or iClothing.
Enhance customer experience – this is to ensure we are providing our users with the best customer experience possible.

Payment information

We use payment information to:

Take payments and give refunds but we don’t keep our users’ payment information. We use a PCI-DSS compliant payment service provider.
Fraudulent activity– this is to prevent and detect fraud against either our users or iClothing.

Date of birth information

We use date of birth information to:

Perform data analysis – for demographic analysis on our customer base.
To send our users offers on special events (e.g. for their birthdays). We send this to our users based on their consent and so we only send it with their permission.

Contact history

We use our users’ contact history with us to:

Perform their sales contract with us.
To provide customer service and support. We perform customer support through a number of different channels: email; contact forms on iClothing.com; ‘real-time’ chat on iClothing.com; and social media channels (e.g. Facebook and Twitter).

Purchase history and saved items

We use our users’ purchase and saved items history to:

Keep a history of what they’ve bought and what they’re storing in their shopping basket. We do this to perform our sales contract with them.
Enhance customer experience – this helps us provide good customer service and support. It also helps us to determine what products to offer and ensure we provide a great customer service.
Facilitate direct marketing.

Information about their phone or laptop, and how they use our website and app

We use our users’ information about their devices to:

Improve our website and customer experience. Examples of information we collect on our users are:
- Their device type and screen resolution.
- Their IP address and ISPs.
- Their browser type (e.g. Google Chrome)
- Monitor fraudulent activity – to prevent and detect fraud against either our users or iClothing.
- Facilitate direct marketing.

Information from accounts they link to us (e.g. social media)

If our users decide to link accounts with us, we use their information to:

Allow them to log into our website simply and easily without having to create a specific account.
Provide them with product recommendations via these channels.
Facilitate direct marketing.

Responses to surveys, competitions and promotions

If our users decide opt in to a survey, competition or promotion that we are running, we use their information to:

Run the activity in question and perform our contract with them.

Securing our users’ information

At iClothing, we adopt ‘data minimisation’ principles in how we collect and store data. What we mean by this is that our users’ personal data is only accessible by employees of iClothing, our service providers and other third parties that are critical for us in providing our services to them.

iClothing takes appropriate organisational safeguards and security measures to protect our users’ data from being accidentally lost, used or accessed in an unauthorised way. We also take all reasonable measures to ensure we maintain a secure website, electronic communications and databases, including:

Our website runs on SSL enabled technology, meaning the communication between our users’ browser and our website uses a secure encrypted connection.
We audit our IT systems and data protection processes on a regular basis.
We carry out Privacy Impact Assessments (PIAs) to manage our risks in relation to data privacy.
We maintain a data privacy risk register.
All of iClothing’s employees are trained with our security policy and practices, as well as the fundamentals of the General Data Protection Regulation (GDPR).
All personal data of our users is only accessible to those that are required to see it to perform their roles.
We have written, legal agreements in place with our service providers that covers the collection or use of our users’ personal data. As part of these agreements, we require any third party who is contracted to process your personal data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.
We use data minimisation techniques such as pseudonymisation in our customer database.
For sensitive information, such as credit card numbers entered at the time of purchase, we use encryption protocols and PCI DSS compliant service providers to protect this information being sent over the Internet.

User Generated Content information

If we reach out to you on social media to feature your content on our social channels. it means we love your look!

By allowing us to feature your posts:

We can use your handle / social username and the content of the post on iCLOTHING.com and on any of iCLOTHINGS’s social media platforms (including but not limited to Instagram, Facebook and Twitter).
We can enhance or modify the visuals (but we promise not to misuse the image or portray it in a negative way).

You declare that you:

Have the permissions of everyone featured in the content / image;
Have the responsibility to grant iCLOTHING the rights listed above; and.
You are at least 18 years of age.

If you (or anyone in the featured content) asks us to remove the content, we will remove the content from the social media accounts that we control and also remove the content from the website, if it is featured.

You understand and are aware that users of these social media platforms can also share and use the content once it has been posted. For example, a user of these platforms can easily take a screenshot of the content and save an image of the content to their device, share the content on social media platforms or websites which feature the content (and possibly provide sharing access.). If you do not want to grant the permissions set out above then please do not give us your consent to use the content.

General Competition

By entering a competition entrants accept these terms and conditions together with any specific instructions and terms for such competition which may be mentioned in any electronic messages, or on the website, or communicated to entrants in any other way (“competition information / competition rules.”). Such competition information shall prevail in the event of there being any inconsistency between these competition terms and conditions and any competition information.

All entrants should be over 18 years of age and living in Ireland (unless stated).
The number of entries per an individual must not exceed 1.
The date of competition entries & results will be published within the context of all competition guidelines held or announced by iCLOTHING.
The winners will be contacted directly by iCLOTHING via email, text, phone or the social network platform used via the iCLOTHING account handle.
The prize is non-transferable and non-refundable. There is no cash alternative.

You declare that you:

Have the responsibility to grant iCLOTHING the rights listed above; and.
You are at least 18 years of age.

Sharing our users’ information

iClothing does not sell any of our users’ personal data to any third party – including their name, address, email address or credit card information.

