Privacy Policy

At naked-underwear.com, we take the protection and respect of your personal data privacy very seriously. This privacy notice explains the methods of collection, use, transfer, and disclosure of your data by NAKED underwear. It applies to data collected when you use our websites, iOS and Android applications, when you interact with us via social media, by email or phone, or when you participate in our contests or events. It covers :

• The personal data we collect
• How we collect your data
• How we use your data
• Marketing, advertising, and cookies preferences
• Links to third-party websites and services
• How we share your data
• Your rights
• Changes to this privacy notice
• How to contact us

Our commitment to you

We take the protection of your personal data seriously and are committed to processing it in a fair, legal, and transparent manner. This privacy notice outlines the types of personal data we collect about you and how it is used.

We will collect and use your personal data only to :

• fulfill your orders
• keep you informed of the latest offers and trends
• offer you a better shopping experience
• provide products more suited to your preferences and interests
• improve our services
• comply with our legal obligations

How we protect your data

We have implemented appropriate organizational security and protection measures to protect your data against any accidental or unauthorized loss, use, access, alteration, or disclosure.

Communication between your browser and our website uses a secure encrypted connection in all contexts where your personal data is involved.

We require all third parties engaged to process your personal data on our behalf to implement security measures to protect your data and to process it in accordance with the law.

In the unfortunate event of a personal data breach, we will inform you and any applicable regulatory body to the extent that the law requires us to do so.

The personal data we collect

Personal data is information about an individual from which that person can be identified. It does not include anonymized data, where identity and identifying information have been removed.

Although our site is designed for the general public, we we do not knowingly collect any information from children under 13, nor do we sell products to them. If you are under 13, you are not allowed to use or submit information on our site.

We collect personal data from the following categories:

• Identity data includes information such as: first name, last name, title, date of birth (optional), profession, personal description, photo, and gender.
• Contact data includes information such as: email address, billing address, delivery address, country, phone number, loyalty program membership number, and social network ID (if you log in via a social network).
• Financial data includes information such as payment card details and bank account information.
• Transaction data includes information such as details of your purchases and order fulfillment (cart number, order number, subtotal, title, currency, discounts, shipping, number of items, item price alone, category, tax, etc.); payments to and from you, and details of other products and services you have obtained from us, correspondence or communications with you regarding your orders, and details of rewards and bonuses awarded.
• Technical data includes information about devices used to access our services, your IP address, login data, 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 you have made, your interests in products and styles, preferences, feedback, and survey responses.

• Usage data includes the following information: how and when you use our site/application, your browsing patterns, what you have searched for; site or application performance statistics, traffic, location, weblogs, and other communication data; loyalty program activities; and details of all other products and services NAKED underwearyou use.
• Marketing and communications data includes information such as: your preferences for receiving promotional campaigns from us and our third parties, as well as 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 are not considered personal data as they do not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the site. However, if we combine or connect aggregated data with your personal data to directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How we collect your data

We may collect personal data about you in the following ways :

• Direct interactions – you may provide us with your identity, contact, financial, transaction, profile, and marketing and communication data (as described above) by filling in forms, entering information online, or corresponding with us by mail, phone, email, or otherwise. This includes personal data you provide, for example, in the following circumstances :
  
  
  • when you create an account or purchase products on our website ;
  • when you subscribe to our newsletter, discussion forums, social networking sites, or when you create wish lists ;
  • when you enter a competition ;
  • when you join a loyalty program NAKED underwear;
  • when you participate in a market study ;
  • when you contact us for information or to report a problem (by phone, email, social media, or messaging service) ;
  • when you use the “refer a friend” function on our website ; or
  • when you log in to our site via social networks.

• Automated technologies or interactions – when you interact with our site, we may automatically collect the following types of data (as described above) : Technical data about your equipment, usage data regarding your actions and browsing patterns, and contact data when tasks performed via our site remain incomplete, such as incomplete orders or abandoned carts. We collect this data using cookies, server logs, and other similar technologies. Please refer to our cookie policy for more details.

• Third parties – we may receive personal data about you from third-party companies, including :
  
  
  • Technical data from third-party companies, including analytics providers like Google. For more information, please refer to the ‘Marketing preferences, advertisements and cookies’ section.
  • Technical data from partner networks through which you accessed our site ;
  • Identity and contact data from social media platforms when you log into our site via one of these platforms ;
  • Contact, financial, and transactional information from technical, payment, and delivery service providers.

How we use your data

Legal basis for processing your personal data

We will collect and process your personal data only in cases permitted by law. As the data controller, the law allows us to collect and use your personal data under different conditions depending on the method and reasons for collection.

