This Privacy Policy (the “Policy”) outlines how your personal information is treated and forms part of our terms and conditions. This policy explains:

• what information we collect when you use the Whistles website (the “Site”), when you communicate with us, or when you visit one of our stores
• how we use your information
• how we share your information
• how long we keep your information and how it is stored
• ur approach to sensitive personal information
• what options you have to control your information
• the rights you may have in relation to your personal information
• how we communicate changes to this Policy

Please contact our Customer Services team if you would like to discuss this with us or have any questions, comments or suggestions relating to this Policy.

This Site is run by Whistles Ltd (“Whistles”). For the purposes of applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) (as amended or superseded) Whistles is the “controller” of the personal information collected through the Site, by phone or in any Whistles store.

1. Information we collect when you visit our Site

We will collect personal information that you provide to us when you:

• create an account on our Site;
• place an order through our Site;
• fill in forms on our Site, for example to leave feedback, enter a competition or respond to a survey;
• subscribe to our mailing list.

We will also collect certain information automatically when you visit our Site, in particular:

• when you access our site, we use “cookies” to make it easier for you to use our Site. These cookies record data about the pages you browse and the activities you carried out during your visit. Further details about our use of cookies is set out in our Cookie Policy;
• we record details of the resources that you access to visit our site (for example, URL addresses, traffic data etc.);
• we record information about the type of device you have used to visit our Site, your device settings, and the cause of any system errors. Your device manufacturer or operating system provider will have further details on what information your device makes available.

2. Information we collect in our stores
We will collect personal information that you provide to us in our stores when you:

• ask us to provide you with an electronic receipt;
• subscribe to our mailing list;
• enter a competition or respond to a survey.

3. Information we collect when you contact us

We will collect personal information about you when you contact us by telephone, email, or via social media.

4. Information we collect if you apply for a job with us

You may be able to apply for a job with us through our Site, in-store or through third party websites such as LinkedIn. The personal information we collect about you may include:

your name,

contact details,

employment history,

and any information set out in your CV.

We will use your information in the following ways:

1. For the performance of a contract between you and us:

to provide you with an account on our Site, if you choose to sign up for one;

to fulfil any order that you place with us;

to collect payment from you;

to provide you with a receipt, if you ask us to send this to you electronically;

to protect and defend our legal rights and interests.

2. Where we have a legitimate interest in using your personal information:

to administer and monitor our Site, including to ensure that content is presented in the most effective manner for you and for your device, and to allow you to participate in interactive features when you choose to;

to analyse any feedback that you provide on our services, and to improve our services;

to administer competitions that you have entered;

to review and assess any job application that you submit to us.

3. Where you have provided your consent to our use of cookies:

to remind you that you have items in your basket or that a transaction is incomplete (this is recorded by use of a cookie file, further details about our use of cookies is set out in our Cookie Policy).

4. If you have consented to receive marketing information from us, we may use your information in the following ways:

we will process details of your previous transactions and contact you by email with information about goods and services similar to merchandise you have purchased (however we never store your payment details);

if you have consented to us doing so, we will share your information internally within the TFG Brands (London) group in order to send you tailored offers or other information we believe will be of interest;

if you provide your mobile telephone number in our preferences centre and if you have consented for us to do so, we may contact you with marketing messages which have been tailored to match your preferences.

You have the option to unsubscribe from our e-mails through a link at the bottom of every email we send to you.

If you want to change the details that you have registered online with us, or would like to amend your subscription preferences or unsubscribe altogether, please contact our Customer Service team

We share your information with our core service providers and third party platforms as required for our business to function; for example, to Clipper Logistics Group Ltd. who pick, package and process orders on our behalf, DHL who assist us with fulfilling deliveries, Cybersource who provide fraud detection services and credit risk reduction checks, and the third parties we engage to provide IT systems support.

If you choose to provide feedback on your transaction, we will share your information with Feefo, a third party feedback site who will capture your feedback on transactions which we use to enhance our customer service.

Your information may be processed by a third party in order to maintain the functionality of our website and database.

In the event that you add items to your basket but do not complete a transaction, our abandon basket partner will automatically send you an e-mail to remind you that there are items in your basket.

Whilst you are a member of our mailing list we may share your information with trusted non-core service providers, such as marketing partners we have carefully selected to deliver incentives to participate in offers, polls, surveys, analysis or research, all of which assist us in enhancing our services. They are not permitted to use your information after you unsubscribe.

We also use services offered by Google, Facebook, Instagram and other similar social media platforms to better tailor our marketing communications and for targeted advertising. As part of this process, some personal information, such as your email address, is provided to the relevant third party, however for security purposes this data is “hashed” prior to being shared. Hashing is a process of identity masking or “pseudonymisation” which means we do not disclose your email but still enables linking between your social media presence and our website. Your personal information may be transmitted to countries outside of the EEA, such as the United States for certain service providers such as Cybersource and Facebook. If you would like more information about how your personal information may be transmitted, please contact accessrequest@whistles.co.uk if you would like to make a request.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and if the changes are significant, we may provide you with additional notice such as adding a statement to the homepage of the website or sending you an email with the update.

Please check this Privacy Policy regularly to stay informed about our information practices and the ways you can help protect your privacy.