Privacy Policy

1.          Introduction 

At Phoebe Philo Limited, as well as companies within its group, including Phoebe Philo SAS (“we”, “our” or “us”), we recognise and respect the importance of protecting your privacy. 

This Privacy Policy describes how we collect and process your personal data when you visit or use www.phoebephilo.com (our “Website”), as well as when you interact with us via email, telephone, post, SMS or WhatsApp, via our chat function and social media, or when you purchase products from us via our Website or in one of our stores or concessions or visit our offices. 

2.          How and when we collect your personal data 

We collect personal data about you from a variety of sources, including:

(a)         from you directly when you create an account with us, purchase products from us via our Website or in one of our stores or concessions, or when you visit our offices, or communicate with us via our Client Services team (by email, telephone, post, SMS, WhatsApp or LiveChat) and via social media;

(b)         from information we generate about you during our relationship with you, such as data collected from cookies and other similar technologies which are described in our Cookies Policy; and

(c)         from information we collect about you from other sources, such as Google and social media. This includes commercially available sources too, such as public databases (where permitted by law). 

3.          What personal data we collect 

We collect the following information from you directly:

(a)         personal details and contact information e.g. name, date of birth, telephone number, email address, billing address, shipping address, type of address (e.g. home, second home, work), payment method;

(b)         account details e.g. username and password, order or purchase history, as well as your marketing preferences per channel;

(c)         your clothing size if you require assistance with product sizing; 

(d)         your voice from call recordings we take when you contact our Client Services team by phone; and 

(e)         other personal information about you, for example, in relation to your reactions and/or feedback on our products and services, some of which may be considered health information and/or involve you providing photographs of you wearing or using our products. Giving such information is voluntary and only collected when you share it with us, for example, when you contact our Client Services team in relation to a product return or feedback. 

When you are using our Website, placing an order with us or purchasing a product from us in one of our stores or concessions, or visiting our offices, or liaising with us about an order or enquiry, we collect and process other types of information about you, such as:

(a)       CCTV footage (audio and video) of you at our relevant premises, which is date and timestamped; 

(b)         technical information collected from your computer or mobile device when browsing our Website e.g. your IP address, your location (by country, state and city), device type, browser type, operating system; and 

(c)         information generated about you e.g. orders placed or transactions made by you which will include details, such as the value of orders, products purchased; and information about your visit to our Website, such as your saved items, the pages you visit, how often you use our Website, all of which help us to understand your interests. 

Finally, we collect information about you from other sources, such as:

(a)       from our delivery partners in relation to the status of your orders e.g. name, signature, location of your order and proof of delivery photographs; 

(b)       from our service providers such as Global-e NL B.V. (“Global-e”), our third party e-commerce cross border partner in relation to orders placed for delivery to Australia, Hong Kong SAR, Japan, Singapore and South Korea, from which we collect your personal and contact details (including your address and email) as part of the order process via Global-e’s checkout. From time to time, Global-e may also share your personal data with us for us to help Global-e with queries related to returns. Where you consent to receive marketing emails from us via Global-e’s checkout, Global-e will share your personal data with us for the purpose of us sending you marketing communications. Global-e may use your personal data for their own restricted purposes such as analytics – for more information, please see Global-e’s privacy policy (available at the checkout stage). Other relevant service providers include our CCTV and security providers will provide information about you to us, as well as law enforcement agencies; and

(c)         publicly available information required for identity verification purposes via Google and social media e.g. gender, country you are located in. 

4.          How we use your personal data and the legal basis on which we use it

Purpose Activity  Legal basis 

To process your orders and to facilitate any returns, we use: 

·       personal and contact details (including your address); 

·       call recordings (where appropriate); and

·       where relevant and provided by you, photographs of products (which may include images of you wearing or using a product). 

We use your personal data to process and deliver any orders that you place with us, and keep you informed of its status. 

Similarly, if you return a product, this information will be used to process and complete any return, including arranging for the product to be picked up. 

Please note that any details taken to process payment for your order, as well as issuing a refund for a return, is done via our third party payment processor. For more information about our third party payment provider, please contact us.

We will also use the personal data you provide at Global-e’s checkout in order to support in the fulfilment of your order and monitor its status. From time to time, Global-e may also share your personal data with us in order for us to support them with specific queries. 