We collect your personal data only if :

• 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 you make, fulfill your orders, or provide you with support related to an order, or
• the processing of this data is in our legitimate interests and is not overridden by your rights, or
• we have a legal obligation to collect or disclose your personal data.

 

How we use your personal data

Your personal data is used by NAKED underwear to support a range of different activities. These activities are listed in the table below along with the types of data used and the legal bases we rely on to process them, including, where applicable, our legitimate interests. Please note that we may process your personal data in different ways permitted by law, depending on the specific activity concerned. Please contact us if you need more details on the specific legal basis we rely on to process your personal data when more than one ground has been defined in the table below.

Purpose/Activity	Type of data	Legal basis for data processing, including legitimate interests
Create an account and register as a new customer (directly or via social networks).	Identity Contact	Execution of a contract with you
Process and deliver your order, including the following activities: recording your order details; keeping you updated on the order status; processing payments and refunds, collecting funds owed to us; and making automated decisions for fraud prevention and detection.	Identity Contact Transaction Financial	Execution of a contract with you Necessary for our legitimate interests (e.g., to recover debts owed to us) For automated decisions, it is in our legitimate interest to ensure fraud detection and prevention measures are in place to ensure that fraudsters cannot benefit from our services; We also consider it necessary for the conclusion of a contract with you that we are able to verify your identity and prevent fraud.
Manage our relationship with you, including the following activities: providing you with any information, products, and services you request from us; informing you of changes to our services, terms and conditions, or privacy notices; asking you to leave a review or participate in a survey.	Identity Contact Profile Marketing and communications	Execution of a contract with you Necessary for our legitimate interests (keeping our records updated and studying how customers use our products and services)
Allow you to participate in a contest, event, or survey, or receive a reward valid for purchases on our site.	Identity Contact Profile Usage Marketing and communications	Necessary for our legitimate interests (studying how customers use our products and services, developing them, and growing our business) When you have decided to participate in a contest or event, for the execution of a contract with you
Administer, protect, and improve our business and our site/application, including through the following activities: troubleshooting, data analysis, testing, system maintenance, support, data analysis, reporting, and data hosting; set default options for you, such as language and currency.	Identity Contact Profile Technical Financial Marketing and communications	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and fraud prevention and detection) Necessary to comply with a legal obligation
Providing you with content, online advertisements, and information relevant to you, and measuring the effectiveness of the advertisements provided.	Identity Contact Profile Usage Marketing and communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)
Use data analysis to: improve our site, products, services, marketing, customer relationships, and experiences; and for market research, statistical and survey purposes.	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business, and to inform our marketing strategy)
Recommend products, services, discounts, and offers that may be of interest to you, including sending you this information by email, post, or SMS.	Identity Contact Technical Usage Profile Marketing and communications	Necessary for our legitimate interests (to develop our products/services and grow our business) or Consent. For further details, see the section "Marketing preferences, advertisements, and cookies"
Notify or remind you by email of any task done via our site that remains unfinished, such as incomplete orders or abandoned carts.	Identity Contact Usage	Necessary for our legitimate interests (to improve our customers' shopping experience)
To protect our customers and the group's sites NAKED underwear against fraud and theft	Identity Contact Profile	Necessary for our legitimate interests (to detect and prevent fraud)

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 other purposes, we will inform you and explain the legal basis that allows us to do so. We may process personal data without your consent, in accordance with the above rules, where required or permitted by law.

If you have any questions about the use of your personal data by NAKED underwear, please contact our data protection officer at the address contact@naked-underwear.com.

Retention period of your personal data

We will not retain your personal data longer than necessary to fulfill the purposes for which it was provided and to ensure compliance with our legal obligations. Further details regarding our data retention periods are available upon request. 

Marketing preferences, advertisements, and cookies

Marketing - your preferences

We may send you marketing communications and promotional offers :

• if you have opened an account with us or purchased products from us, or if you have registered for a promotion or event, and you have not opted out of receiving the marketing communication in question (according to your preferences, as explained below) ;
• by email if you have subscribed to our newsletters ;
• if you have provided us with your contact details when registering for a competition and have consented to receive such marketing communications (according to your preferences, as explained below).

We may use your identity, contact, technical, transactional, usage, profile, and marketing data and communication to give you an idea of what we think might interest you and send you information about products and offers that may be relevant to you.

We will ask for your preferences regarding receiving marketing communications via email, postal mail, SMS, and other communication channels.

From time to time, we may also include in your order promotional items, services, or offers from other third-party companies that may interest you.

Regarding third-party marketing communications, we will obtain your explicit consent before sharing your personal data with third parties for marketing purposes.

