WHO CONTROLS YOUR PERSONAL DATA?

Cloo is the company that is responsible for your information under this Privacy Policy (the “data controller”). We are located at: Cloo (trading under Gleneden Clothing Ltd.) 15 The Millrace Mount Argus Apts., Mount Argus Road, Dublin 6W

WHAT PERSONAL DATA DO WE COLLECT?

The type of data we collect about you includes:

Identity Data including your first name, last name, and address.

Contact Data including your billing address, email address and telephone numbers.

Financial Data including payment card details. This is collected by 3rd party payment gateway. Cloo does not receive or store any financial data.

Transactional Data including details about payments for services you have purchased from us.

Technical Data including IP address, your login data, browser type, operating system and platform, as well as your journey through our digital platform (such as the links you click on and the searches you make), which videos you have watched, what content you like and share, and information collected in any forms you complete. We may also analyse which marketing activity led to your taking specific action on our digital platforms.

Profile Data includes your login and password, purchases, or orders made by you.

Usage Data including information about how you use our website, products, and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

HOW IS YOUR PERSONAL DATA IS COLLECTED?

Direct Interactions

You may give us your data by filling in forms, using our website, ordering services, or from corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Sign up or order from our website
• Enter a competition or promotion
• Sign up to our mailing list
• Complete a survey / give us some feedback
• Accepting our cookie policy

HOW WE USE YOUR PERSONAL DATA

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it. We will only collect personal data from you when:

• we have your consent to do so, or
• we need your personal data to perform a contract with you. For example, to process a payment from you, fulfil your order or provide customer support connected with an order, or
• Pursuing our legitimate interests in a way that you might reasonably expect to be a part of running our business and that does not significantly impact your interests, rights and freedoms, for example, showing Cloo advertisements to you as you browse the internet.
• we have a legal obligation to collect or disclose personal data from you (e.g. in suspected instances of fraud where we need to give personal data to An Garda Siochana or a government body).

THIS IS WHY WE PROCESS YOUR PERSONAL DATA:

• To personalise and assist your use of our website and to generally improve it.
• To offer you special offers, early access to sales and e-marketing information.
• To offer you promotions, products and services that are most likely to interest you.
• To fulfil your order and process purchases that you make by using our website, including retaining your details to allow us to fulfil any contractual obligations, such as contacting you to arrange deliveries, or to facilitate refunds or returns.
• To respond to your queries or complaints on the basis of our contract with you, our legal obligations and our legitimate interests in providing you with the best products, service and experience.
• To protect our business and your account from fraud and other illegal activities and to comply with our contractual or legal obligations to share data with An Garda Siochana or government body.
• With your consent, we will use your personal data to keep you informed by email, web, text, telephone and through our contact centres about products and services including special offers, e-marketing, discounts, vouchers, promotions, events and competitions
• To send you information required by law, like a product recall notice or information relating to your orders.
• To communicate changes to the services we provide you, for example, updates to this privacy notice.
• To administer competitions which you enter at our events, on our website, via social media or otherwise, based on your consent given at the time of entering.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To send you review requests (sometimes via our trusted third parties) to help us improve our products, services and website.
• To build a picture of who you are and what you like, we’ll combine data captured by us and third parties, on the basis of our legitimate business interests to help us personalise your experience and decide what to share with you.
• We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

HOW WE SHARE YOUR DATA

We sometimes share your personal data with our trusted categories of third parties we use to conduct our business, for example, to enable delivery of your purchases; to handle feedback and complaints; and to help us understand your behaviour in order to customise and maximise our products, services, advertising, marketing, competitions and offers to you.

Our trusted categories of third parties include delivery companies and independent contractors, marketing agencies, e-mail marketing service providers who assist our marketing team to run targeted email campaigns, customer survey service providers, advertising partners and agencies, website hosts, cloud service providers, data privacy providers, social media providers, professional services providers, and consumer review providers.

You may be able to access third-party social media before, during or after accessing our website. We use social media buttons and/or plugins on this website, to allow you to connect with your social network in various ways. When you are using your third-party social media account, any personal data we obtain or share with social media service providers is done so in accordance with the practices explained in the third-party social media provider’s terms and privacy notice. Please consult their relevant terms and privacy notices for further information.

As part of our e-marketing methods and on the basis of our legitimate business interests, we use some Google services and some Facebook products in accordance with the practices explained in the Google and Facebook terms and privacy notices. In order to protect your personal data by pseudonymising it, Google and Facebook ensure that a hashing algorithm is applied automatically at the point of sharing personal data with Google and Facebook. Please consult their relevant terms and privacy notices for further information and your options.