 This is so that we can comply with our contractual obligations to you and Global-e.

To process transactions or handle enquiries in one of our stores or concessions we use:

·       personal and contact details (including your address); and 

 ·       information generated about you e.g. purchase history.  

In our stores, we use your personal data to ensure we can process your transaction, as well as manage any returns. Please note that any details taken to process payment in one of our stores, as well as issuing a refund for a return, is done via our third party payment processor. For more information about our third party payment provider, please contact us.

Please note that in our concessions, the transactions and returns are managed by the relevant third party retailer.

For both our own stores and concessions, we will use your personal data to help respond to your enquiries and fulfil your requests. For example, using your personal data to notify you about a product you may wish to have ordered into a store.

This is so that we can comply with our contractual obligations to you.

It is also in our legitimate interest that we are able to respond to your enquiries or requests in an appropriate and personalised way and also assist you with your shopping experience with us.  

To operate our business, we use:

·       personal and contact details; 

·       account details;

·       where relevant and provided by you, photographs of products (which may include images of you wearing or using a product); 

·       call recordings (where appropriate);

·       technical information (as described above); and

 ·       information generated about you e.g. orders placed by you.

 We also use your personal data where it is necessary to verify your identity and to satisfy legal or regulatory requirements to which we are subject. Further, we use your personal data in order to exercise and protect our legal rights. For example, to detect, prevent and respond to:

(i) fraudulent activity and claims, such as creation of new accounts by banned users;

(ii) intellectual  property infringement claims;

(iii) violations of law or our terms of purchase; and

(iv) to prevent or detect counterfeits.

 It is in our legitimate interest to operate our business in an efficient, safe and lawful way and protect it from fraudulent or other unlawful activity. In some cases, we are under a legal obligation (whether by a regulatory authority or a court order) to conduct certain checks and disclose personal data. 

To communicate with you, we use: 

·       personal and contact details;

·       account details; 

·       your clothing size if you require assistance with product sizing; and·       other personal information that you decide to share with us. 

 We may use your personal data when we communicate with you, for example, if we are providing information about changes to our terms of purchase or if you contact us with questions about any products, services or our business in general. 

It is in our legitimate interest that we are able to respond to your queries in an appropriate and personalised way and also assist you with your shopping experience with us.

Also, it is in our legitimate interest to provide you with relevant information about our products, services and/or business.

To ensure the physical security and safety of you, our staff and premises  

To ensure the security of our business, as well as the safety of our staff and visitors, we use CCTV which may capture your image and audio when attending our stores or offices.

If you attend one of our stores or offices, we may also process personal data that you volunteer in connection with your visit. For example, you may volunteer personal data when signing in as a guest.  

 It is in our legitimate interest to ensure the physical security and safety of our stores, offices, staff, visitors and property
We also have legal obligations to guard against and detect crime, as well as to facilitate the investigation, prosecution or defence of such. We also have legal obligations to comply with health and safety laws  

To improve our business, we use:

·       personal and contact details;

·       account details e.g. username and password, marketing preferences;

·       information about or from the various communications you have with us e.g. when you contact us with a query or raise a return, this can include photographs you may provide to us as part of a return, as well as call recordings we take when you contact our Client Services team;

·       technical information (as described above); and

·       information generated about you or shared by you e.g. as part of feedback.

 We analyse information about your use of and feedback on our Website, products and services to provide an improved customer experience. We may use your personal data for product testing and development, as well as site analytics. it is in our legitimate interest to conduct research and analytics in relation to the running of our business so that we can understand any issues with our Website, services or products in order to improve them.

To communicate with you, we use:

·       personal and contact details;

·       account details;

·       your clothing size if you require assistance with product sizing; and

other personal information that you decide to share with us.

 We may use your personal data when we communicate with you, for example, if we are providing information about changes to our terms of purchase or if you contact us with questions about any products, services or our business in general. It is in our legitimate interest that we are able to respond to your queries in an appropriate and personalised way and also assist you with your shopping experience with us. Also, it is in our legitimate interest to provide you with relevant information about our products, services and/or business.

To inform you about our products,  services, events or other news that may be of interest you, we use:

·       personal and contact details;

·       account details;

·       technical information (as described above); and

information generated about you.

 We use your personal data to better understand your preferences and to personalise the messages we send to you. This includes sending you information by email and/or post about our products and services, as well as news or events that may be of interest to you.

