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Privacy Policy: FRESH BLANKS LIMITED
Date: 30th January 2024

This website is owned and run by THE FRESH BLANKS LIMITED ("we", "our", "us"),. If we use the term "our Group", this means us and our subsidiaries, our ultimate holding company and its subsidiaries (or any of them). The term "our online services" refers to FRESH BLANKS, FRESH BLANKS LIMITED, THE OUTNET, our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term "our services" refers to our online services and any of our other products and services, such as freshblanks magazine, offered from time to time. If you use any of our services, we will refer to you using the terms "user", "visitor", "you", "your", "yours" in this policy.

We respect the privacy rights of our visitors and recognise the importance of protecting the information collected about them. This privacy policy is about how we collect, store, and use the personal information that you provide to us. As part of our commitment to your privacy rights and security, our websites have been certified by Cybertrust.

If you are under 18, you must inform a parent or guardian about our privacy policy to obtain their agreement to the privacy policy before registering, subscribing or placing an order with us.
1. What personal data do we collect from you and how?

We collect and process only the data that is required to allow us to provide our services to you. We collect the following data when you browse or shop at www.freshblanks.com:

    We process the personal data required to complete and dispatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.
    We collect your email address when you sign up to receive FRESH BLANKS LIMITED News.
    If you register for a FRESH BLANKS LIMITED account, we collect your name, email address, password, country and additional data regarding your favourite designers and your marketing preferences.
    When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries. Calls to our Customer Care team and live chat messages can be recorded to ensure a high level of customer service to our clients, to enable the development of staff training and to manage queries, complaints or disputes.
    We collect and process data about your browsing on www.freshblanks.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.
    If you are a customer of www.freshblanks.com, or if you have given us your consent, we collect and process your personal data for direct marketing activities.
    If you provide us with someone else's data - for example, if you purchase a product to be delivered to a friend or as a gift - we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.
    When you use the App version of our website, we will ask for your consent to collect personal data from you in order to send you brief messages, "push notifications" about products and services that we believe may be of interest to you. With your consent, we will also collect data regarding your use of the App and your IP address, in order to improve our service to you. You can disable push notification at any time by updating the App settings in your mobile device.
    If you subscribe to freshblanks magazine, we will collect and process the personal data required to complete and dispatch your purchase, including your name, billing address, delivery address, payment details, telephone number and email address. We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the subscription. You have the option to provide us with your birth day and month and to subscribe to our marketing communications and those from our partners .

2. What about cookies? What are cookies?

We and our business partners collect information about your use of our online services using cookies. Cookies are very small files that are sent by us to your computer or other device which we can access when you visit our site in future. Cookies help us remember who you are and other information about your visits. They can help display the information on a website in a way that matches your interests. Most major websites use cookies. For more information about how we use cookies, please read our cookie policy.
3. How this information may be used

Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.

When you use our services:

If you use any of our services, register for or attend one of our events, set up, look at or change your account details or contact your personal shopper or a member of our Customer Care Team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for and to provide you with a personalized shopping experience. We keep the information you provide and may use it for several purposes, including: (i) accounting, billing, reporting and audit; (ii) credit checking or screening; (iii) authentication and identity checks; (iv) credit, debit or other payment card verification and screening; (v) debt collection; (vi) safety, security, health, training, administrative and legal purposes; (vii) data matching and dedupe, statistical and market analysis, and marketing information; (viii) advertising and marketing for us, our Group and third parties; (ix) developing, testing and maintaining systems; (x) studies, research and development; (xi) customer surveys; (xii) customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences; (xiii) where required by law or in connection with legal proceeding or disputes; and (iv) any other uses set out in the terms and conditions for use of our services. For these purposes we may disclose your information to one or more of the other organisations listed in the section called "who we will share your personal information with".

Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner's systems.

We may also use your personal information to send you marketing updates, as detailed in the next section.

Tracking how our online services are used:

We collect, and use third parties to collect and share with us, information from lots of visitors to our online services and analyse it to build up a picture of how people use our websites. This helps us improve the services we offer. We may also give anonymous statistics about visitors to other, reputable organisations, but the information we provide will not include details that would allow these organisations to identify you. For more information on our use of cookies, please read our cookie policy.

