Craghoppers Ltd and its Group companies are committed to protecting and respecting your privacy.

This privacy policy provides information to you about the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, whether you are a visitor to our website ("site") or a visitor to one of our retail shops ("store(s)"). This privacy policy shall be read in conjunction with our cookies policy any notices or terms located within the stores and our site terms of use/terms and conditions.

In this privacy policy, the terms "we", "our", and "us" are used to refer to Craghoppers Ltd, Company Number 03057810, Basecamp, Mercury Way, Dumplington, Urmston, Manchester M41 7RR. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

If you are aged 16 or under, please get your parent/guardian's permission beforehand whenever you provide personal information to our site. Users without this consent are not allowed to provide us with personal information.

Where we collect and use your personal data from a corporate perspective (i.e. where we are contracting with you as a sole trader or partnership, or contracting with the business you are employed / contracted by) this will be done in accordance with the relevant parts of this privacy policy. If you have any questions or concerns about this, please contact us using either the details set out below or by speaking with your usual contact at Craghoppers Ltd.

We will collect and process the following data about you either from your use of our site, or when you come into our stores:

• Information you give us. This is information about you that you give us by filling in forms on our site / in person or by corresponding with us by phone, face-to- face, e-mail or otherwise and includes information you provide when you register to use our site or sign up to use our services in-store, subscribe to any of our services, use the services provided by our site or certain third party services, information submitted as part of any promotions, competitions, games or contests in which you participate, subscription to our marketing emails, use of message boards and live chat facilities, reviews you leave, information submitted to register guarantees and information given when you report a problem with our site or submit an in-store complaint. The information you give us may include your name, address, date of birth, gender, email address, username and password, phone number, details of any comments you provide to us and financial and credit card information. Other information you give us may include feedback regarding our services, our stores or our sites and responses to surveys and/or market research (which you can choose not to fill in and is provided by our third parties such as Stellaconnect, Medallia, Bazaarvoice and Trustpilot). We may also collect and process records of any correspondence and communications with us and telephone calls may also be recorded.
• Information we collect about you. With regard to each of your visits to our site or our stores we may automatically collect the following information:
• • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, MAC addresses, traffic data, location data, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and cookies, which will be collected in accordance with our cookies policy
  • details of your visits to our sites and/or stores and your preferences and habits when using our services; we will use this information to create a profile of you for the purpose of personalising and enhancing your customer experience with us;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), services you viewed or searched for your conduct via the site and (where relevant) details of the fulfilment of any of your orders, and any other site activity, 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 us;
  • information about your visit, including the time and date you came into our store, CCTV images, goods and/or services you requested or purchased; and
  • transaction history and details of transactions you conduct in-store or on our site and (where relevant) details of the fulfilment of any of your orders, and any other on-site, or in-store activity.
• Information we receive from other sources. Personal information may also be provided to us from online vendors, service providers who refer you to our sites or services, from customer lists lawfully acquired from third party vendors and from other third parties who work with us in connection with our sites or services. Third-party service providers may, without limitation, be appointed to provide technical support, process your transactions and maintain your accounts or to run promotions or marketing campaigns. We may have access to any personal information provided to such vendors, service providers and third party e-commerce services.

We use information held about you in the following ways:

• Information you give to us. We will use this information:
• • to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information, products and services that you request from us;
  • to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements
  • to send you a welcome email to verify your account when you register with the site or sign-up in-store and other emails for the purposes of providing any services, products, competitions or promotions to you, including in relation to account management or system maintenance;
  • to provide you with marketing information about other services or products we offer that are similar to those that, or services or products you have consented to receiving on the site or in-store;
  • to notify you about changes to our services and/or products;
  • build a profile of you, your preferences and your habits in order to personalise and enhance your customer experience;
  • to provide customer support; and/or
  • to ensure that content from the site is presented in the most effective manner for you and for your computer.

Please note we will not use any financial or credit card information for any purpose other than to discharge our legal / regulatory duties and to process payments paid by you for our products and services or due to you by agreement (e.g. refunds).

• Information we collect about you. We will use this information:
• • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to carry out appropriate and necessary investigations and discharge our legal and regulatory obligations and duties, including to comply with anti-fraud and anti-money laundering requirements, and (where applicable) to safeguard our staff and other customers / users in respect of unlawful, disruptive or objectionable behaviour in any of our stores or on our site;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to enhance our site and the in-store experience to ensure you receive a personalised and continuously improving customer service;
  • to allow you to participate in interactive features of our site, when you choose to do so;
  • as part of our efforts to keep our site and our stores safe and secure;
  • for data-matching purposes in respect of your use of our site / services and your use of certain third party services;
  • to deliver (whether directly or indirectly via third parties) effective and personalised marketing material and content of Craghoppers Ltd and where you have consented, other companies within our Group and to assist us in the improvement and optimisation of advertising, marketing material and content, our services and the sites;
  • to measure, understand or monitor the effectiveness of advertising, promotions, marketing material and content and any joint initiatives with our affiliates, suppliers, partners, subcontractors and other selected third parties;
  • build a profile of you, your preferences and your habits;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted; and/or
  • to make suggestions and recommendations to you and other users of our site or services about goods or services that may interest you or them.
• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
• For the avoidance of doubt, this privacy policy applies to all in-store customers (actual or potential) and users of our site, where personal information is provided or otherwise (e.g. CCTV images). For example, to the extent that promotions or competitions are offered to individuals who do not hold an account with us, and where personal information is provided, such personal information will be held in accordance with this privacy policy.

