Represent GROUP PRIVACY POLICY (“Privacy Policy”)
LAST UPDATED: December 2022
ABOUT THE REPRESENT GROUP AND THIS PRIVACY POLICY
We are Represent UK Limited (“we”, “us”, “our”), and are committed to protecting your privacy. Represent UK Limited is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) and the UK GDPR, a company registered in England and Wales (Company No. 06400760), with its registered office located at The Bower, 4th Floor, 211 Old Street, London EC1V 9NR, United Kingdom. This Privacy Policy provides information on how we collect and use personal data. Represent UK Limited operates Represent, various international websites (including Represent..uk, Represent.fr, and Represent), and the Represent iOS and Android mobile applications (collectively, the “website”). This Privacy Policy sets out the information that we collect, the reasons for which we collect the information, and how we can use and share the information.
The Website and services provided by Represent are not intended to be used by children. If you have any questions about this Privacy Policy, you can contact the Represent Data Protection Officer at privacy.
If you have any requests to exercise your legal rights, please check section 10 (“What are my privacy rights?”) below.
THIRD PARTY WEBSITES
Our website can contain links to and from the websites of our partner boutiques, retailers, and brands (collectively our “Partners”), advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.
WHAT INFORMATION DO WE COLLECT, AND HOW?
When you interact with us, whether by using our website or communicating with us, we may collect the following information about you:
• Information you give us: you may give us information about yourself if you sign up for an account on our website, place an order for products, complete any online forms (such as registration forms, competitions, surveys or by reviewing the products you’ve ordered), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions or our Beauty Community on our website, or correspond with us (by email, telephone, instant messaging apps, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number, email address, date of birth, gender, purchase information, shopping preferences, reviews, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).
If you register an account on the website or on the Represent Beauty Community, then you may choose to give us your photograph and nickname. From your Represent account, you can also invite your friends to shop at our website (including by email, Facebook, or Twitter). Even though we let them know that we’ve received their details from you, please ensure that you have your friend’s permission before sharing their contact details with us and only forward emails to people you know would be happy to receive them.
• Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts (like when you use your Apple ID or Google Sign In to sign in on our website) or other websites, including data brokers, our Partners, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.
By logging into our mobile applications via Apple, Google, Facebook, or Twitter, or linking your Represent account on our website to your Apple, Google, Facebook, or Twitter accounts, you are giving us permission to obtain certain information and content from these accounts. The specific types of information that we may obtain depend on your settings for that account or website, and will be subject to their privacy policies. We supplement the data you provide us with data from data appending services such as public or social graph data in order to better serve you with content or promotions. We will append this data to our existing customer account information to better understand customers’ interests and to provide more relevant product recommendations and advertising, to increase our customer’s security when using our website and to comply with our legal obligations, such as sanctions laws. This information may include household size, household income, or profession. This information can be associated with your personal information such as name, email, address, physical address or phone number.
You can see more details about the third parties we use in section 5.
• Information our IT systems collect about you: each time you visit the website, certain information will be created and automatically recorded by our IT systems. That information includes:
Cookies: you can see more details about cookies in section 7, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on our website. We also use cookies to provide you with tailored advertising.
Device information: the information provided by your device will differ depending on your operating system and device settings (eg. PC, Mac, iPhone, Android, or otherwise), but includes the type of device you have (eg. iPhone 6S or Samsung Galaxy S7), the device’s IP address and location, the browser you’re using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
• Information we collect in store: the Represent Group is always looking for new opportunities to improve your shopping experience and this extends to your experiences in-store. When you visit the Browns Stores, you may have the opportunity to use pioneering technology to enhance your in-store experience. You may also give us information about yourself in-store if you make a purchase using a credit or debit card, complete a survey or questionnaire, enter a competition or promotion, provide us with feedback or otherwise interact or correspond with us in-store or after your visit. Where you use a WiFi-enabled device in-store, certain information may be provided by your device, which will differ depending on your device and settings. The information that may be provided is the type of device you have, the device identifier/media access control (MAC) address, the proximity of the device from the access point, location of the device, and where relevant, when and for how long the device is connected to the Wi-Fi network. You can prevent information being provided by turning off the Wi-Fi feature on your device. We might also register your interactions with the products, in order to enhance your in-store experience by providing you a more personalised service during your visit and after.