Customisation of our online services and advert targeting:

We may use the information you give us about yourself and the information we collect via cookies when you use our online services to build up a picture of your interests. We may then use this information to try to make sure that when we send you marketing communications and when you visit our websites or use our online services, you don't miss offers and information that might interest you. This information may also be used by our third party advertising agencies and networks, to advertise our own or third party products and services to you when you visit third party websites and online services. This is called advert targeting or interest-based advertising. For more information on how to reject targeted advertising or interest-based advertising cookies please read our cookie policy.

Testimonials:

If you give us feedback, we may use it to improve our services and we may publish it online or offline to promote our business and our services. We will ask for your permission before we publish it.

Comments and reviews submitted to our online services:

If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and our services. We will collect your name or username which will be displayed next to your comment and e-mail address, which will not be published, but which we may use to contact you in relation to your comment.

Mobile services:

When you request our mobile services, we may keep your mobile phone number, the make and model of your phone, the operating system used by your phone and details of your network operator, and we will link a unique identifier to your mobile phone number. We'll store your device language, app language, country, We need this information in order to provide the features and services enabled through our mobile services and to administer our mobile service. Our Givenchy mobile services use your location to show your closest Givenchy store. We may also use it for SMS or voice marketing and market research.

Social networks:

If you follow us or interact with us on any of our pages on third party social media platforms, such as Instagram, Facebook, Twitter, Pinterest and Google+, information you provide will be subject to the third party's privacy policy, as well as this privacy policy.

Direct marketing:

For information on how we may market to you, please read the section called "marketing opt-in and opt-out provisions".

Customer service: 

To ensure a high level of customer service to our clients, to enable the development of staff training and to manage queries, complaints or disputes we may process recordings of calls to our Customer Care teams, live chat messages, customer name, account ID and order ID, the pages you have viewed and items in your Shopping Bag and any other contact details you might provide to us during the course of the conversation. This information is strictly confidential and is not shared with any third parties. Our Live Chat provider stores all chat conversations for 13 months; to receive a copy of your chat conversation please follow the instructions specified in the section “How you can access your personal information and keep it up to date” below .

Customer surveys:

Every now and again, we may ask you for your opinion on our services and the products you have purchased through our services. When we do research or surveys, we may use cookies and may combine the information collected by those cookies with your answers.
4. Who we will share your personal information with

We will share your information with other companies in our Group, who may use it for their own business purposes, as set out in their privacy policy. These purposes may include financial reporting and analysis, strategic planning, the development of customer segmentation and metrics to provide a consistent view of our customer base, research and analytics, to help us source the right products in future and make better product recommendations, more effective targeting of our marketing campaigns, the creation of inspiring content and editorial features, the development of new products and collaboration opportunities with designer brands. It will also be used to provide more tailored marketing by phone, post, email, SMS or any other means (electronic or otherwise) and you expressly agree to such use.

From time to time, we may engage third party business partners to provide information about you or to collect personal information on our behalf. We may also share or match your data with third party business partners to provide you with the products, services or information you ask for or for interest-based advertising. We may pass your information onto one or more of the following organisations: (i) data processing companies, mailing houses and other third party suppliers working on our Group's behalf; (ii) ad-serving agencies and other advertising intermediaries; (iii) credit reference or fraud prevention agencies, which may keep a record of that information; (iv) research students, universities and other research and development organisations; (v) regulatory bodies, government and enforcement agencies, such as the police.

Every now and again, we receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the organisation asking for it.

We collate information about site traffic, sales, wish lists, and other commercial information which we may pass onto third parties, but this information does not include any details which can identify you personally.
5. Where we process your personal information

When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA). When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
6. Marketing opt-in and opt-out provision

We offer you the chance to receive news and fashion updates which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. You can opt-out of receiving these updates, if you wish.

We, or our third party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us. Other companies in our Group may also pass your personal information to us for marketing use.

Marketing communications you subscribe to will only be sent by our Group.

You have the right to ask us not to use your personal information for marketing. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed, if you change your mind. Whenever you receive direct marketing from us, we will tell you how to unsubscribe. Alternatively you can change your marketing preferences by logging into My Account. To opt out of direct mail, please contact our Customer Care Team:

For FRESH BLANKS LIMITED, on +44 330 022 5705 or by email at contact@freshblanks.com.

