EFFECTIVE FROM 29TH JANUARY 2021
Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with our privacy statement.
WHO ARE WE?
We act as the data controller and are responsible for how your personal information is used. We are registered with the Information Commissioners Office. Our ICO registration number is ZA356409.
WHAT INFORMATION DO WE COLLECT?
We collect or receive personal information from you via our website, order forms, or brand pages on social media or otherwise. Sometimes you give this to us directly (e.g. when you create an account, when you contact us, when you purchase from our websites or via our stores), sometimes we collect it to understand how you use our websites or interact with our marketing (e.g. using cookies or tracking pixels). What information we collect from you depends on the interaction you have with our company.
We collect your details via the following methods:
- When you create an account on our website.
- When you place an order or make an enquiry over the telephone.
- When you place an order or make an enquiry through the post.
- When you interact with our email marketing, by clicking, opening, or interacting with emails we send you.
- From time to time we may also receive information about you from third parties such as data hygiene companies, data cooperatives and selected data partners.
Creating an account
When you create an account on our site, we collect the information you give us. This always includes your name and email address. If you allow, we also collect postal address, phone number, date of birth. We use this information to create a more personal experience for you as you shop, analysing it to improve our site and the products we offer.
If you have opted in to receiving our email newsletter, we will also use this information to send you more relevant emails. If you do not opt-in to our marketing emails, we will email you a welcome email to ensure we have your correct details in addition to service emails when necessary i.e., Order confirmation.
You can update your details at any time by going into your account on our website.
Ordering from our website or over the phone
When ordering from our website or over the phone, we collect all the details necessary to process and fulfil the order. These include: name, email address, phone number, postal address, and card details or payment information. We use this information in the following ways:
- To process and fulfil your order
- To contact you about your order
- To create reports and analyse customer behaviour
- To send you more relevant marketing material (if you’ve opted in to our newsletters).
Our communications are designed to tell you about the benefits we can offer so that you have access to our best deals. We use the information we have about you to tailor the content and try to ensure that the offers are as relevant to you as possible. Under the Data Protection Legislation, this might qualify as profiling. If you do not wish us to use your data for this purpose, please call on 0123 3456 7890 or email us at firstname.lastname@example.org
We may collect and process the following data about you:
Information that you provide by filling in forms on the website at www.wearethought.com and information provided to our call centre. This includes information provided at the time of registering to use the website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with the website:
- If you contact us, we may keep a record of that correspondence.
- If you telephone us, we may keep recordings of the call for training, fraud prevention, servicing your account and regulatory consent.
- Details of transactions you carry out through the website and of the fulfilment of your orders.
- Details of your visits to the website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Details of whether you open emails we send you, if you click links in these emails and additional information about your interactions i.e., IP address, time of day, device type, etc.
- We may also receive your information from another organisation where you have consented for them to share your data.
We also collect data because it is necessary for the pursuit of our legitimate interests. Our legitimate interests are set out below.
- Improving our service and our products
- Understanding our customers’ wishes and shopping preferences
- Direct Marketing
- For analysis purposes and to adapt email content to individual reader preferences
Opting in to our email newsletter
When you opt in to our email newsletter we collect your email address. We will send marketing emails using the email address email@example.com provided we have gained your consent to do so. We will also send you our newsletters, including offers and promotions.
We may contact you about similar products where you have not opted-out of receiving this information. The legal basis on which we process your personal data to do this is our Legitimate Interests. You have the right to object to us processing your personal data in this way. To do this, you can contact us by telephoning our Customer Services team on +44 207 607 1173 or by writing to us at Thought Clothing, Roman Way, London, N7 8XH. We will be more than happy to assist.
If at any time you wish to stop being sent our newsletter from us, you can click ‘unsubscribe’ at the bottom of any email we have sent you. You can also contact our customer services team at firstname.lastname@example.org and request to be removed. After unsubscribing we will only send you service emails i.e., Order Confirmation.
