Privacy Policy

Boots Retail USA Privacy Policy

We are committed to maintaining our customers' privacy and take great care to safeguard the information that we collect to ensure that our customers' privacy is maintained. We have provided this Privacy Policy to you to describe our information collection and use practices at Boots Retail USA, Inc. This Privacy Policy also describes the choices you can make about the way your information is collected, used, and shared. By interacting with Boots Retail USA, Inc. through our websites, mobile applications, products, and services, you consent to the use of your information that is collected or submitted as described in this Privacy Policy. We may change or add to this Privacy Policy, so we encourage you to review it periodically.For California residents, there is an "Information for California Consumers" section in this Privacy Policy. For Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia residents, there is a "State Privacy Laws" section in this Privacy Policy.

Personal information includes information that can be used to reasonably identify you,directly or indirectly.Types of personal information we collect may include information such as your name, date of birth, email address, mailing address, phone or mobile number, credit/debit card number, and other identifying information. We may also collect information that does not directly identify you by name or contact information, but which may be used to identify that a specific computer or device has accessed our website or online services.Personal information does not include aggregated or de-identified information.

Throughout this Privacy Policy, ‘we’ means Boots Retail USA, Inc. We are part of the Walgreens Boots Alliance group of companies, including subsidiaries, affiliates, joint ventures and franchises (collectively “Companies”). You can find out more about the Companies at Walgreensbootsalliance.com

Information We Collect

Information we collect directly from you

We collect information about you whenever you visit our website or mobile application, sign up for an account, subscribe to our notifications, make an online or phone purchase with us, request customer service assistance, participate in a contest, sweep stake, promotion or survey, post a review or comment on our website, or post other user generated content on our website.

Information we collect from your use of our services

Log information refers to information that is automatically sent by your web browser or device (or otherwise automatically collected by us) each time you view or interact with our online services and ads. Log information may include the online service(s) requested; date and time of your request; referring URL (i.e., the website you came from); your device's Internet Protocol (IP) address; location data derived from your device's IP address; browser type; browser language; device operating system; device hardware and other characteristics; information regarding your use of our online services (e.g., pages viewed, features used, number of clicks, time spent on a particular page); and related device and usage data. Log information is automatically recorded by our servers each time you view or interact with our online services and ads.

Device information refers to device-specific information that we automatically collect when you view or interact with our online services and ads. Device information may include your device type and model; device operating system and version; unique device and advertising identifiers; mobile network information; and related device information. To learn more about the information your device may make available to us, please check the policies of your device manufacturer or software provider.

Information we collect online: Cookies and Similar Technologies

We use Cookies on this website. A 'Cookie' is a small data file that is sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit (“session cookies”) or for a fixed period of time (“persistent cookies”). Cookies enable us to recognize your computer when you visit the site and make using our website quicker and easier (e.g. login fields may be pre-filled with your email address). Cookies are also essential to the functioning of certain parts of the site, and we use them to collect information about how the site is used, such as how many people visit and return and what products are being viewed. We may also use Cookies for marketing and to give you a more personalized experience on our website.

How we use Cookies,Beacons and Similar Technologies:

Making our website work:

Certain Cookies are essential so that you can move around the site and log in to your Account. Without them you would be unable to take certain actions on our website or access your account.

Monitoring and improving the performance of the website:

We may use Cookies to collect information about how visitors use the site,e.g. which pages they visit most often and whether they see error messages. The information is aggregated so it does not identify individuals, and we use it only to help us improve the way the website works.

Enabling the features of the website:

We may use Cookies that allow our website to remember choices you have made, such as your username, and help us provide you with a better, more personalized experience. For example, they may allow you to watch a video clip, comment on a blog or add a product review.

Marketing and advertising:

We may use Cookies to deliver advertisements that are more relevant to you, as well as to limit the number of times you see a particular advertisement and to measure the effectiveness of advertising campaigns. The Cookies remember that you have visited a website, and this information may then be shared with other organizations for advertising purposes.

What are ‘Flash Cookies’ (or ‘Local Shared Objects’)?

If your browser does not support HTML5 player, we may deliver video content using Adobe Flash Player instead (although you may experience display problems if your browser is unsupported). Flash Cookies are stored on your device in a similar way to other types of Cookie, but they're managed differently by your browser, and the cookie management tools provided by your browser will not remove Flash cookies. If you wish to disable or delete them you can do this through Adobe Flash Player security settings or by visiting the Adobe website. 

