Privacy Notice

## Privacy Notice Here at boohoo.com Ltd (‘boohoo’) we are committed to protecting and respecting the privacy of your personal data. This privacy notice explains how your data is collected, used, transferred and disclosed by boohoo. It applies to data collected when you use our websites, iOS and android applications, when you interact with us through social media, email, or phone, or when you participate in our competitions or events. It also applies to the extent that someone has nominated you through our "refer a friend" function or purchased an e-gift card on your behalf. It covers: - The personal data we collect - How we collect your data - How we use your data - Marketing preferences, adverts and cookies - Links to other websites and third parties - How we share your data - Your rights - Changes to this privacy notice - How to contact us ### Who is boohoo boohoo is a leading online fashion retail company. We design, source, market and sell clothing, shoes and accessories. boohoo.com Ltd, of 49-51 Dale Street, Manchester M1 2HF (collectively referred to as “boohooo”, “we”, “us” and “our” in this privacy notice) is the controller and responsible for your personal data collected through the www.boohoo.com website (the “website”) and boohoo app (the “app”). Details of our Data Protection Officer responsible for overseeing questions in relation to this privacy notice, and our details are set out in the “How to Contact Us” section at the end of this notice. boohoo is part of the Boohoo Group (“Group”) and, as part of the Group, is affiliated with a number of brands, including Warehouse, Debenhams, Oasis, Coast, Dorothy Perkins, Debenhams, Burton, Wallis, Boohoo, boohooMAN, Prettylittlething and Nasty Gal. In this privacy notice, such brands together with any other brand which is acquired into the Group shall be referred to as the “affiliated group companies”. ### Our commitment to you We take the protection of your personal data seriously and will process your personal data fairly, lawfully and transparently. This privacy notice describes the personal data we are collecting about you and how it is used. We will only collect and use your personal data for the following purposes, to: - fulfil your order(s) - fulfil orders made on your behalf (e.g. e-gift card orders) - communicate with you following a "refer a friend" nomination - keep you up to date with the latest offers and trends - give you a better shopping experience - help us to make our marketing more relevant to you and your interests - improve our services - meet our legal responsibilities ### How we keep your data safe and secure We have appropriate organisational safeguards and security measures in place to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved. 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. 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. ### The personal data we collect Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed. While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 13, you are not permitted to use or submit your data to the website. The following groups of personal data are collected: - Identity Data includes information such as: first name, last name, title, date of birth (optional), occupation, personal description, photo and gender. - Contact Data includes information such as: email address, billing address, delivery address, location, country, telephone number, loyalty programme membership number, and social media id (if you log in by social media). - Financial Data includes information such as: payment card details and bank account. - Transaction Data includes information such as: details of your purchases and the fulfilment of your orders (such as basket number, order number/reference, subtotal, title, currency, discounts, shipping (including tracking information, order status), number of items, product number, single item price, category, tax etc.); payments to and from you and details of other products and services you have obtained from us, information relating to returns, correspondence or communications with you in respect of your orders, and details of any rewards and bonuses awarded. - Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform. - Profile Data includes information such as: purchases or orders made by you, product and style interests, preferences, feedback, and survey responses. - Usage Data includes information such as: how and when you use our website/app, how you moved around it, what you searched for; website/app performance statistics, traffic, location, eblogs and other communication data; loyalty programme activities; and details of any other Debenhams products and services used by you. - Marketing and Communications Data includes information such as: your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. ㅤ We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. ### If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products you have ordered from us). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. ### How we collect your data We may collect personal data about you in the following ways: - Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you: - Create an account or purchase products on our website; - Subscribe to our newsletter, discussion boards, social media sites or create wish lists; - Enter a competition; - Join a Debenhams loyalty programme; - Complete a voluntary market research survey; - Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service); - Use the “refer a friend” function on our website; or - When you log in to our website via social media. - Automated technologies or interactions – as you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details. - Third parties – we may receive personal data about you from various third parties, including: 1. Identity and Contact data from another individual when they purchase an e-gift card for you or use the "refer a friend" function on our website; 2. Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled ‘Marketing preferences, adverts and cookies’. 3. Technical Data from affiliate networks through whom you have accessed our website; 4. Identity and Contact Data from social media platforms when you log in to our website using such social media platforms; 5. Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; 6. Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and 7. Identity, Contact and Transaction Data from Concessionaire Brands who will be responsible for your contract and fulfilling your order if you purchase a product from one or more of the Concessionaire Brands on our website (so that we can, for example, carry out invoice reconciliation, receive updates on the status of the order, and assist with dealing with any complaints or issues with the products purchased). ### How we use your data #### The legal basis for processing 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 (including, in respect of direct marketing, where you have not chosen to opt-out of such marketing); 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 - the processing is in our legitimate interests and not overridden by your rights, or - we have a legal obligation to collect or disclose personal data from you. #### Uses made of your personal data Your personal data is used by Debenhams to support a range of different activities. These are listed in the table below together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests. Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To create an account and register you as a new customer (either directly or via social media).	Identity . Contact	Consent
(1) To process and deliver your order including: recording your order details; keeping you informed about the order status; process payments and refunds, collect money owed to us; and	Identity . Contact . Financial . Transaction	(1) Performance of a contract with you
(1) To manage our relationship with you, including: providing you with any information, products and services that you request from us(or that has been requested on your behalf through our "refer a friend" function);	Identity . Contact . Profile . Marketing and Communications	(1) Consent
To enable you to take part in a competition, event, survey, or receive a reward for shopping with us.	Identity . Contact . Profile . Usage . Marketing and Communications	Where you have decided to enter into a competition or event, for the performance of a contract with you
Where you purchase products from one of the Concessionaire Brands, to enable the relevant Concessionaire Brand to fulfil their order with you (for example, to deliver the products, deal with collection and returns and/or any issues or complaints you may have in relation to the products).	Identity . Contact . Transaction
Where you purchase products from one of the Concessionaire Brands, to enable us to keep up-to-date with your order status and track your order, receive proof of delivery for products shipped to you, provide you with tracking information and to perform invoice reconciliation.	Identity . Contact . Transaction	Performance of a contract with you
To assist with any queries or complaints you may have, including where you have purchased products from the Concessionaire Brands.	Identity . Contact . Transaction	Performance of a contract with you
To administer, protect and improve our business and our website/app, including: troubleshooting, data analysis, testing, system maintenance, support, data analysis, reporting and hosting of data; setting default options for you, such as language and currency.	Identity . Contact . Profile . Technical . Transaction . Marketing and Communications	Consent
To deliver relevant website content, online advertisements and information for you; and measure the effectiveness of the advertising provided.	Identity . Contact . Profile . Usage . Marketing and Communications . Technical	Consent
To use data analytics to: improve our website, products, services, marketing, customer relationships and experiences; and to improve our affiliated group companies’ websites, products, services, marketing, customer relationships and experiences; and for market research, statistical and survey purposes.	Identity . Contact . Profile. Technical . Usage	Consent Legitimate interests (to improve our websites, products, services, marketing, customer relationships and experiences, and those of our affiliated group companies)
To recommend our products, services, discounts and offers and any products, services, discounts and offers provided by our affiliated group companies, that may be of interest to you, including to send you such information by email, post or SMS.	Identity . Contact . Technical . Usage . Profile . Marketing and Communications	Consent (we always give you the choice of whether or not you wish to receive marketing communications from us (for example by providing opportunities to opt-out of receiving marketing from us). Legitimate interests (when we share data with credit reference agencies, to ensure credit products are offered to customers who are suitable for it)
To inform or remind you by email of any task carried out via our website which remains uncompleted, such as incomplete orders or abandoned baskets.	Identity . Contact . Usage	Consent (by providing the opportunity to opt-out of receiving such reminders from us).
