Claudio Lugli Womenswear Ltd ("we", "us", or "our") is committed to protecting and respecting your privacy. This policy explains how we use your personal data and sets out the following:

1. What personal data we use and how we collect it.
2. How and why we use your personal data.
3. Our legal basis for using your personal data.
4. Obligations on you to provide us with personal data.
5. When your personal data will be shared.
6. Where we use your personal data.
7. How long we store your personal data.
8. Your rights in relation to our use of your personal data.
9. Changes to this policy.
10. How to make a complaint.
11. How to contact us.

Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.

1. What Personal Data We Use and How We Collect It

We use the following personal data about you:

• Information You Give Us: You provide information about yourself by filling in forms on our site or by corresponding with us via phone, email, or otherwise. This includes information provided when you register to use our site, subscribe to our services, search for a product, place an order, participate in discussion boards or other social media functions, enter competitions, promotions, or surveys, and when reporting problems with our site. This information may include, but is not limited to, your name, address, email address, phone number, financial, and credit card information.

• Information We Collect About You: With each visit to our site, we collect:

  • Technical information, including the IP address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
  • Information about your visit, including when and how you accessed our site (e.g., date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and any phone number used to call our customer service number.
  • Email opens, particularly when customers opt into email marketing, allowing us to track email engagement.

• Information We Receive from Other Sources: We may receive information about you if you use any other websites we operate, services we provide, or our social media pages. We work closely with third parties (e.g., business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

2. How and Why We Use Your Personal Data

We use your personal data in the following ways and for the following purposes:

• Contractual and Sales Purposes:

  • To manage our relationship with you as a customer or supplier.
  • To fulfill our obligations arising from any contracts between you and us.
  • To notify you about changes to our services.

• Marketing Purposes:

  • To engage in direct marketing, communicating information about goods and services, either from us or selected third parties, that are similar to those you have purchased or inquired about, or that we believe may interest you.
  • To measure or understand the effectiveness of the advertising we serve and to deliver relevant advertising to you.

• Website Purposes:

  • To personalize your experience on our site, ensuring content is presented in the most effective manner for you and your device.
  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
  • To keep our site safe and secure.

3. Our Legal Basis for Using Your Personal Data

To process your personal data for the purposes outlined above, we rely on the following legal bases:

• Legitimate Interest: Our legitimate interest is to:

  • Fulfill our obligations to you as a customer or supplier.
  • Provide you with information about goods and services that we or selected third parties believe may interest you.
  • Offer a personalized and functional experience both online and offline.
  • Operate our administration services effectively.

  Our use of your personal data aligns with our commercial interests and is designed to provide a more effective and efficient service, in ways that have minimal impact on your rights and that you would reasonably expect given the nature of our goods and services.

• Contracts: We use your personal data when it is necessary for the performance of a contract between us, such as when you purchase something from us or when we buy something from you.

• Consent: In certain circumstances, we may ask for your consent to use your personal data. If we do so, we will clearly explain the reason for requesting your consent and how we will use your data, ensuring you can make an informed decision. If you do not provide consent when requested, we will not use your personal data for that specific purpose, nor will we rely on any other legal basis.

4. Obligations on You to Provide Us with Personal Data

There is no statutory obligation for you to provide us with your personal data. However, you may be required to provide your personal data when entering into a contract with us. Without this data, we may not be able to fulfill our contractual obligations.

5. When Your Personal Data Will Be Shared

We may share your personal data with any member of our group, including our subsidiaries, our ultimate holding company, and its subsidiaries.

We may also share your data with selected third parties, including:

• Business partners, suppliers, and sub-contractors for the performance of any contract.
• Advertisers and advertising networks to select and serve relevant adverts to you and others.
• Analytics and search engine providers that assist us in improving and optimizing our site.
• Credit reference agencies for assessing your credit score as a condition of entering into a contract with you.

We may disclose your personal data to third parties in the event of:

• A sale or purchase of any business or assets, where personal data may be transferred as part of such a transaction.
• Claudio Lugli Womenswear Limited or substantially all of its assets being acquired by a third party, with customer data being part of the transferred assets.
• A legal obligation requiring us to disclose your data, or to enforce our terms of use, terms of supply, or other agreements; or to protect the rights, property, or safety of our customers or others, including exchanging information with other companies and organizations for fraud protection and credit risk reduction.

6. Where We Use Your Personal Data

Your personal data may be transferred to, stored at, or processed by staff outside the European Economic Area (EEA), including for order fulfillment, payment processing, and support services.

We will take all reasonably necessary steps to ensure your personal data is treated securely and in accordance with this privacy policy. For further information on the safeguards in place, please contact us using the details below.

7. How Long We Will Store Your Personal Data

We will store your personal data as long as it is necessary for the purposes outlined in clause 2. We will review our storage criteria every 12 months to ensure data is not retained longer than necessary.

Data will be stored as long as:

• You hold an account with us and have not deleted it.
• You have consented to receive marketing materials and have not revoked consent.
• A warranty period applies to goods you purchased, or a claim under the warranty is ongoing.

We may delete your data earlier if:

• Internal reviews suggest the risk to your data rights outweighs our security measures.
• We believe your data may be outdated or inaccurate and cannot verify this with you.
• You exercise your right to be forgotten, as outlined in clause 8.

We may continue to store your data if you request it, to comply with legal obligations, or for statistical purposes where adequate security measures are in place.

8. Your Rights

You have several legal rights regarding your personal data. If you wish to exercise any of these rights or require further information, please contact us using the details below. We may refuse your request if:

• Required by law.
• We cannot verify your identity.
• You already have the requested information.
• We consider your request excessive, in which case we may charge a reasonable fee.

We will aim to respond within one month and will notify you if a delay occurs.

Your rights include:

• Right of Access: You can request a copy of your personal data free of charge, though additional copies may incur a fee.
• Right to Object: You can object to our use of your data based on the legal basis we rely on, including direct marketing and profiling.
• Right of Correction: You can ensure your data is accurate and up to date.
• Right to Be Forgotten: You can request deletion of your data in certain circumstances.
• Right to Restrict: You can restrict how we use your data in specific situations.
• Right to Portability: You can request the transfer of your data to another organization in a commonly used, electronic format.

9. Changes to This Policy

Any future changes to this policy will be posted on this page and, where appropriate, notified to you via email. Please check back frequently for updates.

10. How to Make a Complaint

If you have a complaint about how we use your data, please contact us using the details below. If we do not address your complaint to your satisfaction, you may contact the Information Commissioner’s Office (ICO) on their helpline: 0303 123 1113. For more information, visit https://ico.org.uk.

11. How to Contact Us

For data protection matters, we are the data controller. If you have any queries or concerns about your data or this policy, please contact us:

FAO: Nav Salimian
Claudio Lugli Womenswear Ltd
Unit 16/17 NCR Business Centre, Great Central Way, London NW10 0AB, United Kingdom
Phone: 0208 450 1274
Email: info@claudioluglishirts.com