If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with products and services you request and for administration purposes
7. How you can access your personal information and keep it up to date

You have the right to see information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your personal information, please contact us at contact@freshblanks.com.

You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online services and, after logging into the site using the "Sign In" menu on the home page, your personal information will be made available for review and change in the "My Account" section. Only you or, upon your request, our Customer Care team, may access your personal data from our online services using your user ID and password. Information may be changed online within "My Details", "Shipping Details" and "My Email Preferences". You can change or delete saved credit/debit card details each time you make a purchase. You will also be able to delete saved credit/debit card details by adding or editing a shipping/billing address. If you change your billing or shipping address while your order is still being processed, the order will be re-processed through security validation checks. If you prefer, you may contact us by email at contact@freshblanks.com and we will amend your personal details.

Our Live Chat provider stores all chat conversations for 13 months. To receive a copy of your chat conversation simply request this when exiting Live Chat or contact our Customer Care team by emailing contact@freshblanks.com
8. California Privacy Rights

This section applies solely to the personal information collected online of California consumers. This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and uses certain terms that have the meaning given to them in the CCPA.

    Your information, sources and purposes: Please refer to the sections headed “What personal data do we collect from you and how?, “How this information may be used” and “What about Cookies?” for a description of the personal information we may collect about you (or have collected in the preceding 12 months) and the sources of such information (we collect data directly from you or your device). These sections also describe the purposes for which we may use or have used such information. We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
    Retaining your information: We will retain your personal information for the time period reasonably necessary to achieve the purposes described this Privacy Policy, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.
    Disclosing your information: We may have disclosed your personal information to certain categories of third party that we use to provide our services, as described in the section headed “Who will share your personal information with?” above.
    Selling your information/sharing your information for cross-context behavioral advertising: We do not sell or share your personal information in exchange for monetary compensation. As described in the section headed “What about Cookies?”, we may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our platforms in an effort to serve you content and advertisements that may be of interest to you. We also may share your personal information, such as your email address, with third parties to help support our marketing activities. This kind of sharing may be considered a sale or sharing for cross-context behavioral advertising under the CCPA. You have the right to opt out of this disclosure of your information, as described below.

Your rights: Subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:

    Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
    Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate. 
    Deletion: You have the right to request that we delete certain personal information we have collected from you.
    Opt-Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising. You can opt-out of cookie-based selling/sharing by clicking here or broadcasting the Global Privacy Control signal. For more information about how to use the Global Privacy Control signal, please see https://globalprivacycontrol.org/. In addition, you can opt out of other types of selling/sharing as further described in the CCPA Opt-out Page. Your opt-out will be specific to the browser and device you are using and will apply to the website domain on which you submit the request.  If you clear your cookies or use a new browser or device to access the site, please submit a new request to re-apply your opt-out choice. Note that even if you opt out of sale or sharing, you may still be served advertisements and receive marketing emails from us and our service providers.

No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. This section is available in alternative formats upon request by contacting us at the e-mail address contact@freshblanks.com.

Personal, family and household clients: In addition, under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to our e-mail address below with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.

To exercise your rights on behalf of yourself or another individual, you can:

    contact us directly at the e-mail address contact@freshblanks.com ;
    call the toll-free number +1 877 535 3677 excluding public holidays.

If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address) or the authority of any third person acting on your behalf.
9. Safeguarding your personal information

We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These cover storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorised access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorised use.
10. Why we link to other websites

Our online services contain hyperlinks to websites that are owned and operated by other organisations. These websites have their own privacy and cookie policies, and we urge you to read them. They control how your personal information is used when you give it to these other organisations or they collect it with cookies. We do not approve any other websites and we are not responsible for any information, material, products or services that are on or accessible through those websites or for the privacy practices of websites run by other organisations. If you use these other websites you do so at your own risk.
11. How we can make changes to this policy

We may update this privacy policy from time to time so you may want to check it each time you give us personal information or use our websites.
12. Where and how to ask questions or contact us about this policy

If you require further information about our privacy policy, please go to the help section of our websites where frequently asked questions (FAQs) are answered. We welcome your questions, comments and requests about this privacy policy. If you require more information, please contact us at contact@freshblanks.com

If you wish to talk to a Customer Care representative, please call us on +1 877 535 3677 or by email at contact@freshblanks.com.