To process and deliver your e-gift card orders including taking payment and communicating with you and/or the nominated recipient if delivered to another person.	Identity . Contact . Financial . Transaction	Performance of a contract with you
We may disclose your information to other companies in connection with any merger, acquisition, insolvency situation or otherwise, in which case we will only disclose your information so far as is necessary.	Identity . Contact . Profile . Usage . Marketing and Communications . Technical	Legitimate interest (we have a legitimate interest in processing your information in connection with any mergers, acquisitions or reorganisation of our business, in which case some of your information may be shared with a prospective buyer or otherwise but only so far as is strictly necessary for the purposes of such sale or administration).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish 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. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law. If you have any questions about how boohooo use any of your personal data, please contact our Data Protection Officer at DPO@boohoo.com. #### How long we keep your data for We will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request. ### Marketing preferences, adverts and cookies #### Marketing - your preferences We may send you marketing communications and promotional offers: - if you have opened an account with us or purchased goods from us, or registered for a promotion or event, and you have not opted out of receiving that marketing; - by email if you have signed up for email newsletters; - if you have provided us with your details when you entered a competition and you have consented to receiving such marketing (in accordance with your preferences, as explained below). We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data and Marketing and Communications Data 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 may check your details with appropriate third parties (for example credit reference agencies, such as Experian) before we send you promotions for financial services products. This is to ensure your information is accurate, that the product is suitable for you, and to tailor those offers to you. From time to time we may also include with your order, inserts advertising goods, services or offers from other third-party companies that you may be interested in. You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us or any of our affiliated group companies (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 - You may also unsubscribe by contacting customer services at [customerservices@boohooo.com](mailto:customerservices@boohoo.com) and confirming to them your preferences to opt-out. 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 target Debenhams banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage and Profile Data. 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 (as described above) to you, 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 analyse Google's interest-based advertising data and/or third-party audience data (such as age, marital status, life event, gender and interests) to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties, such as Facebook, Content Square, Adroll, Bloomreach, Criteo and Bing to perform similar tasks, using your Contact, Technical, Usage and Profile Data. In order to opt out of targeted advertising you need to disable your ‘cookies’ in your browser settings (see Cookie Policy for details) or opt-out of the relevant third-party Ad Settings. For example, you can opt-out of the Google Display Advertising Features. As an added privacy measure, you can also use the The Digital Advertising Alliance (which includes companies such as Google, Bloomreach and Facebook) provides a tool called WebChoices that can perform a quick scan of your computer or mobile devices, find out which participating companies have enabled customised ads for your browser, and adjust your browser preferences accordingly. 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. ### Links to other websites and third parties Our website may include links to and from the websites of our partner networks, Concessionaire Brands, 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. ### How we share your data We may disclose and share your personal data with the parties set out below: - where you have consented for us to do so. For example, if you have consented to receive marketing materials from third parties, or in respect of third parties’ (including co-branded or jointly promoted) products and services, we may pass your data on to the relevant third parties for the purpose of sending you such marketing communications; - to business partners, suppliers, sub-contractors and other third parties that we use in connection with the running of our business for the purposes set out in the table above in the section ‘How we use your data’, such as: - to Concessionaire Brands, who require your personal data in order to perform their contract with you if you purchase their products on our website (as set out in the ‘How we use your data’ section above). When you purchase Concessionaire Brand products from our website, we only transmit to the relevant Concessionaire Brand the personal data they require in order to fulfil their contract to you. Please note that the Concessionaire Brands have their own privacy policies and we do not accept any responsibility or liability for these policies nor their data processing practices; - third party service providers that we engage to provide IT systems and software, and to host our website; - third party payment processing services (including Ayden), and in some regions, Klarna (please see T&C’s [here](https://www.klarna.com/ie/terms-and-conditions/) to process your payment to us. Debenhams does not store your payment information. Your payment details are provided to the payment processing service you have selected, who are required to comply with applicable regulations and data protection laws. Please refer to the privacy policy of the relevant provider for details of how they process your personal data; - third party service providers that we engage to deliver goods you have ordered and to manage any returns; - third party service providers that we engage to send emails and postal mail on our