1. Introduction and General Terms

 

 Last updated: July 2024

We are committed to respecting your privacy and protecting your personal data. This privacy policy(“Policy”) sets out how we use personal data relating to you and applies to all use of your personal data by Threads Styling Ltd, a company registered in England and Wales under company number 07093672 and whose registered office is at Telephone House, 6th Floor, 69-77 Paul Street, London, England, EC2A 4NG (“Threads”, “we”, “us” or “our”in this Policy).

This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our global concierge business that sources and delivers bespoke luxury fashion and other products for women, men and children (“ConciergeServices”) and our online shopping business that allows you to purchase bespoke luxury fashion and other products for women, men and children via social media platforms (including Instagram) (“Social Media Shopping Services”, and together with the Concierge Service, the “Services”). In limited cases, we may also collect personal data through our website https://www.threadsstyling.com/ the “Website”).

We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including without limitation the Data Protection Act 2018 and the UK GDPR (as defined in the Data Protection Act 2018). Where we decide the purpose or means for the processing of your personal data, we are the “data controller”.

You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
If you have any concerns over privacy, or this Policy, contact us at email: privacy@threadsstyling.com
 

2. WHAT INFORMATION WILL THREADS COLLECT ABOUT ME?

 

Providing the Concierge Services to you (including prospective customers)
What personal data we will collect: Name, address, clothing size, age, gender, telephone number, email address and any other information which is provided by you (“General Data”).

How do we collect it: You will provide this personal data to us via chat-based media such as WhatsApp or email when requesting our Concierge Services.

How we will use it:
To pursue our legitimate interests of:

• promoting the success of our business (e.g. by suggesting products and Concierge Services that may be of interest to you, taking steps with a view to entering into any terms or agreements with you);
• responding to your queries or requests; and
• improving the delivery of our Concierge Services (e.g. by building and maintaining your client profile).
• providing the Concierge Services to you (excluding prospective customers)

What personal data we will collect: General Data, shipping address, billing address and payment information (your credit card number and bank account details).

How do we collect it: You will provide this personal data to us (including via our secure payments page https://pay.threadsstyling.com/ ).

How we will use it:

• To provide you with the Concierge Services in order to perform our obligations in accordance with any terms or agreements we have in place with you (including our Terms and Conditions https://www.threadsstyling.com/pages/terms-conditions) (e.g. placing orders, purchasing products on your behalf and in accordance with your instructions and delivering the products to you).
• To pursue our legitimate interests of:
• promoting the success of our business (e.g. providing you with a tailored and bespoke service, providing you with information about the Concierge Services that we offer);
• responding to your queries or requests; and
• improving the delivery of our Concierge Services (e.g. analysing certain types of information that you submit to us in your chats and emails with our personal shoppers to create chat data insights).

Who we will share it with: We may share your personal data with our selected third-party retailers and suppliers, and our third-party retailers will have their own processing terms.

We may use a third-party payment services provider to process payment for our Concierge Services, Stripe (a PCI Service Provider Level 1 certified platform), who will store, collect and process your payment details over SSAL (Secure Sockets Layer). When using Stripe, our servers will not have access to your payment information.

Providing the Social Media Shopping Services to you
What personal data we will collect: General Data, shipping address, billing address, payment information (your credit card number and bank account details) and information relating to your social media profiles (including usernames and social media handles).

How do we collect it: You will provide this personal data to us (including via our secure payments page) or we will collect it via the relevant social media platform.

How we will use it:

• To provide you with the Social Media Shopping Services in order to perform our obligations in accordance with any terms or agreements we have in place with you (including our Terms and Conditions https://www.threadsstyling.com/pages/terms-conditions) (e.g. placing orders and delivering the products to you).
• To pursue our legitimate interests of:
  • promoting the success of our business (e.g. providing with a quality and efficient service, providing you with information about the Social Media Shopping Services that we offer);
  • responding to your queries or requests; and
  • improving the delivery of our Social Media Shopping Services.

Who we will share it with: We may share your personal data with our selected third-party retailers and suppliers, and our third-party retailers will have their own processing terms.

We may use a third-party payment services provider to process payment for our Social Media Shopping Services, Stripe (a PCI Service Provider Level 1 certified platform), who will store, collect and process your payment details over SSAL (Secure Sockets Layer). When using Stripe, our servers will not have access to your payment information.

Compliance and prevention of fraud and illegal activity
What personal data we will collect: Image of identity documents, information describing the identity document, image of your face, numerical biometric data, name, name of individual paying for the Services on your behalf (if applicable), date of birth, address, information about your credit history and any other information to prevent fraud or other illegal activities.

How do we collect it: You will provide this personal data to us via email or our payments page or we may collect this personal data from third-party service providers (such as credit agencies).

How we will use it:

• To pursue our legitimate interests of ensuring that use of our online Services is lawful and non-fraudulent, does not disrupt the operation of our Services and protects our staff or other individuals from harassment.
• To comply with our legal obligations (e.g. complying with AML and anti-fraud obligations, complying with HMRC requirements for retaining records of customer purchases and transactions) and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention)

Who we will share it with: Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content. If we do, we will only do so because: (i) there is a legal basis to justify that processing; (ii) the law permits us to do so (such as so that we can carry out legal rights and obligations necessary in the context of the particular role); and (iii) we find it necessary.

We may share your personal data with our selected third-party retailers and suppliers (such as Onfido), and our third-party retailers will have their own processing terms.

Marketing

What personal data we will collect: General Data, phone number (if you opt-in for SMS marketing), and information concerning your interaction with our social media pages (such as posts, comments, likes, retweets, or similar).

How do we collect it: You will provide this personal data to us via email, chat-based media such as WhatsApp, or we may measure your engagement on social media platforms (e.g. Instagram). Additionally, your phone number will be collected through sign-up forms, during purchases, or other interactions with our services if you opt-in to SMS marketing.

How we will use it: To pursue our legitimate interests of:

• Promoting the success of our business (e.g. to assist with our advertising campaigns, for business development purposes);
• Providing you with recommendations relating to our Services;
• Responding to your queries or requests; and
• Improving the delivery of our Services (e.g. analyzing certain types of information that you submit to us in your chats and emails with our personal shoppers to create chat data insights).
• The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS

If our marketing communications, including SMS marketing messages, are not of interest to you, you can opt-out at any time by following the instructions provided in the messages or by emailing us at privacy@threadsstyling.com.

Who we will share it with: When you click on adverts which we have placed on third-party channels (e.g. Facebook Inc., Twitter Inc., and Google Inc.), we may share your personal data with third-party channels. We may also share your phone number with third-party service providers who assist us in delivering SMS marketing messages, ensuring they comply with our data protection standards and only use your information for the specified purpose.

Analytics

What personal data we will collect: Information about your:

• Equipment (including your 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); and
• Browsing actions and usage patterns on the Website, our public pages (e.g. our payment page), and on our social media pages (including Instagram and Snapchat).

How do we collect it: Our Website collects this information to help analyze how visitors use the Website and to compile statistical reports on Website activity. We may also receive the above information about you from Google, Inc. (based outside the EU) through their Google Analytics platform. Please see below for further information. To find out more about Google Analytics and to learn how to opt out, please visit: Google Analytics Opt-Out.

We also process information that we collect via Instagram and Facebook to understand how customers interact with our social media pages and to compile statistical reports regarding that activity.

How we will use it: To pursue our legitimate interests of:

• Promoting the success of our business (e.g. by understanding how individuals interact with our social media pages and to compile statistical reports regarding that activity, marketing purposes);
• Improving the delivery of our Services (e.g. by providing a better Service and source of information to visitors, debugging purposes); and
• Providing you with recommendations relating to our Services.

Who we will share it with: Analytics service providers (including Google Inc., Social Bakers, Splunk, and Instagram (“Native”)).

 

3. DATA SHARING

We will share your information with third parties only in the ways that are described in this Policy. If you would like to find out more about how the third parties listed in this Policy use your information, this should be set out in their respective privacy policies.

We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard this information.

In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your profile and/or a prominent notice on the Website of any changes in ownership or use of your personal data, as well as any choices you may have.

We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.

We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.

If you share our content with friends through social networks – such as Instagram WhatsApp, Snapchat and WeChat – you may be sent cookies from these third-party websites and services. We can’t control the setting of these cookies, so we suggest you check the third-party websites and services for more information about their cookies and how to manage them.

 

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

 

4. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have certain rights over the way we process personal data relating to you, some of which are not absolute and are subject to certain additional requirements under data protection laws. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:

• for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
• to restrict, stop processing, or to delete your personal data;
• for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
• to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/.

To make a request in relation to any of the aforementioned rights, please send your request to privacy@threadsstyling.com.

You may request deletion of your personal data by sending an email to privacy@threadsstyling.com. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.

For data processing activities for which we rely upon your consent, you can withdraw your consent at any time by using the tools provided or otherwise by contacting us at privacy@threadsstyling.com.
 

5. DATA RETENTION

We will hold your personal data on our systems for as long as is necessary for the relevant Services, as required by law, for accounting or regulatory purposes or as otherwise described in this Policy.

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.
 

6. CHILDREN

If a parent or guardian becomes aware that his or her child, who is under the age of 18, has provided us with information without their consent, he or she should contact us at privacy@threadsstyling.com. We will delete such information from our files within a reasonable time.

 

7. SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors and customers. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

 

8. CHANGES

We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.

 

9. INTERNATIONAL DATA TRANSFERS

Where we use data processors outside the UK and European Economic Area, and transfer personal data to a country which does not provide an adequate level of protection, we seek to use contracts which give personal data the same protection it has in the European Economic Area and the UK. For more information, please contact us at privacy@threadsstyling.com. Your personal data can be removed on request.

 

10. COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners and operators of the site. The table below explains the cookies we use and why.

 

How do I change my cookie setting?

You can select your cookie settings through the cookie consent tool on the Website when you first visit. Most web browsers and mobile devices also allow some control of most cookies and similar devices through the browser and mobile device settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org. Find out how to manage cookies on popular browsers:

• Google Chrome (here)
• Microsoft Edge (here)
• Mozilla Firefox (here)
• Microsoft Internet Explorer (here)
• Opera (here)
• Apple Safari (here)

To find information relating to other browsers, visit the browser developer's website. To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.