When you consent to receive marketing emails from us via Global-e’s checkout, Global-e will share your personal data with us for the purpose of us sending you marketing communications.

We work with trusted marketing agencies to carry out social media advertising. Our marketing lists which contain your personal data are used by us to help us reach new audiences with similar interests to you without targeting individual users by analysing commonalities within our marketing lists. Your personal data is not shared with such marketing agencies as we use anonymised and/or aggregated data to produce lookalike audiences whose demographics and interests are similar to yours. 		We add you to our marketing list on the basis of your opt in consent which is either collected by us (online or in our stores or concessions) or on our behalf by Global-e. You may opt out at any time without affecting the lawfulness of any processing  undertaken prior to you withdrawing such consent.
To analyse our marketing lists, it is in our legitimate interest that we are able to grow our business and reach new audiences.

To customise your experience, we use:

·       personal and contact details;

·       technical information (as described above); and

information generated about you, for example, details  about device type, pages visited on the Website. For more information, please see our Cookies Policy.

 When you use our Website and services, we may use your personal data to improve your experience with us. It is in our legitimate interest to provide and develop our services and Website based on your feedback and content generated about you.

5.          How and when we share your personal data

         We may share your personal data with third parties under the following circumstances:

(a)         We share your personal data with our service providers and business partners. These third parties belong to the following categories:

(i)          Companies that help us process your order, such as our payment service provider, as well as our warehouse and logistics services provider. 

(ii)         Companies that help us deliver your order, such as couriers and parcel delivery companies who act as data controllers for the duration of the delivery process. 

(iii)        Professional service providers, such as CCTV and security providers, messaging services, telephony providers, IT software providers, sales tax software providers, marketing and research agencies, profile and behavioural analytics companies and website hosts who help us run our business. 

(iv)        Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud and, as necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

(v)         Governmental bodies and regulators to comply with our legal obligations.

Further details about the specific third parties we engage can be provided on request.

(b)         Group companies

We work closely with other companies which are part of our group, which includes, Phoebe Philo SAS. We may share your personal data with such companies for the purposes of security, optimisation of our products and services, as well as internal reporting. 

(c)         As required by law

We may share your personal data with law enforcement agencies, courts, government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of a third party.

(d)         In the context of a transaction

We may share your personal data with potential partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal data to use it in a manner that is consistent with this Privacy Policy.

6.          How we secure and store your personal data

We implement physical, technical and organisational security measures designed to safeguard the personal data that we process. These measures are aimed at providing the ongoing integrity and confidentiality of your personal data. We evaluate and update these measures on a regular basis. However, no information system is impenetrable, so we cannot guarantee the absolute security of your personal data.

We retain your personal data in line with the following: our retention policy; as required by law; for our business purposes; to investigate or defend against potential legal claims; and to help prevent fraudulent activity. We only retain personal data for as long as it is required. 

8.          International Data Transfers

In some cases, your personal data will be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal data as the UK and EEA.  At all times, we will ensure that we put in place appropriate safeguards to provide adequate protection of your personal data in accordance with applicable legal requirements

For more information on these safeguards or to obtain a copy of such safeguards, please contact us at: digital-privacy@phoebephilo.com.

9.          Your Rights 

You may, in certain circumstances, have rights in relation to the personal data that we hold about you. These may include the rights to access, correct, delete, restrict or object to our use of, or the processing of your personal data. You may also request a portable copy of your personal data in a usable electronic format. Where you have provided your consent to any use of your personal data, you can withdraw this consent at any time.

We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. 

Please note that we may require additional information from you in order to honour your requests. There may be situations in which we will not be able to comply with your request due to our legitimate interests or legal obligations.

If you would like to discuss or exercise any rights you may have, please contact us at: digital-privacy@phoebephilo.com.

If you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the UK data protection regulator, the Information Commissioner’s Office: https://ico.org.uk/.

For the EU, a list of supervisory authorities and their contact details can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

9.        Changes to this Privacy Policy

We may modify or update this Privacy Policy from time to time. If we make any revisions that materially change the way in which we process your personal data, we will notify you of these changes before applying them.

10.        Changes to this Privacy Policy

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email at digital-privacy@phoebephilo.com.

Last Updated: 6 March 2025