Privacy Policy

Introduction
EU WE GOT U (we or us) is committed to protecting and respecting your privacy. It’s your information, and we respect that. 

This policy, along with our website terms of use, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully, alongside our Terms & Conditions, to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.eu.bodaskins.com (our site), you are accepting and consenting to the practices described in this policy. Please also note that this Privacy Policy only applies to personal information obtained by us in accordance with applicable laws – not information collected from your interactions with third parties.

Who we are and how to contact us
The website is operated by or on behalf of EU WE GOT U.
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please email us at hello@bodaskins.com

How we collect your personal information
Generally, we collect your information when you decide to interact with us. This could include purchasing online or when you sign up to receive emails from us. We also look at how customers use our website, so that we can offer the best possible experience. 

We collect information in a number of ways, examples of which are listed below:

- When you register or use bodaskins.com
- When you contact BODA SKINS by telephone or email or through electronic channels (e.g. the website)
- When you register or use BODA SKINS pop up or virtual shopping services (e.g. personal shopping)
- When you sign up to receive marketing newsletters
- When you attend an event, or enter prize draws or competitions run by BODA SKINS
- When completing any surveys that we send to you for research purposes (although you are under no obligation to complete these)
- When completing any forms for transactional, employment or other purposes
- When you buy products, services and gift certificates from BODA SKINS (ie: details of transactions you make from BODA SKINS)
- When you use or are a customer of any of our other Services or pop-up or virtual offerings
- When you visit our website: we use cookies to help make the experience of using our website better and to personalise the service you receive from us – this means we will remember your previous visits and track the pages on our website that you visit. For more information please see our Cookie Policy.
- When you visit www.bodaskins.com the BODA SKINS web server automatically records your public internet protocol ('IP') address.

From time to time, we may also get data about you from third parties. This could include other partners that we have run partnerships, competitions and events with or that provide some of our Services.

The types of information we collect
We only collect the information that’s necessary to carry out our business, provide the particular service you’ve requested and to keep you up to date about all things new. These are through;

Information you give us: You may give us information about you by filling in forms on our site, or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, chat on a live system, sign up for our newsletter, leave reviews, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, email address and phone number, date of birth, gender, measurements, and financial and credit card information.

Information we collect: With regard to each of your visits to our site, we may automatically collect the following information:

Technical information: When visiting our website we may collect an automatically populated IP address. An IP address is a unique number which allows a computer, group of computers or other internet connected device (such as your mobile or tablet) to browse the internet. We may also record the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version.

Information about your visit: including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, and any phone number used to call our customer service number.

Information we receive from other sources: We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers) and may receive information about you from them. This will only be done when we both have a lawful basis to do so.

KLARNA: In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you. General information on Klarna can be found here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

Epsilon Abacus: We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories. Retailers share information about their customers and what they buy. Epsilon Abacus processes this information as a processor on behalf of the retailers to help them understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending individuals suitable offers that should be of interest to them, based on what they like to buy. You can learn more about how Epsilon Abacus processes your personal information in their Privacy Policy, which is available here:https://abacus.epsilon.com/privacy-policy/

Social Media: Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you may give us permission to access information from those accounts or services.

Information available publicly: We may include information found in places such as Companies House and information that has been published in, for example, articles/ newspapers / online. 

Ensuring your personal information is only used where lawful
In order for our use of your personal information to comply with applicable data protection law, that use by us needs to fall under at least one of the specific lawful reasons that are set out in applicable data protection law. Examples of these lawful reasons include our use of your personal information being necessary for the purchase of goods or services, or for compliance with a legal obligation.    

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, we will have a lawful reason to use your personal information in such a way to ensure that we provide the very best products to you and our other customers.

Why we collect your personal information and how we use it
At BODA SKINS, we like to get to know our customers – after all, this is how we find new ways to provide you with an extraordinary experience. We use information about you in a number of ways, including providing the services that you have requested, offering you a personalised experience and informing you about special events or exciting BODA news. We might also use the information we have to contact you about any information we might need to process your orders, returns or queries.    

Examples of how we use your data are as follows:
- To carry out our business and to provide a service or carry out a contract with you.
- Fulfilment of, and delivery of, products and services you have ordered and our other services that we provide. We may share your personal information with our delivery partners, third party service providers and third party concessions.
- Process payments. BODA SKINS does not store any payment card numbers once the transaction has been completed. We share your personal information with credit card companies and other payment providers and acquirers. These third parties will be responsible for the handling of your personal data for these purposes and their privacy policies will set out how they do this. An example of this is Shopify Pay, who provide payment processing services for BODA SKINS. They are a Data Controller of your transactional data in order to process the payment. Shopify Pay’s privacy statement, which can be found on their corporate website, sets out how they use and handle your personal information.
- Contact you with important information relating to your booking or purchase, or use and administration of any of our Services, such as confirming your order, letting you know about returns and refunds and any information in relation to that Service. We may share your information with our communication partners for this purpose. 