You will always have full control of your marketing preferences. If you no longer wish to receive marketing information from us (or from a third party, if applicable), at any time:

• you can unsubscribe or 'opt-out' of communications by using the unsubscribe button and following the link included in the footer of any marketing email; or
• account holders can withdraw their consent simply by accessing My Account and changing their 'Contact Preferences'.

We will process all unsubscribe requests as soon as possible, but please note that due to the nature of our computer systems and servers, it may take a few days for any unsubscribe request to be executed.

Cookies

Our site uses cookies to distinguish you from other users and track your visits. This allows us to improve our site and provide you with a better user experience during your visits. Cookies also allow us, as well as our advertising networks, to offer you advertisements that match your preferences and interests.

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

For more information about the cookies we and our third-party providers use and why we use them, see our Cookie Policy.

Online Advertising

Thanks to our online advertisements, stay connected with our news and find our products. Like many other companies, we display banners and ads NAKED underwear when you browse other websites and applications, based on your contact, technical, usage, and profile data. We do this using a variety of digital marketing networks and advertising exchanges and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers. But also specific services offered by certain sites and social networks like Facebook's 'custom audience' service.

How do we use analytics and targeted advertising tools ?

With a set of analytics and targeted advertising tools, we display relevant content for you on our site and online ads on other sites and apps (as mentioned above), we provide you with relevant content through commercial ads and evaluate the effectiveness of the provided advertising. For example, we use tools such as Google Analytics to analyze targeted advertising data by interest and/or third-party consumer data (such as age, gender, and interests) to target and improve marketing campaigns, marketing strategies, and content on our site. We may use other tools offered by third parties, such as Facebook, Content Square, Adroll, Responsys, Criteo, and Bing to perform similar tasks, using your contact, technical, usage, and profile data.

To disable targeted advertising, simply disable your 'cookies' in your browser settings (see Cookie Policy for more details) or, disable the Advertising Settings applied to the concerned third party. For example, you can disable the Google Display advertising features using their . As an additional measure to protect your privacy, you can also use the .

The Digital Advertising Alliance (composed of companies like Google, Responsys, and Facebook) offers a tool called WebChoices which allows for a quick analysis of your computer or mobile devices, to find which participating companies have provided access to personalized ads on your browser and adjust your preferences accordingly.

If you would like more information about the data collected by these third parties or how they use it, please contact us.

Links to third-party websites and services

Our site may, at times, contain links to and from other sites of our networks, advertisers, and affiliate partners, or to social media platforms. If you click on any of these links, please note that these sites have their own privacy policies and we are not responsible for these policies. Please check these policies before submitting your personal data to these sites.

Marketing Text and notifications (if applicable):

By entering your phone number phone at checkout and by initiating a purchase, by subscribing via our subscription or a keyword, you agree that we may send you SMS notifications (for your order, including abandoned cart reminders) and SMS marketing offers. Marketing text messages will not exceed X per month. You can unsubscribe from any other text message by clicking on the unsubscribe link. Sending text messages or using automations requires you to transmit the phone numbers or names of recipients to our importer. We will store and use this data to show you campaign analysis and results, including message delivery status, sending status, and in some cases, whether the purchase resulted in a sale. If you decide to use our link shortener in text messages, we will collect information to know whether the link was clicked or not and use it to display results in your analytics. Any other third-party service you may decide to use outside the scope of smsbump.com (third-party link shortener, GA tracking, etc.) you will be referred to their specific third-party policies that you must accept. When sending text messages, we will transmit the data to our text message operator to perform their delivery. Information is only shared with our operator at the time of initializing a marketing campaign. If your recipients no longer wish to receive messages, they must reply to the message with STOP or contact us at the email address below so we can successfully unsubscribe them.

How we share your data

It may happen that we share your personal data with the parties designated below :

• if you have consented to do so. For example, if you have consented to receive commercial offers from third parties or relating to third-party products and services (including those offered in co-branding or as part of a joint campaign), it may happen that we transmit your information to the third parties in question for the purpose of sending you such advertisements ;
• to business partners, suppliers, contractors, and any other third parties we use in the course of our activities, for the reasons stated in the table above in the section ‘How we use your data’, including :

• third-party service providers we engage for the supply of IT systems and software and for hosting our site ; ;
• third-party service providers to whom we entrust the delivery of products you order ;
• third-party service providers with whom we subcontract to send you emails and postal mails, including regarding incomplete orders or abandoned carts or commercial advertisements, to provide data cleaning services and marketing and advertising services ;
• analytics and search engine system providers who assist us in improving and optimizing our site ;
• partner networks through which you accessed our site ;

