Privacy Policy — Thread

  1. OUR APPROACH TO PRIVACY
    1. Thread Online Limited ("Thread", "we", "our", or "us") is totally committed to protecting your privacy. The Thread team members are customers themselves of other Internet sites and fully appreciate and respect the important of privacy on the Internet.
    2. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.
    3. Thread operates a website located at https://www.thread.com (our "Website") which provides users with personalised clothing recommendations and the ability to purchase clothes using a human stylist and machine learning algorithms (the "Thread Service"). This privacy policy applies to our Website.
    4. Please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this privacy policy.
    5. Thread is the data controller of the personal information we hold about you.
  2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
    1. We collect personal information about you when you voluntarily submit information directly to us when you access or use our Website. This can include information you provide to us when you register for an account, fill in a form, correspond with us via the Website, phone, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the Website as available from time to time.
    2. If you choose not to provide personal information, we may not be able to provide the Thread Service to you or respond to your other requests.
    3. The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
    4. We also automatically collect personal information about you indirectly about how you access and use the Website and information about the device you use to access the Website.
    5. The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
    6. We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
    7. We may anonymise and aggregate any of the personal information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Website or the Thread Service and developing new products and features. We may also share such anonymised information with others.
  3. DISCLOSURE OF YOUR PERSONAL INFORMATION
    1. As required in accordance with how we use it (as set out in the Annexes), we will share your personal information with the following categories of recipients:
      • (a) Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, delivery services, tax and accounting services, payments processing, data enhancement services, fraud prevention and credit risk reduction, web hosting, or providing analytics services.
      • (b) Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
      • (c) Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms & Conditions or to protect the security or integrity of our Website; and/or (c) exercise or protect the rights, property, or personal safety of Thread, our customers or others.
    2. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
  4. MARKETING AND ADVERTISING
    1. As part of the Thread Service, we will send you emails from time to time with recommendations from your stylist, styling tips or similar content. We may also send you other relevant information about the Thread Service, including marketing and promotional materials which we think you will find interesting. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.
    2. If you do not want to receive marketing messages from us, you can usually inform us by selecting certain boxes when you first provide your contact details to us. You can also change your preferences at any time by logging into your account and clicking on the Notifications tab within the Settings area. You can also unsubscribe by clicking on the unsubscribe link at the bottom of our emails.
  5. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
    1. Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers.
    2. International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Union ("EU"), your personal information may be processed outside of the EU including in the United States; these international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.
    3. Retention of your information. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
    4. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
  6. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
    1. In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
      • (a) Right of access and portability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it transmitted to another data controller.
      • (b) Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
      • (c) Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
      • (d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
      • (e) Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
    2. If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.
    3. You also have the right to lodge a complaint with the Information Commissioner’s Office, the data protection regulator in the UK.
  7. COOKIES AND SIMILAR TECHNOLOGIES
    1. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.
    2. Cookies are pieces of code that allow for personalisation of our Website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device's hard disk (such as your computer or smartphone) for record-keeping purposes.
    3. We use the following types of cookies:
      • (a) Strictly necessary cookies. These are cookies that are required for the essential operation of our Website such as to authenticate users and prevent fraudulent use.
      • (b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
      • (c) Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
      • (d) Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
    4. The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
    5. We also use clear gifs in HTML-based emails sent to our Customers to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our Service. You can set your e-mail options to prevent the automatic downloading of images that may contain these technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
    6. If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org.
  8. INTEREST BASED ADVERTISING
    1. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third party services to collect information about your use of our Website over time so that they may play or display ads on our Website, on other websites, apps or services you may use, and on other devices you may use.
    2. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
  9. LINKS TO THIRD PARTY SITES
    1. Our Website may, from time to time, contain links to and from third party websites. 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 their policies. Please check the individual policies before you submit any information to those websites.
  10. TRY NOW, PAY LATER WITH KLARNA
    1. In order to be able to offer you Klarna’s Pay Later payment option, we will pass Klarna some of your personal information such as contact and order details. This is so Klarna can assess whether you qualify for their payment options and to tailor the payment options for you.
    2. You can find general information on Klarna here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.
  11. OUR POLICY TOWARDS CHILDREN
    1. Our Website is not directed at persons under 16 and we do not knowingly collect personal information from children. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
  12. CHANGES TO THIS POLICY
    1. We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
  13. NOTICE TO YOU
    1. If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
  14. CONTACTING US
    1. Questions, comments and requests regarding this privacy policy are welcome and should be addressed to privacy@thread.com
    2. This privacy policy was last modified on 24 May 2018.