Where we have your consent:
- Send you marketing updates via email about all the latest news, events and offers at BODA SKINS. You can unsubscribe at any time by clicking the unsubscribe link in any email. We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you. Third Parties include: Klaviyo, Calendly, Shopify Flows.
- Use your details to show you advertising on such Social Media platforms, such as Facebook and Instagram, or via other third party advertising that may appear on other websites you use. Online advertising channels we may use are: digital display, video on demand, search engine marketing, paid social - these are all on third party sites or platforms.
- We tailor emails and online advertising to the things you love, so they’re relevant to your location, what you have shown an interest in and the things you buy from us.

Where we have justifiable reason (legitimate interest):
- Respond to customer service enquiries raised online, on social media or on the phone. 
- Send an abandoned basket email via third party suppliers, e.g. Shopify flow, Klaviyo.
- Invite you to provide feedback about our products and services in the form of online, or email surveys. We use this information to help us improve the quality of service provided; to monitor the quality of our products and services and to assist with the selection of future product and service lines. 
- Conduct postal marketing. We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.
- Analyse aggregated customer information with other interactions customers have with BODA SKINS in order to continually improve the products and services we offer through our website. We do this using third parties such as Google Analytics.
- For classifying our audience into user profiles, groups or segments, using shopping habits information regarding your personal or professional interests, demographics, experiences with our products and contact preferences. These segments help us to understand our audience better. We do this using Customer Relationship Management systems such as Gorgias and digital platforms for online behaviours, such as Google Analytics.
- To keep our database accurate and relevant, we may do this for example, using National Change of Address.
- Detect and reduce fraud and credit risk.  

Business Administration and Legal Compliance
In certain circumstances, we share and/or are obliged to share your personal information for business administration and legal compliance purposes with third parties outside of BODA SKINS. We may use your personal information in connection with a business transition (such as a merger, acquisition by another company, or a sale of all of or portion of our assets), to enforce our legal rights and/or to protect the rights of third parties and it is in our legitimate interest to do so. In such instances it will be necessary to share your personal information with external professional advisors such as lawyers and accountants, or insurers or financial institutions. 
We may use your personal information for legal compliance purposes and to enforce our legal rights. In such instances it will be necessary to share your personal information with external parties such as administrative authorities (HMRC), the Financial Conduct Authority, police and public prosecutors or to comply with a court order or power of attorney. We may also have legal obligations to overseas tax authorities and will be required to share your personal information for these purposes. 
We will also need to use your personal information for legal compliance purposes to undertake customer checks to know our customers and verify their identity. We will use your information to conduct online searches with Thomson Reuters World-Check, to assist us with meeting our legal requirements.  We may also be required to share your information to report any suspicious and/or criminal activity including fraud, sanctions and anti-money laundering. It is our legal obligation to do so.


How can I unsubscribe from marketing communications?  
  
We would hate for you to leave us, but if at any point you do not wish to hear from us there are a number of ways you can unsubscribe:

You can click onto the "unsubscribe" link in any communication that we send to you by email which will automatically unsubscribe you from that type of communication. Each "unsubscribe" link only relates to that specific type of communication (e.g. general marketing communications, or survey communications). This means that unsubscribing from general marketing communications (email) will not automatically unsubscribe you from specific marketing (pop up / events) or our survey communications (or vice versa). Please also note that you may continue to receive communications which are already en route to you for a short period of time while your relevant unsubscribe request is being processed.

Third Party Links and services 
Our website and emails contain links to third party websites, tools and services. Please remember that when you use a link to go from our Sites to another website, use a third party tool or you request a service from a third party, this Privacy Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party tool or service provider, is subject to that website’s or third party tool or service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit, or third party tool or service provider that you deal with, and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Sites or Services (or Third Party providers performing our Services on our behalf) and does not apply to these third party websites, tools and third party service providers.   

Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We do not sell your personal information for any purpose.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.   

Applicable Law
We are committed to protecting your personal information and the rights set out in this Policy reflect your rights under applicable laws. 

Applicable laws for the purpose of this Policy means: (a) the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2013; (b) General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) until such time as it might cease to apply in the UK; and (c) to the extent applicable, any legislation ratifying or otherwise adopting the GDPR in the UK, and any applicable associated or supplementary data protection laws or regulations. 

We recognise that as an international business, some of our customers are resident in jurisdictions other than England and Wales. In certain circumstances, local laws of these jurisdictions, may by way of their application, afford rights to a customer in respect of the personal data that they provide to us. We anticipate that the rights set out in this Policy also provide you with such protection in relation to your personal information. Please do email us directly at hello@bodaskins.com to discuss any additional questions you may have.

Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required, to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

Cookies
Our site uses cookies to distinguish you from other users on our site. This helps us to provide you with a good experience when shopping on our site, and also allows us to improve our website regularly too. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:
- Business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If EU WE GOT U or substantially all of its 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 website terms of use or terms and conditions of sale and other agreements, or to protect the rights, property, or safety of EU WE GOT U, our customers, or others.

Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at hello@bodaskins.com.

Our site may, from time to time, contain links to and from the 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.

Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@bodaskins.com.