Data protection laws require that we meet certain conditions before we are allowed to use your data in the manner described in this privacy policy. We take our responsibilities under data protection laws extremely seriously, including meeting these conditions. To use your personal data, we will rely on the following conditions, depending on the activities we are carrying out:

• Compliance with legal obligations: As an entity established under the laws of England and Wales, Craghoppers Ltd is obliged to comply with UK laws and guidance provided by UK regulatory bodies. In particular, we will need to process your personal information to verify your identity, establish your age, your source of funds for anti-money laundering and fraud purposes, and to establish whether you have been barred from any of our stores or from using our site due to objectionable behaviour. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.
• Necessary for the entry into / performance of a contract: When you enter into a transaction with us, a contract between you and us will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to purchase goods from us), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up and financial information on entering into the transaction or objecting to this type of processing / exercising your deletion rights will unfortunately mean we cannot provide our goods / services to you.
• Consent: We may provide you with certain marketing information about third party services or products where you have provided your explicit consent for us to do so. Please note that we will use your personal information in order to provide certain marketing information for the same or similar services you have previously used. You have the right to withdraw your consent at any time and can object to processing of this nature.
• Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we will rely on a condition known as "legitimate interests". It is in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively. Effectively, this requires us to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with the information, products and services that you request from us), against the interests you have as a citizen and the rights you have under data protection laws (for example, to not have your data sold to third party marketing companies without your knowledge, or not store your personal data in insecure or unstable countries or regions). The outcome of this balancing test will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to certain marketing activities, where we will always rely on your explicit consent). We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.

When your data is no longer required for the purposes listed above, we will delete it within 6 years from the date of our last positive interaction with you. This data is archived where customers are inactive for a period of 2 years. In some circumstances, some of your data will be deleted in much shorter timescales, where possible (e.g. copies of marketing emails and other communications). We keep your personal information for 15 years, to enable us to retain the information we may require for legal, regulatory and guarantee purposes.

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

We will only share your personal information with other members of the Group for marketing purposes where you have expressly opted-in/consented to the disclosure of your personal data for these purposes.

We will only disclose your information to:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• members of the Group and third party suppliers and service providers for the purposes listed under HOW WE USE YOUR INFORMATION above;
• third party suppliers and service providers to the extent they assist the Group with its legal / regulatory obligations e.g. providers of services in respect of anti-money laundering, fraud, verification etc.;
• selected third parties so that they can contact you with details of the services that they provide, where you have expressly opted-in/consented to the disclosure of your personal data for these purposes;
• analytics and search engine providers that assist us in the improvement and optimisation of our site and other selected third parties; and
• your employer, educational institution (e.g. school, college or university), email or internet provider, parents (if you are under the age of 18) or law enforcement agencies, or other appropriate third parties, where we consider your behaviour to be unlawful, offensive, inappropriate or objectionable in one of our stores or on our site;

We will disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• in the event of any insolvency situation (e.g. the administration or liquidation) of Craghoppers Ltd or any of its Group;
• if we, or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• in order to enforce or apply our website terms and conditions;
• to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, other third parties, your employer, educational institution, email or internet provider, your parents (if you are under the age of 18) and/or the metropolitan police or other law enforcement agencies) for the purposes of staff and customer safety (whether this is in-store or online), crime prevention, fraud protection and credit risk reduction; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers, or those of our suppliers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

You have a number of rights under data protection law in relation to the way we process your personal data, although these are not absolute and in some instances we may be unable to accept your request, in which case we will respond to you to explain why . These are set out below. You may contact us using the details on our site (or by contacting us directly - details below) to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request.

Our Data Protection Coordinator is contactable at dataprotection@craghoppers.com or Data Protection Coordinator, Regatta Group, Basecamp, Mercury Way, Urmston, Manchester, M41 7RR. Please address any questions, comments and requests regarding our data processing practices to us in this way in the first instance.

Information and terms related to how we use your personal data in relation to our membership scheme can be accessed here.

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 you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna's privacy policy.

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:

• First Contact Team
• Information Commissioner's Office
• Wycliffe House
• Water Lane
• Wilmslow
• SK9 5AF

Any changes to this privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this privacy policy

This policy was last reviewed and updated: June 2024