Privacy Notice

• 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 BOOHOOMAN

Our commitment to you

• fulfil your order(s)
• fulfil orders made on your behalf (e.g. e-gift card orders)
• 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 -provide and personalize our website and applications -support, develop, troubleshoot, and debug our website and applications -provide you with information, products, or services that you request from us -create, maintain, customize, and secure your account with us -help maintain the safety, security, and integrity of our websites, applications, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; -debug to identify and repair errors that impair existing intended functionality in our websites or applications -internally test, research, analyse, and develop our products and services, including to develop and improve our websites and applications, and to develop, improve, or demonstrate our products and services -carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our terms of use or terms of sale -fulfill any other purpose for which you provide it.

How we keep your data safe and secure

The personal data we collect

• 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.

• Coast
• Dorothy Perkins
• Wallis
• Burton
• boohoo
• Prettylittlething
• BOOHOOMAN
• Karen Millen
• Nasty Gal
• Miss Pap
• Warehouse
• Debenhams References to "we", "us", and / or "our" are to the companies that make up the group of companies. Details of our Data Protection Officer responsible for overseeing questions in relation to this privacy notice including how your data is processed by companies in the group, and our details are set out in the “How to Contact Us” section at the end of this notice.

How we collect your data

• 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 BOOHOOMAN 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 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

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 automated decision making to assist fraud prevention and detection. (2) To protect our customers, boohoo group companies and website from fraud and theft, which involves automated decision making to assist such fraud prevention and detection	Identity . Contact . Financial . Transaction	(1) Performance of a contract with you (2) For automated decision making we consider that fraud detection and prevention is in our legitimate interests to ensure that fraudulent transactors are unable to benefit from our services and in the legitimate interest of the public as a whole due to the impact of fraud on the consumer market; we also consider it a necessary element of entering into a contract with you that we are able to verify your identity and prevent fraud.
(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); (2) Notifying you about changes to our services, terms and conditions or privacy notice; asking you to leave a review or take a survey.	Identity . Contact . Profile . Marketing and Communications	(1) Consent (2) Performance of a contract with you
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).

How long we keep your data for

Marketing preferences, adverts and cookies

Marketing - your preferences

• 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).

• 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@debenhams.co.uk and confirming to them your preferences to opt-out.

Cookies

Online ads

Our use of analytics and targeted advertising tools

Links to other websites and third parties

How we share your data

• 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 www.klarna.com/uk/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 at: 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.

WORLDPLAY

Do Not Track Signals

Accessing, Correcting, and Deleting Your Personal Data

Jurisdiction-Specific Privacy Rights

Your GDPR Privacy Rights

Changes to this privacy notice

How to contact us