Welcome to the privacy notice of Thomas Pink Shirtmaker Limited (“Thomas Pink”, “us, “we”, “our”), trading as Thomas Pink.

This policy (together with our terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting thomaspink.com you are accepting and consenting to the practices described in this policy.

Thomas Pink respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how Thomas Pink collects and processes your personal data.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Thomas Pink Shirtmaker Limited is the controller and responsible for your personal data.

Contact details

Our full details are:

Full name of legal entity: Thomas Pink Shirtmaker Limited

Email address: customerservice@thomaspink.com

Postal address: Suite 1, 7th Floor, 50 Broadway, London, SW1H 0BL, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. We work with Rakuten Advertising who will drop cookies.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes name, title, date of birth and gender.

• Contact Data: includes billing address, delivery address, email address and telephone numbers.

• Demographic Data: includes post code, preferences and interests.

• Financial Data: includes payment card details.

• Transaction Data: includes details about payments to and from you and other details of products you have purchased from us.

• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data: includes information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you 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.

• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

We may 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 in law 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.

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, genetic data and biometric identifiers). 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 goods or services). In this case, we may have to cancel a product or service you have with us. We will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, technology platforms or otherwise. This includes personal data you provide when you:

-   search for a product;

-   create an account on our website;

-   subscribe to our service;

-   place an order on thomaspink.com (our site);

-   participate in discussion boards or other social media functions on our site or our social media pages/forums;

-   request marketing to be sent to you;

-   enter a competition, promotion, survey or question and answer sessions; or

-   give us some feedback or report a problem with our site.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at the bottom of this page for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

-  Technical Data from analytics providers such as Google based outside the UK.

-  Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Adyen and Paypal based inside and outside the UK.

- We work with Rakuten Advertising who will drop cookies.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need 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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to collaborate with, or 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.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may transfer your data outside the United Kingdom (UK).

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries in compliance with UK adequacy regulations.

• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the UK, Europe and the US.

• In addition, we have a system of principles, rules and tools (known as binding corporate rules) designed to ensure effective levels of data protection where we transfer personal information to companies within our group that are outside the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Encryption of payment information is provided via Adyen and PayPal.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. See below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data

Commonly known as a "data subject access request" – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, 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.

Object to processing of your personal data

The right to object exists where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent

This right exists 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other 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.

Time limit to respond

We 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.

Thomas Pink is required to inform you when we use tracking features called "cookies" on our website. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does in no way give us access to your computer or any information about you, other than the information you choose to share with us.

Customers can either accept or decline the use of cookies. By giving your consent for Thomas Pink to use cookies, you are enabling us to provide the best possible experience and service. Accepting cookies enables Thomas Pink to provide the best customer experience while visiting our website. Customers may wish to decline cookies. However, if so, certain features of the Website may not function fully or as intended by Thomas Pink.

All cookies used by this Website are used in accordance with current UK cookie law. Thomas Pink has taken steps to ensure that our customer’s privacy is protected and respected at all times.

How we use cookies

A cookie is a small, text file which asks permission to be placed on your device's hard drive when you visit a website. We use these cookies to understand where our customers come from and how they use our website enabling us to constantly improve our customer’s website experience. Cookies also enable us respond to our customers as individuals, tailoring operations to individual needs, likes, dislikes and preferences. Cookie data is anonymised, stored temporarily, and does not include sensitive information such as your name, address or credit card details.

Thomas Pink use both first- and third- party cookies that fall into the following four categories:

Essential cookies: These are cookies that allow customers to access our website, browse and shop our products, and navigate through pages. These are required in order to provide customers with the basic functionality of our website.

Performance cookies: These cookies allow Thomas Pink to better understand how our customers use our website. Performance cookies will collect information such as how many visitors the site receives, as well as measuring usage. This in turn also allows us to understand how effective our marketing is and where we can improve to deliver a more relevant shopping experience for our customers.

Functionality cookies: Functionality cookies help us to improve the functionality of our site. While they are not technically essential, they do contribute to easier navigation and therefore an improved shopping experience with Thomas Pink.

Targeting cookies: Thomas Pink additionally uses cookies to track browsing behaviour to better understand what products our customers are interested in. This allows us to provide tailored product offerings and marketing materials which are relevant to our customers.

Cookies may be either temporary or permanent. Temporary cookies last for the duration of a customer’s visit, being deleted when a web browser is closed. These are primarily used to identify website navigation and to support security and basic functionality. Permanent cookies are enabling Thomas Pink’s website to remember customers’ actions and preferences for future visits.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

External third parties means:

• Service providers acting as processors based inside and outside the UK who provide IT, ecommerce, delivery and system administration services

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in inside and outside the UK who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

• Advertisers and advertising networks based inside and outside the United Kingdom that require the data to select and serve relevant adverts to you and others – we do not disclose information about identifiable individuals to our advertisers, but we may provide them with Aggregated Data.

• Analytics and search engine providers based inside and outside the United Kingdom that assist us in the improvement and optimisation of our site.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at customerservice@thomaspink.com or by mail using the details provided below:

Thomas Pink Shirtmaker Limited

Data Protection Officer

Suite 1, 7th Floor
50 Broadway
London, SW1H 0BL

United Kingdom