However, we may share our users’ personal data with some of our service providers and other third parties that are critical for us to provide our services to them. Service providers and third parties we may share data with include:

Our service providers that facilitate getting our users’ orders to them, such as payment service providers, order labelling providers, and delivery companies (e.g. An Post).
Our professional service providers, such as marketing partners, data processors, customer support partners and website hosts, who help us run our business.
Third parties approved by our users, such as social media sites (e.g. if they decide to link their Facebook account to us).
Third parties that help us monitor fraudulent activity such as law enforcement agencies. We may disclose our users’ personal data in order to comply with a court order or a request from a law enforcement agency to release such information.

We may also use data privacy techniques such as anonymisation and/or pseudonymisation (so that it protects our users’ identity) and aggregate personal information to use it for purposes such as:

Testing our IT infrastructure;
Improving our website; and
Trends and product analysis.

We may also share this information with our service providers who are helping us facilitate such activities.

In the unlikely event of a personal data breach on our part or one of our service providers, we will notify our users and any applicable regulator when we are legally required to do so.

Marketing messages

If our users have given us prior consent, we may send them marketing messages by email or text, to keep them aware of what we’re up to and to help them see and find our products.

Our users have a number of mechanisms they can use to stop receiving marketing messages from us at any time. To do this, they can simply complete one of the following actions:

Our users can use the ‘unsubscribe’ link in any of our marketing emails.
Our users can contact us at privacy@iclothing.com and we will process this request for them.

Once they complete the request to stop receiving marketing messages, their profile will be updated to ensure that they don’t receive further marketing messages.

However, consideration needs to be given for the fact that iClothing has a number of IT systems and service providers, so it might take a reasonable period of time for our users’ request to be fulfilled, typically a few days. As a result, they might get marketing messages from us while their request is being processed.

Also note that requesting to stop marketing messages will not stop us from sending our users messages relating to their purchases. These types of messages are service related and we need to send them to perform our sales contract with them.

Direct marketing

Like many retail companies, we use direct and re-targeting marketing practices to send our users targeted iClothing banners and adverts when they are on other websites and apps to keep them up-to-date on what we’re doing and our latest products. We do this using digital marketing service providers.

Any targeted banners and adverts our users see from iClothing will be based on information we collect about our users for example, their contact data, device data and usage data. See the “Information collected and its purpose” section above).

Retention period for holding our users’ information

We will store our users’ information for:

The duration they have an account with us; or
For as long as is necessary to provide services to them; or
For as long as is necessary to provide customer related support; or
When we have their consent to do so; or
Processing the data is in our legitimate interests and not overridden by our users’ rights,

If required to meet legal and regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also store our users’ information as long as is reasonably necessary, even after they have closed their account or it is no longer needed to provide the services to them.

Our users’ data privacy rights

It’s entirely up to our users whether they provide iClothing with any of their personal information, but without giving it, they may not be able to purchase products from our website. Similarly, they are unlikely to receive our best customer experience.

With the GDPR becoming effective on May 25^th 2018, our users have a lot of rights relating to their personal information:

Right to Notice – they must be informed of how their personal data is being used (this Privacy Notice is an example).
Right of Access – they have the right to access all data collected about them and get a copy of this data and any relevant supplementary information free of charge.
Right to Rectification – they can ensure all inaccurate personal data concerning them is corrected.
Right to Erasure (be forgotten) – in some circumstances, they can ask us to erase all their personal data without undue delay. Note: there are exceptions to this, notably for the prevention of crime.
Right to Portability – they have the right to ask for their personal data to be sent to them or another service provider in a machine-readable format.
Right to Object to Direct Marketing – they have the right to stop all direct marketing messages that are being sent to them.
Right to Object to Automated Processing – they have the right to object to certain parts of automated processing or to a decision based solely on automated processing. Note: iClothing does not make any forms of decisions based on automated processing.
Right to Make a Complaint – they have the right to make a complaint to their relevant data protection authority – for example in Ireland, this is the Data Protection Commissioner and in the UK, this is the Information Commissioner’s Office.

iClothing is fully committed to facilitating our users’ data privacy rights and we are confident in our ability to do so. If you are one of our users and you have any questions in relation to your data privacy rights with us, please contact us at privacy@iclothing.com

Cookies use

We use cookies on our website. Cookies are to obtain information about the preferences of our users and the services they select. They help us to provide our users with the very best experience when they browse our website and helps us to make appropriate improvements to our website. We also use cookies for security purposes to protect our users. For example if a user is logged on and does not use the website for more than 10 minutes, we will automatically log the user off.

Our users can set their browser to refuse all or some browser cookies. However, if they disable or refuse cookies, some parts of our website may become inaccessible or not function properly.

Changes to privacy protection

We may change our Privacy Notice occasionally to reflect how we are processing personal data and will inform our users by publishing an updated Privacy Notice on the iClothing website.

iClothing is fully committed to facilitating our users’ privacy rights and we are confident in our ability to do so. If you are one of our users and you have any questions in relation to your data privacy rights with us, please contact us at privacy@iclothing.com

Links

iClothing’s website contains links to other websites. Please note that when our users click on one of these links, they are moving to another website. We encourage them to read the privacy notices of these linked sites as their privacy policies may differ from ours, and as such we do not accept any responsibility or liability for these policies.