We use a recognised legitimate interest to send you relevant postal marketing. We will use the personal information you have provided together with details of the products and product categories you have purchased from us to help identify which communications to send to you. If at any time you wish to stop being sent our direct mail from us, you can visit here and fill in your details. You can also contact our customer services team at email@example.com and request to be removed.
Marketing to you on the web (not on our website)
“We use Facebook Audience Manager, Google Customer Match and Microsoft Advertising to target you from time to time with advertising which we think is the most relevant to you. This feature allows us to target ads to you as part of a specific set of people, based on your preferences. Personal data, such as email address, is encrypted on upload to such third-party networks. These networks only receive a unique identifier. You can manage your privacy settings in the privacy tab of your account(s) with such third parties. You can find further details on Facebook Audience Manager, Google Customer Match and Microsoft Advertising here [https://www.facebook.com/about/privacy/, https://policies.google.com/privacy, https://privacy.microsoft.com/en-gb/privacystatement].”
Interacting with our customer services team
In order to offer a complete service we will also store data and records from any interaction with our customer services team. We may refer to these at a later date to improve the website and your experience as a customer. As with all the data we store we will keep these records securely.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Using cookies, tracking pixels and similar technologies are standard practice across websites, applications and email and are Privacy/GDPR compliant when used correctly. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.
For the exhaustive list of cookies we collect see the List of cookies we collect section.
KEEPING YOUR DATA
We keep all personal information we have for as long as you have an account with us or as long as we need to provide our services. We are under obligation to keep all transactional data for 6 years. We may keep it longer than this if we still require it for trend analysis and reporting unless you request for it to be deleted. Upon request we can remove your account from our systems but we will still need to keep all transactional data until the 6 years is up. We keep your personal data until you request your data to be removed from our marketing database.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We store all data we collect on servers within the European Economic Area (“EEA”). In some cases when but we may also transfer your data outside of the EEA to secure servers. Where this is the case the data transfer will be carried out in compliance with applicable laws.
WHO HAS ACCESS TO YOUR PERSONAL INFORMATION?
We may share your details with carefully selected retail partners who we feel may be of interest to you, to provide you with information about their goods and services by post, we do not share email addresses. We will do this when we believe it is in our mutual legitimate interest to do so.
The participating retailers are active in the following product categories:
- Food and Wine
- Gadgets and Entertainment
- Health and Beauty
- Household Goods
- Home Interiors
In addition to the information that we share in order to comply with our legal obligations, we also may share or disclose the information:
- To third parties that process data on our behalf
- To our trusted retail partners via data pooling
- To any other party with your prior consent
Data pools are groups of retailers who share information on what their customers buy. This pooled information is analysed to understand consumer’s wider buying patterns. From this information, customers are sent tailored communications containing suitable offers that should be of interest to them based on what they like to buy.
When we are legally obligated to we may also share your personal information with governmental and law enforcement agencies.
Outlines to each of the data agencies we share data with can be found below
The Thought Clothing Ltd mobile message service (the "Service") is operated by Thought Clothing Ltd (“Thought Clothing Ltd”, “we”, or “us”). Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes.
By consenting to Thought Clothing Ltd’s SMS/text messaging service, you agree to receive recurring SMS/text messages from and on behalf of Thought Clothing Ltd through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).
You understand that you do not have to sign up for this program in order to make any purchases, and your consent is not a condition of any purchase with Thought Clothing Ltd. Your participation in this program is completely voluntary.
We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.
You may opt-out of the Service at any time. Text the single keyword command STOP to Thought or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other Thought Clothing Ltd mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.
For Service support or assistance, text HELP to Thought or email firstname.lastname@example.org.
We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.
The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.
To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.
We respect your right to privacy. To see how we collect and use your personal information, please see our Privacy Notice.
We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. They share information on what their customers buy. Epsilon Abacus analyses this pooled information to understand consumer’s wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.