ANNEX 1 — PERSONAL INFORMATION WE COLLECT

Category of personal information How we use it Legal basis for the processing
Contact information and basic personal details. Such as your name, email address. We use this information to communicate with you, including sending statements, news, alerts and marketing communications and conducting market research. The processing is necessary for our legitimate interests, namely for marketing purposes, and for communicating with you effectively and responding to your queries.
We use this information to deal with enquiries and other requests made by or about you, including customer service issues, relating to our Website or the Thread Service.
We use this information to operate, maintain and provide to you the features and functionality of the Website and Thread Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms & Conditions).
Information provided by social networks you use to connect to our Website. If you connect a social network, such as Facebook, to our Website, we will collect personal information from that social network in accordance with your privacy settings on that social network. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. We use this information to operate, maintain and provide to you the features and functionality of the Website and Thread Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms & Conditions).
Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, when you respond to customer surveys or when you interact with customer service, we will record your comments and opinions. To address your questions, issues and concerns and resolve your customer service issues. The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.
Your clothing-related preferences. This includes your favourite clothing brands, fit preferences, styles, stores, preferred style photos, clothing sizes, clothing categories owned and wanted, items liked on the Website. We use this information to make personalised clothing recommendations and related advice. The processing is necessary for the performance of a contract (namely our Terms & Conditions).
Details of your appearance and similar characteristics. This includes your date of birth, photographs of you, hair colour eye colour. We use this information to make personalised clothing recommendations and related advice. The processing is necessary for the performance of a contract (namely our Terms & Conditions).
Your skin colour. Where you provide it, we use this information to recommend clothes that suit your complexion. We only collect this information with your explicit consent.
Delivery address, billing address and country. We use this information to process and deliver orders and for billing purposes. The processing is necessary for the performance of a contract (namely our Terms & Conditions).
We use this information to verify the eligibility of the users (as the Thread Service is for UK users only). The processing is necessary for our legitimate interests, namely to verify that you are a UK-based customer.
Recruiting details. Contact information and basic personal details; professional details and employment information such as resume, references, LinkedIn profile. We use this information to facilitate recruiting. The processing is necessary for our legitimate interests, namely assessing your suitability for a role with Thread.
All personal information set out above. We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Website and Thread Service, to monitor and improve the Thread Service, our Website and business, and to help us develop new products and services, for internal record keeping. The processing is necessary for our legitimate interests, namely to administer and improve the Thread Service, our business and develop new services.

ANNEX 2 — PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information How we use it Legal basis for the processing
Information about how you access and use our Website. For example, the website from which you came and the website to which you are going when you leave our Website, your social media profiles, how frequently you access the Website, the time you access the Website and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Website from multiple devices, and other actions you take on the Website. We use this information to present our Website to you on your device. The processing is necessary for our legitimate interests, namely to tailor the Thread Service to the user
We use this information to determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely for marketing purposes.
We use this information to monitor and improve our Website and the Thread Service and business, and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues and to improve the Thread Service generally.
Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Website through the device, information about the server upon which the Website operates, your Internet service provider or mobile network. We use this information to: - enable the Website to be presented to you on your device; and - operate, maintain and provide to you the features and functionality of the Website. The processing is necessary for the performance of a contract and (namely our Terms & Conditions).
We use this information to monitor and improve the Thread Service and business, and to help us develop new products and services. This processing is necessary for our legitimate interests, namely to tailor the Thread Service to the user and to improve the Thread Service generally.