• to any third party to whom we we can decide to sell, transfer, or merge shares of our company or our assets. Furthermore, we may seek to acquire other companies or merge with them. In the event of a change within the company, the new owners have the right to use your personal data in the same manner as the previous ones, under the terms of this privacy notice.
• To protect our customers and the group sites NAKED underwear against fraud and theft, we may share your personal data necessary to perform identity checks and personal data (including data about your age, name, and location) with other companies in the group NAKED underwear and third-party organizations (including law enforcement agencies) involved in preventing and detecting fraud and reducing credit risk. Please note that these third parties may retain a copy of the information we provide them for this purpose;
• we may share personal data with Ravelin and/or Risk Guardian and/or other fraud prevention and analytics service providers, to perform fraud prevention checks. If personal data is provided to Ravelin, Ravelin will also use this personal data to improve its service and machine learning to enhance automated processing. A copy of Ravelin's privacy notice can be viewed at https://www.ravelin.com/privacy-policy-new, which explains how Ravelin will use your personal data for these purposes; and
• if we are required to disclose or share your personal data in order to comply with any legal obligation; or
• to our professional advisors: lawyers, bankers, auditors, and insurers, who provide banking, legal, consulting, insurance, and accounting services.

Data and countries outside Europe

The personal data we collect from you may be transferred and stored in countries outside the European Economic Area ("EEA") through mechanisms provided by law for cross-border data transfer. They may be processed by staff working outside the EEA on our behalf or on behalf of one of our suppliers. The staff handling these transfers may be involved, among other things, in fulfilling your order, processing your payment data, and providing support services. We will take all necessary measures to ensure that your data is processed securely and in accordance with this privacy policy.

Whenever we transfer personal data outside the EEA, we ensure a similar level of protection by ensuring appropriate safeguards are in place, as required by law. This includes imposing specific contractual clauses approved by the European Commission that ensure personal data protection equivalent to that offered in Europe. You can find more information about this here http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32010D0087

Please contact us if you would like more information about the countries to which we can transfer your personal data and the specific mechanism we use when transferring your personal data outside the EEA.

Your rights

You have various rights under the data protection law. Where applicable, you have the right to: 

• request access to your personal data
• request the rectification of your personal data
• request the erasure of your personal data
• request a restriction on the processing of your personal data
• request the transfer of your personal data
• object to the processing of your personal data
• object to automated decision-making
• Request human intervention

 Some details about each of these rights. If you wish to exercise any of these rights, please send us an email at contact@naked-underwear.com

Request access to your personal data

You have the right to obtain a copy of your personal data that we hold and certain information related to the processing of your personal data.

Request rectification of your personal data

You have the right to have your personal data rectified if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your information or by sending us an email at  contact@naked-underwear.com

Request erasure of your personal data

You have the option to request NAKED underwear to delete your personal data when we have no good reason to continue processing it. Please note, however, that we may not always be able to comply with your erasure request 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 the right to request NAKED underwear to stop processing your personal data in certain scenarios, for example, if you want us to establish the accuracy of the data, or if you have objected to our use of your data, because we need to verify if we have legitimate compelling reasons to do so. In the case of restricted processing, we are allowed to retain enough information about you to ensure compliance with the restriction in the future.

Request to transfer your personal data

You have the right to receive a digital copy of your personal data or to request the transfer of your personal data to another company. However, please note that this right only applies to automated data for which you have given us permission to use or that we have used to execute a contract with you.

Refusal of processing your personal data

You have the right to object to the processing of your personal data even when we believe we have a legitimate interest in processing it (as previously indicated). You also have the right to object to the processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling and legitimate reasons to process your data that override your rights and freedoms.

Request human intervention for automated decision-making and profiling.

You have the right to request human intervention when we make automated decisions in processing your personal data. If necessary, this type of processing is allowed, within the framework of our contract with you, provided that appropriate preventive measures are in place or that your explicit consent has been obtained.

We strive to respond to all legitimate requests within one month. It may sometimes take us longer than a month if your request is particularly complex or if you have made a series of requests. If this is the case, we will keep you informed. We may request your specific information, which will help us confirm your identity and ensure your right to exercise any of the aforementioned rights. This is a security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it.

Right to file a complaint

For any concerns or complaints about how we handle your data, please send us an email directly at contact@naked-underwear.com. 

Changes to this privacy notice

We may occasionally modify the terms of this privacy notice. In the event of significant changes, we will post updates on our website, on our applications, or we will inform you by email.

How to contact us

We welcome your feedback and are happy to answer any potential questions you may have regarding your data.

Please send your questions, comments, or requests for information to our designated representative and data protection officer, who can be contacted at the address  contact@naked-underwear.com.

This privacy notice was updated on January 3, 2020.

NAKED underwear FR Limited,