WHAT DO YOU USE MY INFORMATION FOR?
To provide you with our services, including to allow you to order and receive products using our website, administer your Represent account and to optimise your experience, we need to use your information in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we and our partners will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt-out instructions in the promotional emails that are sent to you.
You may unsubscribe from our email marketing communications by modifying your preferences in your Represent account’s profile management section, by following the opt-out instructions in the promotional emails that are sent to you or, by completing this Unsubscribe Form Should your country be covered by such services, we may use your information to provide you with shopping recommendations and personal styling-related services, therefore, you’ll have access to an improved and more interactive shopping experience. Such services will be provided along with third-party providers, which will be acting as processors.
To register and manage your Represent account on our Website, we collect your name, email, password, and other additional details you may wish to add to your account, like phone number, addresses, and gender. The legal basis is the performance of a Contract with you.
To fulfill the orders you make through our website, we collect your Name, addresses, phone number, Order details, like the products you are buying, the size, and price. The legal basis is the performance of a Contract with you.
To collect payment from you, we collect your payment information, which comprises the credit/debit card’s number, holder’s name, and CVV. We don’t store them and only transfer them to our authorized payment providers. The legal basis is the performance of a Contract with you.
To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us): we collect your name, email, password, phone number, and addresses and your contact history with us. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
To handle possible health and safety queries related to Beauty products: along with the data collected to provide you our customer services, we will also collect the kind and severity of an adverse reaction, the affected area, and if any medical treatment was used or needed. The legal basis is the performance of a Contract with you and compliance with a legal obligation.
To monitor the quality of our customer services, we collect your name, email, password, phone number, and addresses, your response to our SMS inquiries about the quality of the service and your contact history with us (including phone records of our conversations and conversations through email or other instant messaging apps). The legal basis is the legitimate interests in running our business.
To review and post your reviews on your orders: we collect your name, age range, skin characteristics (such as type, tone, and concerns) and your written review. The legal basis is your consent.
To administer, maintain and optimize our Website and our services, we collect your device information (such as your device IP address and device type), cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
To perform fraud and credit checks and if we can do business with you, we collect your name, email, addresses, credit/debit card details, browsing history, purchase history, date of birth, gender, specific behavioral cookies, device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect Represent and its customers from fraudulent activities and compliance with a legal obligation.
To send you marketing communications and personalized offers, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behavior, device information, shopping preferences, cookie identifiers, internal identifiers, and country. The legal basis is the legitimate interests in electronic direct marketing of similar products and services which you have acquired using our website. When such is not applicable, your consent to send you special offers and campaigns powered by Represent in cooperation with exclusive partners.
To manage our loyalty programs, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behavior, device information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.
To provide you with personalized recommendations and enhance your experience, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behavior, in-stores interactions with products, device Information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.
To provide you information, through your Represent App, about Represent’ partner boutiques and products closer to your location, we collect your name, location and device information. The legal basis is your consent to allow the Represent app to access your location.
To carry on research, analysis, inquiries, and surveys on your use of our website, we collect your Name; Addresses; Email; Device information, legal basis is our legitimate interests in running our business and improve our Website and your experience.
To advertise and retarget advertising of our and our Partners’ products and services, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
To produce aggregated statistical reports, we use your order history, provided that the result of such reports does not identify you. The legal basis is our legitimate interests in running our business and improving our website.
WHO DO YOU SHARE MY INFORMATION WITH?