Your personal data is shared with Experian Ltd for the purposes of managing a service called Club Canvasse, a home shopping and direct retailer data co-operative of which Thought are members. By sharing information on what customers buy and pooling that with contributions from other members of the co-operative, the service allows Thought to better understand our customers and to communicate with you more effectively. To understand more please click through to their website here
To find new customers for our business we are a member of a large co-operative of like-minded UK retail brands that pool and share transactional information. We work with a program called IBehavior, part of the Company Conexance that processes customer transactional data on behalf of each Member. This process highlights spending patterns and allows us to identify suitable prospects to receive an offer or introduction from us via the post. Thus, we send postal offers and information only to prospective customers that are likely to be interested in buying from us. Co-op Member brands operate in numerous categories, including apparel, home and garden, collectables, food and wine, gadgets and gifts, entertainment, health and beauty, travel and leisure.
Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.
Your Rights/Opt Out : https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/
Data sharing outside of EEA
Some of our third–party processors, who provide marketing analysis for us have sub-processing activities outside the UK, so your data may be passed out of Europe where strictly speaking it may be subject to less strict data protection laws. We will however seek to ensure that it is subject to appropriate data security at all times.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
CONTROLLING YOUR PERSONAL DATA
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
To enquire about any of the above please contact our Customer Services team on email@example.com or at the address below. We will ensure to deal with your request as quickly as we can where we’re obliged to.
149 Roman Way
We strive to protect your data and use it only as discussed in this policy. If for any reason you have a complaint on how we have managed your data please get in contact with our customer service team. If they are unable to resolve your issue, you may also get in contact with the Information Commissioner’s Office (ICO): https://ico.org.uk
LIST OF COOKIES WE COLLECT
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies and other such software on our website contain information that is transferred to your computer’s hard drive. They help us to improve the website and to deliver a better and more personalised service. This includes, but is not limited to:
- Your IP address
- Your operating system
- Your browser type
- The name of your internet service provider
- The date, time and duration of your visit
- The name and URL of pages you access
The purpose of this is for system administration and to report aggregate information to our advertisers. This contains statistical data about our users’ browsing actions and patterns and does not identify any individual.
The website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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 these websites.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the website.
Thought Clothing may change this policy from time to time by updating this page. This notice was updated on 4th January 2021. It may be updated at times to take into account changes in regulation or legislation. Please check back to this page regularly for possible changes and updates. We may also inform you of any changes when appropriate via email.
The table below lists the cookies we collect and what information they store.
|COOKIE name||COOKIE Description|
|PHPSESSID mage -banners -cache -storage mage -cache-sessid mage -cache -storage mage -cache -storage -section -invalidation mage -messages mage -translation -file -version mage -translation -storage private _content _version product _data _storage recently _compared _product recently _compared _product _previous recently _viewed _product recently _viewed _product _previous section _data _ids store||Temporary information of your session. This information is needed to optimise the speed of the website, or used to provide Shopping Bag functionality.|
|wordpress _test _cookie wordpress _logged _in wp -settings -3 wp -settings -30 wp -settings -time -3 wp -settings -time -30||Our website software use these cookies to determine if you are logged in or not. They are necessary for the operation of our site|
|sentisum _session||Persistent cookies preserved through browser shutdowns. This means, even if you close this page today and ever return there in future, our website will know you’re a returning visitor. This may be used for “remember me” features, as well as persistent user tracking.|
|form _key||Stores randomly generated key used to prevent forged requests|
|_hj Included In Sample||Hotjar cookie. This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels.|
|stc [site id]||This is the third party cookie used to store all the other cookie data in a shortened form.|
|candid_userid||Cookie that allows GetCandid to function on our site|
|_ga, _gat, _gid||Cookies used to create reports in Google Analytics|
|__ cfduid||This cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis.|
|_ncuid, IDE, DSID, Cto_lwid, icts, rmuid||Google double click cookies used to improve advertising|