As part of our fraud monitoring, detection and prevention methods and on the basis of our legitimate business interests, we use a third-party fraud monitoring, detection and prevention service provider for all website/online sales. As part of this service, we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your age, name and location), together with account information, with third party organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that these third parties may retain a record of the information that we provide to them for this purpose.

We may share your personal data with government bodies and law enforcement.

We may also share your personal data with our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

MARKETING, ADVERTS & COOKIES

We may send you marketing communications and promotional offers: · if you have created an account with us or purchased goods from us, or registered for a promotion or event, and you have not opted out of receiving marketing (in accordance with your preferences, as explained below); · by email if you have signed up for email newsletters; We may use your personal data (as outlined in the ‘Personal Data We Collect’ section) to form a view on what we think you may like, or what may be of interest to you, and to send you details of products and offers which may be relevant for you. We will ask you for your preferences in relation to receiving marketing communications by email, post, SMS and other communication channels. You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us (or any third party, if applicable) at any time: · you can unsubscribe or ‘opt-out’ by using the unsubscribe button and following the link included in the footer of any marketing email; or ·We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.

Cookies

Our website uses cookies to distinguish you from other users of our website and to keep track of your visits. They help us to provide you with the very best experience when you browse our website and to make improvements to our website. They also help us and our advertising networks to make advertising relevant to you and your interests.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

For detailed information on the cookies which we and our third-party providers use and the reasons why we use them, please refer to our Cookie Policy.

Online ads

We use online advertising to keep you aware of what we’re up to and to help you find our products. Like many companies, we may use targeted Cloo banners and ads to you when you use other websites and apps. We do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience Service.

Our use of analytics and targeted advertising tools

We use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps to you. We use these tools to deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties to perform similar tasks. If you would like any further information about the data collected by these third parties or the way in which the data is used, please contact us.

In order to opt out of targeted advertising you need to disable your ‘cookies’ using our website cookie tool (see Cookie Policy for details) or opt-out of the relevant third-party Ad Settings.

How to delete cookies in Mozilla Firefox How to delete cookies in Google Chrome How to delete cookies in Opera How to delete cookies in Safari

LINKS TO OTHER WEBSITES AND THIRD PARTIES

Our website may include links to and from the websites of our partner networks, advertisers and affiliates, or to social media platforms. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites.

TRANSFERRING YOUR DATA OUTSIDE THE EEA

The personal data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area (“EEA”) using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.

If we share your personal data outside of the European Economic Area, we ensure that there is an appropriate transfer mechanism in place to protect your personal data and comply with our data protection obligations.

Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside the EEA.

STORING AND SECURING YOUR DATA

Storing your data

We need to retain your personal data to satisfy our legal obligations, to deal with complaints and queries, in order to resolve, litigate or defend a dispute and to prevent fraud and abuse.

Having obtained your consent (or other legal basis) to contact you, we will retain your personal data for marketing and analysis purposes until you withdraw your consent. If you choose to withdraw your consent to marketing, we will delete your personal data from our systems, unless we have another legal basis to retain it, which may include performance of our contract with you.

We will not keep your personal data for longer than is necessary and when we no longer need to keep it, we will securely destroy, delete or anonymise it.

Securing your data

The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.

We have put in place physical, electronic and managerial security procedures in the storage and disclosure of your personal data to protect it against accidental loss, destruction or damage. Nevertheless, any data transmission over the internet or by any other means can never be fully secure, such is the character of the internet, and provision of personal data by you to us is at your own risk. We take all reasonable measures to protect your personal data by putting appropriate technical and operational security measures in place.

When we disclose your personal data to trusted third parties (for the purposes set out in this notice), we require all third parties to have appropriate technical and operational security measures in place to protect your personal data, and we work with them to ensure that your data protection and privacy rights are respected. Where your personal data is shared with a third party, it must only be used for the purposes for which it was supplied.

In the unfortunate event of a personal data breach, we will notify you and any applicable regulator when we are legally required to do so.

CHANGES TO THIS PRIVACY NOTICE

From time to time we may change this privacy notice. If there are any significant changes we will post updates on our website, applications or let you know by email.

HOW TO CONTACT US

We welcome feedback and are happy to answer any questions you may have about your data.
You can contact us at: hello@clooactive.com