behalf including in relation to incomplete orders or abandoned baskets, or marketing communications, to provide data cleansing services and to provide marketing and advertising services; - analytics and search engine providers that assist us in the improvement and optimisation of our website; - affiliate networks through whom you have accessed our website; - to any third party 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 notice. - to protect our customers, Debenhams group companies and website from fraud and theft, 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 other Debenhams group companies and with third party organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that the other Debenhams group companies and 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 Ravelin and/or Risk Guardian and/or other fraud prevention and analysis service providers, in order to carry out fraud prevention checks on our behalf. If personal data is provided to Ravelin, Ravelin will also use this personal data to improve its service and machine learning to improve its automated processing. A copy of Ravelin's privacy notice can be found [here](https://www.ravelin.com/privacy-policy) explains how Ravelin will use your personal data for these purposes; - we may further 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 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; - if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or - to our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. ### Adyen Adyen are the data controller in respect of the Personal Information that you give to them (and which they hold about you) when you sign up for, access, or use services, features, technologies or functions offered on the Adyen website (including when using Adyen to pay for goods or services offered on the Debenhams website) and in relation to Personal Information collected during the course of business as set out in their Privacy Policy which can be found on their website [here](https://www.adyen.com/privacy-policy). ### Your data and countries outside of the UK The personal data we collect from you may be transferred to, and stored at, destinations outside the UK using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the UK 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. Whenever we transfer personal data outside the UK, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place. We will be able to transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. More information can be found [here](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-protection-principles/a-guide-to-the-data-protection-principles/). Otherwise, we may use specific contractual clauses approved for use in the UK which give personal data the same protection as it has in in the UK. 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 UK. ### Your Rights You have several rights under the data privacy legislation. This includes, under certain circumstances, the right to: - request access to your personal data - request correction of your personal data - request erasure of your personal data - request restriction of processing of your personal data - request the transfer of your personal data - object to processing of your personal data - request human intervention for automated decision making - withdraw your consent to process your personal data Brief details of each of these rights are set out below. If you wish to exercise any of these rights, please email us at [DPO@boohoo.com](mailto:DPO@boohoo.com). #### Request access to your personal data You have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data. #### Request correction of your personal data You are entitled to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at [DPO@boohoo.com](mailto:DPO@boohoo.com). In certain circumstances we may need to verify the accuracy of the new data you provide to ㅤ #### Request erasure of your personal data This enables you to request that Debenhams delete your personal data, where there is no good reason for us continuing to process it. 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. #### Request restriction of processing of your personal data You have a right to ask Debenhams to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in future. #### Request the transfer of your personal data You have the right to obtain a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you. #### Object to processing of your personal data You have the right to object to the processing of your personal data where we believe we have a legitimate interest in processing it (as explained above). You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms. #### Request human intervention for automated decision making and profiling You have the right to request human intervention where we are carrying out automated decision making when processing your personal data. This form of processing is permitted where it is necessary as part of our contract with you, providing that appropriate safeguards are in place or your explicit consent has been obtained. #### Withdrawal of consent You have the right to withdraw previously given consent at any time where we are relying on consent to process your personal 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. We will try to respond to all legitimate requests within one month. Occasionally, it may 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. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above 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. 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. #### Right to lodge a complaint If you have any concerns or complaints regarding the way in which we process your data, please email us directly at [DPO@boohoo.com](mailto:DPO@boohoo.com). You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the data protection regulator in the UK [www.ico.org.uk](www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance ### 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. Please send any questions, comments or requests for more information to our nominated representative and Data Protection Officer Keri Devine, who can be contacted at [customerservices@boohoo.com](mailto:DPO@boohoo.com) This privacy notice was last updated on July 2023 (Version v1.5) boohoo.com Limited, Registered Company Number: 12054246, UK VAT Number: 185 4874 61.