LAST UPDATED: 28TH NOVEMBER 2019
2. THIRD-PARTY WEBSITES
3. 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, and surveys), opt-in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number, and email address, date of birth, gender, purchase information, shopping preferences, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).
• information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts 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.
We supplement the data you provide to us with data from data append 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.
• the 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:
device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone 6S or Samsung Galaxy S7), the device’s IP address, the browser you are 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.
4. WHAT DO YOU USE MY INFORMATION FOR?
To provide you services and the Website, including to allow you to order and receive products using our Website, administer your account and to optimize your experience we need to use the information that we collect 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.
We also carry out research, analysis, and surveys on your use of our Website, and views. Finally, we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.
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 do not 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 and addresses and your contact history with us (including phone records of our conversations. The legal basis is the performance of a contract with you and our legitimate interests in retaining you as a customer.
To monitor the quality of our customer services, we collect your name, email, password and addresses and your contact history with us. The legal basis is the legitimate interest in running our business.
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 interest 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; 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 our 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; Country. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.
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 interest in running our business and improves the 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; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interest in running our business and improves our Website and your experience.
Carry on research, analysis, inquiries, and surveys on your use of our website, we collect your Name; Addresses; Email; Device information, the legal basis is our legitimate interest in running our business and improve our Website and your experience.
Advertising 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 interest in running our business.
To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interest in running our business and improves our Website.
5. WHO DO YOU SHARE MY INFORMATION WITH?
To provide the Website and our services, 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:
• 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:
o Courier companies, such as DHL and UPS, that we use in order 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;
o 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, the United States, and China and are engaged depending on your location;
o Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders in order to check for any fraudulent behavior. Our current provider is based in Israel.
o Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimisation of the website. These providers are based in the United States and in Europe.
o Marketing Tools providers that help us to enable our marketing, such as Oracle Responsys and Mention Me. These providers are based in the United States.
o Performance Marketing and Recommendations Providers that help us deliver advertising and recommendations of Golub.udp products tailored to your interests and needs. These providers are based in Europe and in the United States.
o 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.
• advertisers for marketing purposes: we can provide your information to our advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about our 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. We do this to better understand your customer profile and interests so that we can deliver customized offers and other personalized services;
• 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 the 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; and
• 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 on the basis of 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 a 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.
6. TRANSFERS OF YOUR PERSONAL DATA
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 European Economic Area (“EEA”), mostly to the United States to one of our Partners or to one of the third parties with which we work with, as stated below:
o 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.
We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our Website:
CATEGORY 1: STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
CATEGORY 2: PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience, and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt-in to these cookies using your browser settings.
CATEGORY 3: FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, color or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings.
CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third-party companies to provide you with more personalized adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
CATEGORY 5: SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at . Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.
You can withdraw your consent to these cookies at any time through the following options:
• Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
• any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:
• using an SSL (Secure Socket Layer) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details);
• not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number), and
• regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our Website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the Website in a non-protected environment (such as through email, SMS, online messages) then that information can be collected and used by others outside of our or your control.
9. HOW LONG WILL YOU USE MY INFORMATION FOR?
We retain the data you provide to us for as long as you have your account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.
In some circumstances, you can ask us to delete your data as set out below.
After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.
• by emailing us at ;
11. UPDATES TO THIS POLICY