To provide our services and the website, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
• Group companies for business purposes: Represent UK Limited is part of a larger family of companies in different parts of the world (the “Represent Group”). The Represent Group comprises Represent Limited and all its subsidiaries, including, but not limited to, Browns (South Molton Street) Limited, Stadium Goods, and New Guards Group. You can find information about the Represent Group here. We may share your personal information to operate our business and provide the Website and services. Rest assured, their use of information is consistent with this Privacy Policy;
• Our partner boutiques and brands from whom you purchase products: we rely on carefully selected partners that supply the products that you see on our website. For selected Partner and whenever you purchase from them, we will automatically share – unless you tell us otherwise – your name, contact information, and purchase details about the products you have acquired from them for their marketing purposes. The usage of your personal information for the mentioned purposes will be done in accordance with the Partner’s privacy policy.
• Third-party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
Courier companies that we use to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address.
Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States, and China and are engaged depending on your location.
Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders to check for any fraudulent behavior. Our current providers are based in the United States, Europe, and Israel.
Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimization of the website. These providers are based in the United States and Europe.
Customer Service management providers that allow us to provide our customer services and improve and manage your customer experience. Our current provider is based in the United States.
Marketing Tools providers that help us enable our marketing. These providers are based in the United States.
Performance Marketing and Recommendations Providers that help us deliver advertising and recommendations of Represent products tailored to your interests and needs. These providers are based in Europe (mostly in the UK) and in the United States.
Research companies that we can engage to help us carry out surveys regarding your use of our Website and Services. These providers are mostly based in Europe (mostly in the UK) or in the United States.
Third parties that administer the platforms integrated with the Website, such as the selected partners that manage your product reviews and our Beauty Community.
IT/technology providers that we use to support, maintain and provide our technology and IT infrastructure that supports our website and the storage of your information. This includes Microsoft Azure that we use to host your information. These providers are based in the Netherlands and Ireland.
• Advertisers for marketing purposes: we can provide your information to our advertising and social media partners that you select (including Facebook and Twitter), where they require the data to select and serve relevant adverts about ours and our partners’ products and services to you and others.
• Third-party service providers to enrich data: we may also enrich, match or combine information we hold about you with data from other sources, for instance by sharing some of your personal data with selected business partners. These partners are based in the United States. We do this to better understand your customer profile and interests so that we can deliver customized offers and other personalized services.
• Third parties where we are considering a corporate transaction: the Represent Group is always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as mergers, acquisitions, reorganizations, asset sales, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred.
• Third parties which help us provide you with a styling service: we’re always trying to find new and interactive ways to improve your shopping experience and provide a unique personal styling journey. To do so, we may rely on third-party service providers, such as Wishi Fashion Ltd., 379 West Broadway, 5th Floor, New York, NY 10012, United States, if this service is available in your country.
• To comply with legal requests: on occasion, we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases, we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.
• Aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our website, purchase of products, and other general, grouped information about our customers. The legal basis is our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymized, meaning it cannot identify you as an individual, it provides valuable insight into the use of our website, and we may, therefore, share it with select third parties. These parties may include providers of plugins or similar technologies (to help measure traffic), our partners and other providers (to allow them to better stock products), and our investors.
TRANSFERS OF YOUR PERSONAL DATA
By using our website and our services, you acknowledge and accept that your personal information will be processed in the United Kingdom. To provide our website and our services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination outside of the United Kingdom or the European Economic Area (“EEA”), mostly to the United States, either to one of our Group Companies, to one of our Partners or to one of the third parties with which we work, as stated below:
o When transferring personal information to one of our Group Companies outside the EEA, which may include the USA, Brazil, Russia, Japan, or China, we rely on the Commission’s model contracts for the transfer of personal data to third countries.
o We transfer the personal information to one of our Partners outside the EEA, to the extent such transfer is needed to fulfill the contract between you and the Partner which you are ordering the products from.
o When transferring personal information to one of our third party services’ providers set out above, we rely on different adequacy measures, as set out below:
Adequacy Decision: we transfer the personal data that we collect from you to conduct fraud checks to Israel, which was found to have an adequate level of protection for personal data under Commission Decision 2011/61/EU of 31 January 2011.
Model Clauses: we rely on the EU Commission Standard Contractual Clauses and the (UK) International Data Transfer Addendum to the EU Commission Standard Contractual Clauses for the transfer of personal data to third countries.