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Privacy & Cookies Policy

This webpage sets out when and how we use your personal information that you or others provide to us.

We are Wolf & Badger, a limited company with registration number 06980629. Our registered address is 10 Queen Street Place, London, United Kingdom, EC4R 1AG.

We have appointed a Data Protection Officer Aphaia Ltd who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Protection Officer by email at [email protected] or directly at [email protected]

OVERVIEW:

This Privacy Policy explains how Wolf & Badger uses your personal information that you or others provide to us. We are deeply committed to the relationship and trust we have with you, and we take our data protection responsibilities seriously. As we continue to innovate and develop in how we bring products and services to life, we’ll match progressive technology and practices with your privacy interests.

You must not use our platform if you are not at least 18 years old. We may use age verification tools to prevent underage users from using our platform.

We will process your personal data and information in compliance with the applicable data protection laws in each case, including, but not limited to, the GDPR (General Data Protection Regulation), the UK GDPR (the GDPR as it applies under UK law), the CCPA (California Consumer Privacy Act) and the FADP (Swiss Federal Act on Data Protection) as relevant. This policy applies where we are the data controller alone or, in some cases, jointly with the seller, to the extent we might jointly manage an individual order. In the latter case, you may contact us or the seller in relation to any rights you are entitled to exercise under the relevant data protection laws.

INFORMATION WE COLLECT:

How do we use your data? What is considered personal information? What is considered personal data?

Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

Personal data are any information which are related to an identified or identifiable natural person.

When you purchase products from our website or from in store

We collect:

Your name, address, email address, phone number, payment details, order details

Our lawful basis:

Our legitimate interest to help conclude the contract you have entered into with the seller, providing our online service to you by means of creating and maintaining user accounts.

Who we share it with:

We share your personal information with our subcontractors who are involved in the purchase process, such as payment providers, as well as credit reference agencies who we use to assess fraud, credit and/or security risks. The seller you have purchased from also receives your name, address and contact details so they can deliver your order (if applicable) and help resolve any customer service queries you have. Our sellers are under strict instructions and binding contracts to only use your personal information to deliver your order, if applicable, and help resolve any customer service queries you have.

When you contact us or talk to us via live chat for customer service purposes

We collect:

Your name, contact details and the other details you provide to us.

Our lawful basis:

We provide customer services because we have a legitimate interest in wanting to assist you receive the best service possible.

Who we share it with:

Our live chat provider. But they can only use the personal information they hold in accordance with our instructions.

When you have expressed an interest in our products

We collect:

Your name, email address, postal address, telephone number and sector preferences, browsing history, geolocation, queries, call recordings.

Our lawful basis:

Running the recommendation engine as the core functionality of our online service. Recommending items to you.

When we send you marketing emails because you have opted-in to receive them, we rely on your consent to contact you for marketing purposes.

If you have not opted-in and we send you marketing emails, and when we use Facebook Custom Audiences and Google’s Retargeting lists, we do this because of our legitimate interest to promote the success of our business.

You can tell us that you do not want your personal information to be processed in this way at any time by contacting us at [email protected] or, where relevant, by following the unsubscribe link shown in every marketing communication you receive from us.

If you have opted out of our email marketing, you may still continue to see target ads on social media platforms. Please check the social media platforms for more details on how to opt out of seeing these ads.

Who we share it with:

Facebook and Google for retargeting.

We also share your personal information with our subcontractors who help us electronic marketing platforms

If you are a brand talking to us about, or selling on our website

We collect:

Your name, address, email address, phone number and payment details, as well as information about your products.

Our lawful basis:

If you are not yet selling on our site, our lawful basis is our legitimate interest to encourage sellers to use our site. If you are an active seller with us, then our lawful basis is to enter into a perform the contract between us.

Who we share it with:

Our professional advisors when required for tax, regulatory, legal and accounting purposes.

To improve and secure our website

We collect:

IP address, browser type, device type, referring website, cookies, perceived geolocation based on IP.

Our lawful basis:

Our legitimate interest to provide you with the best experience we can, and to ensure that our site is kept secure. Consent for non-essential cookies.

Who we share it with:

The service providers identified in the cookies table below.

If our business is sold

What details we may transfer

If Wolf & Badger or the majority of its assets are acquired by somebody else, your personal information held by may be transferred to the buyer.

Our lawful basis:

We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.

In some circumstances we may also need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation.

Who we share it with:

The purchaser of our business and our professional advisors (such as lawyers and accountants).

Where you tag us in social posts, the information on that is added to our tool Olapic, which enables our “shop the look” feature. We do not approve such posts until you have given us the permission. For this purpose, Olapic has a built-in rights approval tool which leaves a comment on your post, whereby you can reply with permission #yeswolfandbadger .

Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We use the following cookies:

Cookie

Purpose

Google Analytics

This is a web analytics service, which allows us to track the use of the Website, prepare reports on user activity and share them with other Google services (privacy policy; opt-out).

Ometria

This is a web analytics service, which allows us to track the use of the Website (privacy policy)

Qubit

This is a personalisation service (privacy policy).

Criteo

This is an online advertising and remarketing service (privacy policy; opt-out).

Sift

This is a fraud and malicious behaviour detection service (privacy policy).

PayPal

This service processes payments for us (privacy policy).

Hotjar

This is a screen recording service (privacy policy)

Olark

This is a live chat customer support service (privacy policy).

Olapic

This service collects user generated content for us (privacy policy).

Facebook

This provides an online advertising and remarketing service for us (privacy policy).

SkimLinks

This is an affiliate service (privacy policy).

Pinterest

This is a conversion tracking service for us (privacy policy).

Except for essential cookies, all cookies will expire after 2 years.

NOTICE REGARDING MINORS:

Wolf & Badger strongly believes in protecting and maintaining the privacy rights of children. Our services are not intended to be used by or targeted to children under age 13. If we receive actual knowledge that we have collected any individually identifiable information about a child under the age of 13, we will delete that information and not use or disclose that child’s information except as may be required by law. If you are a parent or legal guardian and believe your child under age 13 has provided us with personally identifiable information, you can write us at the address provided at the end of this Privacy Policy.

Wolf & Badger strongly encourages all parents to supervise their children's on-line activities and regularly monitor their children's use of the Internet. Parents should consider using parental control tools and other services to assist them in supervising their children's on-line use or on-line disclosure of their name, address, or other personal information without parental consent.

SOURCE OF INFORMATION COLLECTED BY WOLF & BADGER:

Wolf & Badger may collect personal information through these sources:

  • Customers providing information directly to Wolf & Badger, such as through Wolf & Badger ‘s “Contact Us” page or e-mails made to our Customer Service department

  • Customers using Wolf & Badger

  • Employment applications

  • Information collected in the course of employment

  • Points of purchase for Wolf & Badger’s products and services

  • Social media sites maintained by Wolf & Badger

  • Vendor data used to provide services to Wolf & Badger

  • Information provided at Wolf & Badger events or locations

  • Geographic data and preferences from the use of the Wolf & Badger’s website

RECIPIENTS OF YOUR DATA

Subject to the need to perform the contract with you based on the contract you enter with us and our legitimate interests, we may share your personal data and information in the ways described below:

-Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers, including cloud storage, analytics and communications providers, and system administrators or third parties who host and manage data;

-Analytics, CRM and other software that assist us in the communication with you and the improvement and optimisation of our website;

-Any other third parties for the purpose of enabling the services to be provided:

-Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers;

-Other reasons – We may also share your personal information with a purchaser or potential purchaser of our business.

-Any other third parties with your express consent.

Where is my data stored and transferred?

We may need to transfer your personal data in connection with the conclusion or performance of a contract with you or with our partners in your interest. Some of our external third parties are based outside the European Economic Area (EEA), the UK or Switzerland so their processing of your personal information will involve a transfer of data outside of the EEA, the UK or Switzerland.

Whenever we transfer your personal information outside of the EEA, the UK or Switzerland we ensure it is protected by making sure at least one of the following safeguards is in place:

  • by transferring your personal information to a country covered by an adequacy decision; or

  • by using specific contracts approved by the European Commission and/or the ICO and/or the FDPIC which give your personal information the same protection it has within the EU/UK/Switzerland i.e. Standard Contractual Clauses (SCC).

