Website privacy notice

Privacy Notice

This notice explains how Charles Tyrwhitt Shirts Limited ("We") collects personal data from you, why we collect it, how we process it and where we may disclose it to other entities.

We are committed to complying with the Data Protection Act 1998 and the EU General Data Protection Regulation for the purposes of data protection and privacy.

Information We May Collect From You

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 and process the following data about you:-

• Identity Data includes first name last name.
• Contact Data includes delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Technical Data includes internet protocol (IP) address 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.
• Transaction Data includes details about payments from you and other details of products you have purchased from us.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect and use Aggregated Data such as statistical or demographic data for internal purposes.

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 and genetic and biometric data). 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 but we will notify you if this is the case at the time.

How We Use Your Information

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.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 where more than one ground has been set out in the table below.

How We Use Your Information

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Necessary for our legitimate interests (to be able to create a profile for customers)
To respond to your enquiry submitted on the site, at one of our local stores or via phone, live chat, post or otherwise	Identity Contact Profile	Necessary for our legitimate interests (to provide customers with the products)
To process and deliver your order including: Manage payments Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about our services that may be of interest to you	Identity Contact Marketing and Communications Profile Technical	Necessary for our legitimate interests (to develop our products/services and grow our business)

Direct Marketing Communications

We may use your data to enable us to send you post and emails with information about our goods and services that we believe may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased goods from us and, in each case, you have not opted out of receiving that marketing. We may permit trusted retail partners to use your data in order to provide you with information about their goods and services by post. We will do this when we believe it is in our mutual legitimate interest to do so.

By trusted retail partners, we mean organisations operating in the following categories:-

• Charities
• Clothing
• Collectables
• Food and Wine
• Gardening
• Gadgets and Entertainment
• Health and Beauty
• Holidays and Leisure
• Household Goods
• Home Interiors

You have the right to withdraw from or amend the receipt of direct marketing communications. If you would like to do this then simply contact the Data Controller and let us know. If you do decide to do this then you will miss out on news of the fantastic offers that we would like to make you aware of.

Disclosure of Your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 or one of our connected companies.

We may disclose your personal information to third parties:-

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
• If Charles Tyrwhitt Shirts Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Charles Tyrwhitt Shirts Limited, our customers, or others

Data Sharing

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. We do not share email addresses for the purposes of data pooling.

Fraud Prevention

We may also exchange your information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Where false information or fraud is suspected, we may pass this information to fraud prevention and law enforcement agencies.

Retention of Data

We retain your information for as long as you hold an account with us. This enables us to maintain an ongoing relationship with you and allows us to service the orders that you place with us. We follow a data retention schedule; this has been put in place to ensure that we retain the minimum amount of personal data about you.

Sensitive Information

We ask that you not send or disclose any sensitive personal information to us either through our website, post, email, text message, live chat, telephone call or by any other method. For clarity, sensitive personal information means information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership.