Privacy Policy

It is important to us that we handle your personal data with great respect. To protect your personal data, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Information systems and software programs are configured so that personal and identification data are used only when necessary to achieve the specific processing purpose from time to time sought.

This privacy policy explains how we collect and use your personal information. It also describes your rights and how you can exercise them.

It is important that you read and understand the privacy policy and feel secure in our processing of your personal data. You are always welcome to contact us if you have any questions. By visiting our website you are accepting and consenting to the practices described in this policy.

What is a personal data and what is a processing of personal data?

Personal data is any information that may be directly or indirectly attributed to a physical person. Images and sound recordings that are processed digitally can be personal data even though no names are mentioned. Encrypted data and different types of electronic identities (e.g. IP number) are personal data if they can be linked to natural persons.

Processing of personal data is all that happens with personal data. Each action that involves personal data is a ‘process’, regardless of whether it is performed automatically or not. Example of common ‘processes’ are gathering, registration, organisation, structuring, storage, processing, transmission, and deletion.

Who is responsible for the personal data that we collect?

Newbie by Kappahl Limited is a company registered in England and Wales. Our company registration number is 10811237 and our registered office is at 1 Chapel Street, Warwick CV34 4HL, United Kingdom. Our registered VAT number is number 275 0511 19.  For the purpose of Data Protection Act 2018 and the UK General Data Protection Regulation, the data controller is Newbie.

What personal data do we collect about you as a customer and for what purpose (why)?

Online purchase:

Purpose

In order to process an online purchase

Processes performed

Secure safe delivery of the right items to the right person and address, in collaboration with our distribution partners.
Communication with the customer before and after the purchase (order & delivery notifications)
Payment processing, which includes analysis of the payment providers for the purposes of securing payment and preventing fraud.
Handle legal guarantee errands.

Categories of personal data

Name
Delivery address
Billing address
Phone number
Email
Order summary (items bought, amount spent)
Choice of payment gateway
Transaction ID

Legal basis

Performance of a contract. This collection of your personal information is required in order to fulfill obligations under the purchase agreement. If the information is not provided, our commitments cannot be fulfilled, and we must therefore refuse your purchase.

Storage limitation

We save data as long as it is necessary for the legitimate purpose and longest for 36 months (based on the date of your latest communication with us). We can clean out all data before 36 months upon the request of a customer when they ask to be “forgotten”.

Return process:

Purpose

To provide our customer with an excellent return process.

Processes performed

Customers fill in a return information label where they state what items to return and why.
Communication with the customer when the return process is completed, we then refund the money.

Categories of personal data

Name
Address
Order number
Email
Items for return
Reason for return
Amount to be refunded

Legal basis:

Performance of contract. This collection of your personal information is required in order to fulfill our obligations under the return process.

If the information is not provided, our commitments cannot be fulfilled, and we cannot process your return. This is a part of our legal contract with our customers.

Storage limitation

Customer service

Purpose
Our customer service team needs to be able to give help and answer questions.

Processes performed

Communication and response to any questions to customer service (via phone or digital channels, including Social media
Identification
Examination of possible complaints and support cases (including Tech support)

Categories of personal data

Name
Order history
Email
Address (home & billing address)
Correspondence

Legal basis

Legitimate interest. The process is necessary to accommodate your legitimate interests as well as ours in dealing with customer service matters.

Storage limitation

The correspondence is saved for 36 months (based on the date of your latest purchase or the service case). We can clean out all data before 36 months upon the request of a customer when they asked to be "forgotten”.

Newsletter subscribers

Purpose
To be able to communicate to newsletter subscribers the latest news, invites to special events, offers and more.

Processes performed

Communication to subscribers via email

Categories of personal data

Legal basis

Based on consent. The process is necessary to be able to keep our promise to our customers; inform them of latest news, invites and special offers. The process is completely voluntary and takes place only when a customer chooses to become a subscriber.

Storage limitation

We save data as long as the customer choose to stay as a subscriber. If a customer has been inactive for 36 months we may remove the customer from our subscription list.

Marketing of products:

Purpose

To promote Newbie products.

Processes performed

Display relevant product recommendations, give suggestions, remind customers about forgotten/abandoned digital shopping carts in order to simplify future purchases or similar arrangements.

Send direct marketing messages via email, SMS, postal mail, social media (e.g. Facebook and Google).

Creation of targeted messages and lookalike target groups as well as customized target groups on social media (e.g. Facebook and Google) and market Newbie products to third parties.

In order to understand which type of marketing or direct marketing we should use, we perform analyses, e.g. about:

How websites and other digital media are used
Purchase history
Age and geographical information
Results from inquiries

Categories of personal data

Name
Contact information (e.g. address, email, cell number)
Purchase history
Customer segment
Cookie data
Personal choices provided for communication

Legal basis:

Legitimate interest: Our legal basis for the processing of the data is necessary in order to accommodate your and our interest to promote relevant products and services.

Based on consent: Our legal basis for and providing electronical direct marketing messages and processing cookie data is consent.

Storage limitation

For newsletter subscribers, we save data as long as the customer choose to stay as a subscriber. If a customer has been inactive for 36 months, we may remove the customer from our subscription list.

For non-subscribers, we save data as long as it is necessary for the legitimate purpose and longest for 36 months (based on the date of your latest communication with us). We can clean out all data before 36 months upon the request of a customer when they ask to be “forgotten”.

Analytics:

Purpose

To evaluate, develop and improve our service & products for existing and future.

Processes performed

Fraud analysis to offer a secure payment gateway and to prevent fraud.
Supporting our strategic plan for new business locations.
For development and improvement of our range.
Analysis of conversions, open rates and click rates to understand what offers to provide and what items to highlight in order to be more relevant to our customers.

Please note: This analysis is based in the data we collect (e.g. Purchase history, age and gender) and you are sorted into a customer group (so-called customer segments) The analyses is then done on an aggregated level with the help of unidentified pseudonymised data, without any connection to you as an individual.

Categories of personal data

Where you live
Correspondence and feedback regarding our services and products
Purchase and user-generated data (e.g., click and visit history)
Technical data relating to devices used and settings (such as language setting, IP address, browser settings, time zone, operation system, screen resolution and platform).
Onsite visits: such as which pages were visited, response times, download errors, how you reach and leave the service etc.
Gender

Legal basis:

Legitimate interest: Our legal basis when processing your personal data for the purpose to develop and improve our service & products, is based on our legitimate interest.

Based on consent. We may also use personal data received from cookies to improve our service & products. Our legal basis when using cookies for the process is consent, read our cookie policy for more information.

Storage limitation

We save data as long as it is necessary for the legitimate purpose and longest for 36 months from the time of collection. We can clean out all data before 36 months upon the request of a customer when they asked to be “forgotten”.

Shopping experience:

Purpose

Give our existing and future customers a greater value by integrating with the brand. For existing customers, it means a faster checkout process. For our future customers it means they can get more information about our products.

Processes performed

Give customers who have ordered online the opportunity to share their experience with the brand by leaving product reviews.
Give customers the possibility to mark items as “favourites” in a wish list that can be sent to her/himself or friends for an easier future checkout,
Give customers the possibility to create a personal account which enables full view of order history, current order status and make the checkout process faster.
Make it easier for the customer to pick up the checkout process where they left it, in case they get interrupted during the order process,
Give customers the opportunity to be notified when a sold-out item is back in stock or when an incoming item is in stock.

Categories of personal data

Email
Shopping cart/desired items
Name
Order number
Address

Legal basis:

Based on consent. The process is necessary to be able to give our customers a greater value and extend their relationship with our brand. The processes are completely voluntary and take place when a customer chooses to activate the particular service.

Storage limitation

From where do we collect your personal data?

From you and from our payment gateways in order to know if a payment is correct and we can start fulfilling your order.

Personal shopping experience:

Purpose

Give you a personal shopping experience and a greater value. This gives us the opportunity to customize and create content and services that match your and other users’ interests and desires.

To give you a personal shopping experience, we provide you with personalized recommendations and automation advertising on our site, by e-mail and, through social media channels. The personalized recommendations and ads are resulting from algorithmic analysis and predictions of your preferences, interests, and behavior.

We collaborate with marketing partners to optimize your shopping experience, read more about our partners below.

Processes performed

For showing you product recommendations. Recommendations based on products you have previously viewed and/or similar to ones you have clicked and viewed, and/or products other costumers like you have purchased and viewed.
Onsite content personalization by adapting messaging, visuals, layouts, and more.
Delivering personalized emails with relevant product recommendations based on your abandoned cart or recently purchased product.

Please note: The personalization and analysis are based on the data we and our advertising partners automatically collect from our site, mostly through cookies, see the categories of data below. The intelligent data layer combines behavioral, transactional, and imported data to predict your preferences and interests and then take this into account when choosing the ads and recommendations.

Categories of personal data

Email address (incl. sent emails)
Shopping cart/desired items/disliked products
Name
Order number and order information
Address (incl. zip code and country code)
Purchase history
User-generated data (e.g. clicking and visiting history)
User agent (browser)
IP address
Events
External campaign attributions
Images files
Phone number

Legal ground:

Based on consent. Our legal basis for using personalization cookies is consent. The consent is completely voluntary and is taken place when a customer chooses to activate the service.

Storage limitation:

We save data as long as it is necessary for the legitimate purpose. We can clean out all data before 36 months upon the request of a customer when they asked to be “forgotten” or actively reject further marketing communication from us. Please read our cookie policy for more information.

Who can we share your personal information with?

Personal data will not be shared with third parties, natural persons or legal entities, that are unrelated to, or that do not operate a business, professional or technical function for Newbie. We share your data with the following partners:

Payment gateways
Our distribution partner
Marketing (print and distribution, social media, media agencies or advertising agencies).
IT services (companies that handle necessary operations, technical support and maintenance of our IT solutions)
Our online platform

We share data to be able to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.

We will disclose your personal information to third parties if the following events occur:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If all or substantially all of our 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 service, policies and other agreements; or to protect our rights, property, safety or safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your personal data will not be disclosed to third parties for their own marketing purposes.

If you at any time find that we do not process your personal data as we promise in our policy, you are entitled to complain to the Information Commissioner’s Office (https://ico.org.uk/).

Where do we process your personal information?

Our store is hosted on Shopify Inc (Shopify). Shopify provide us with the online e-commerce platform that allows us to sell our products and services to you. Personal data collected through the Site will be processed and stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall and it is protected by a DPA. Personal data may be transferred from EU/EEA to a third country not being approved by the European Commission as a country with an adequate level of protection. Newbie and its sub-processor will in such cases use Standard Contractual Clauses to ensure an equivalent level of protection as granted in the EU/EEA or other appropriate safeguards.

Shopify host our store on the behalf of Newbie Ltd by KappAhl (registration number is 10811237 and our registered office is at 20 Red Lion St. London. WC1R 4PS. Our registered VAT number is number 275 0511 19).

How long do we save your personal data?

We will never save your personal data longer than is necessary for each purpose. See more about the specific storage periods for each purpose stated above.

Your rights as registered

Right to access: We are always transparent about how we process your data. If you would like a deeper insight into what personal data we may hold about you, you can request access to the information. Please note that if we receive a request for access, we may ask for additional information to ensure the efficient handling of your request and that the information is provided to the right person.

If you have questions about a register extract, please contact our customer service team: [email protected]

Right to erasure and right to rectification: You have the right to demand Newbie to delete your personal data without undue delay. You are entitled to access information regarding the content of the personal data we process, and you are entitled to request a correction if any information is found to be inaccurate. Please note that if you have an account you can change some of your data directly on our website.

If you would like to access your registered data more than once a year, we charge a small administrative fee. Under certain circumstances you may have personal data deleted, for example, if you have not given your consent or you have withdrawn your consent.

Keep in mind that we may have the right to deny your request if there are legal obligations that prevent us from immediately deleting certain personal data. These obligations derive from accounting and tax legislation, banking and money laundering legislation, as well as from consumer law. It may also be necessary for the processing to be established, enforced or defend legal claims.

If you have questions about your right to rectification and deletion of your personal data, please contact our customer service team: [email protected]

Right to restriction: You are entitled to request limited processing of your personal data If you claim that the personal information we process is incorrect, you may request limited processing during the time we need to check whether the personal data are correct or not.

If you have questions about your right of restriction, please contact our customer service team: [email protected]

Right to object to certain types of processing and direct marketing: You are always entitled to avoid direct marketing and to object to all processing of personal data based on a balance of interest. For example you always have the right to end your newsletter subscription whenever you wish.

Just contact us or click on the unsubscribe link at the end of the newsletter.

Our emails may, from time to time, contain links to websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Should you subscribe to a third party website or newsletter, you will have given your consent independently. We will not share your personal details with any third party company.

If you have questions about your right to object, please contact our customer service team: [email protected]

Legitimate interest: In cases where we use legitimate interest as a legal basis for a process, you have the right to object to the processing of personal data. In order to continue processing your personal data after such an objection, we need to show a compelling legitimate reason for the current processing, which outweighs your interests, rights or freedoms. Otherwise, we may only process the data to determine, exercise or defend legal claims.

If you have questions about your legitimate interest, please contact our customer service team: [email protected]

Right to data portability: Whether our right to process your personal data is based on your consent or performance of an agreement, you are entitled to request that information related to you is transferred to another party responsible for data (also called as data portability).

If you have questions about data portability, please contact our customer service team: [email protected]

Contact

We take data protection very seriously and if you have any questions in these matters you can always contact our customer service team at [email protected]

Newbie by Kappahl Limited registered office is at 20 Red Lion St. London. WC1R 4PS.

Changes to the policy

We reserve the right to amend these policies at any time. All amendments to these policies will be posted online. However, continued use of the site will be deemed to constitute acceptance of the new policies.