To keep this privacy policy as short and easy to understand as possible, we have not set out the specific circumstances when each of these protection measures are used. You can contact us at [email protected] for the details as to how we protect specific transfer of your data.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

What are my rights as a California resident?

If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (CCPA), including the rights under California Privacy Rights Act (CPRA).

These include:

  • The right to know – you have a right to request:

  • The categories of personal information it has collected about that consumer

  • The categories of sources from which the personal information is collected

  • The business or commercial purpose for collecting or selling personal information

  • The categories of third parties with whom the business shares personal information

  • The specific pieces of personal information it has collected about that consumer.

  • The right to opt-out of sale or sharing

    – you may request that we stop selling or sharing your personal information, including via opt-out preference signals where such solution has been implemented. After we receive your opt-out request we cannot sell or share your information unless you authorize us to do so.

  • The right to non-discrimination

    - under the CCPA we cannot deny you goods or services, charge a different price, or provide a different level or quality of goods or services, if you decide to exercise your rights.

  • The right to delete

    – you can request that we delete your personal information that we have collected from you, and we would direct our service providers to do the same. However, this request is subject to certain exceptions (for instance if we are legally required to keep the information)

  • The right to correct

    – you may ask us to correct inaccurate information that we hold about you

  • The right to limit use and disclosure of sensitive personal information

    – please note that Wolf & Badger does not does not use or disclose personal information outside the scope of section 7027, subsection (m)

To exercise the above rights, you can email us at [email protected]. Alternatively, you can opt-out of our sharing/selling your personal information by means of following the link at the bottom of our US webpage titled “Privacy Choices”. If you maintain an account with us, we may ask you to submit the request through that account. Where required, we may also provide a California toll-free number.

Wolf & Badger will respond to your request within 45 days of receiving your request.

In some circumstances we may need to verify your request before we can fulfill your requests. Whenever feasible, we will match the identifying information provided by you to your personal information that we already have, normally by means of your email address.

Please note a California toll-free number is not required for businesses operating “exclusively online”. We are aware of your shop in London, but do you have any shops in the US/California?

How long do we retain your data for?

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

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

In some circumstances (to understand purchasing trends and how people interact with our website) we may anonymise your personal data so that it can no longer be associated with you, and use it for research or statistical purposes.

Call recordings are kept for 18 months.

What are my rights under data protection laws?

If you are an EU, an UK or a Swiss citizen, the GDPR, the UK GDPR and the FADP outline some fundamental rights, plus the right to withdraw consent which guarantees you an autonomy over both, your personal data, and its processing.

Request access to your data (commonly known as a "subject access request"). This enables you to receive a copy of the data we hold about you and to check that we are lawfully processing it.

Request correction of the data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your data. This enables you to ask us to delete or remove 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 data where you have exercised your right to object to processing (see below).

Object to processing of your data 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. You also have the right to object where we are processing your data for direct marketing purposes, research, or statistical purposes.

Request the restriction of processing of your data. This enables you to ask us to suspend the processing of data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your data to another party.

Privacy law is often complicated, and whether these rights are available to you sometimes depends on the types of data we are handling, as well as why we are handling it. If you would like to exercise any of these rights, please contact us using the details at the bottom of this notice. You always have the right to lodge a complaint with us or the Information Commissioner's Office at ico.org.uk, or another competent data protection authority outside the UK.

What about websites we link to?

Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates.

Our site connects you to different websites. If you follow a link to any of these websites or use our services, please note that you have left our site and these websites have their own privacy policies.

We do not accept any responsibility or liability for these policies or websites. Please check their policies before you submit any personal information to these websites.

When will you change your privacy policy?

Any changes we make to our privacy policy in the future will be posted on this page and may be notified to you by email.

Please check back frequently to see any updates or changes to our privacy policy.

How do I contact you with feedback?

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Officer Aphaia Ltd at [email protected] or directly at [email protected].

You also have the right to lodge a complaint with the relevant supervisory authority. For example, you can contact the ICO at Contact us | ICO and the FDPIC at Contact (admin.ch).

This privacy policy was last updated on 19 September 2023.