Restricting or blocking Cookies

As you will have seen in ‘How We Use Cookies’ above, some parts of our website need Cookies in order to function correctly. By default, Cookies should be enabled on your computer or device, and although you can ‘disable’ them in your browser this will affect your experience on the website. You will be limited to browsing,viewing and searching for products but may not be able to take additional actions on our site or log in to your account.

If you'd still prefer to restrict,block, or delete Cookies from this or any other website, you may do so in your internet browser. Each browser is different, so you’ll need to go to the 'help' menu on your browser and look for how to change your ‘Cookie preferences’. The website www.aboutcookies.org contains comprehensive information on how to do this on a wide variety of browsers.

Disabling advertising Cookies

We may engage third party advertisers to provide interest-based advertising on our website, as well as other third party sites in order to display advertising that is relevant to you. These third parties may collect information about your use of our services over time and that information may be combined with information collected on different websites and online services.

If you are concerned about behaviorally targeted advertising Cookies (which serve you advertisements based on your use of this website and other websites), you can visit either about ads or network advertising and opt out of advertising Cookies. 

Please Note: When you "opt-out" of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us.It means that the online ads that you do see will not be tailored for you based on your particular interests. We may still collect information about you for any purpose permitted under the Policy, including for analytics.

Google Analytics

Some of our online services may use Google Analytics, a web analytics service provided by Google. Google Analytics utilizes cookies and similar technologies to collect and analyze non-identified information (i.e., data that does not identify a specific individual) about the performance and use of our online services and ads. More information on Google Analytics can be found here. If you would like to opt-out of having your information collected and used by us and our online partners as described herein, please use the Google Analytics opt-out.

Interactive Services

Our website may provide interactive services, including chat bot and managed chat. By accessing or using these features, you agree that we may record and retain a transcript of all communications with you via these interactive tools and may record or recreate your activity while using the website,in order to provide services, enhance your website experience, and for quality and verification purposes. We may work with trusted service providers to analyze, store, and/or use this data on our behalf. Your use or access of any of these tools or of our website is governed by this Privacy Policy and this section.

Your privacy and shared computers

If you log in to the website from a shared computer, such as in an internet cafe or from a colleague’s computer at work, Cookies may cause your email address to display in the login field to anyone who uses the site on that computer after you. You can avoid this by clearing the Cookies stored by the web browser. The option to do this can normally be found within your browser ‘tools’ preferences.

Information we obtain from external companies

We collect data that is publicly available. For example, information you submit in a public forum (e.g., a blog, chat room, or social network) can be read,collected or used by us and others, and could be used to personalize your experience. You are responsible for the information you choose to submit in these instances.

From time to time, we may supplement the information we hold about you with data from other commercially-available sources like third party partners, organizations, and other companies. This helps us keep our records up to date and learn more about our customers so we can continue to improve our products and services.

Information from within our parent company

As noted above, Boots Retail USA, Inc. is part of the Walgreens Boots Alliance group of companies. If you are also a customer of Boots or other companies in our group, we may consolidate the information we hold about you across our Companies. This helps us build a better picture of our customers, develop our products and services and, with your consent, provide you with offers and information we think may interest you.

How We Use Your Information

Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience. We may use your information in a variety of ways, including for the following purposes:

Product and Service Fulfillment

We use your information to respond to your inquiries, fulfill your product and service requests, and improve your experience.

Our Marketing Purposes

We may analyze your information, including the products you view and buy, your browsing habits and other ways you interact with us, to evaluate the effectiveness of our advertising and help us provide more relevant offers and content. We may also use your information to deliver coupons, mobile coupons, newsletters, e-mails, mobile messages, social media notifications and other notifications about our brands, products, events, or other promotional purposes.

Internal Operations

We use your information to improve the effectiveness of our services, conduct research and analysis, or to perform other business activities as needed.

Legal Compliance and As Necessary or Appropriate Under Applicable Law

We may use your information as necessary or appropriate under applicable law, to comply with legal process, to respond to such requests from public and government authorities (including law enforcement), to enforce our terms and conditions, including investigations of potential violations, to detect, prevent or otherwise address fraud, security or technical issues, to protect our rights, privacy, safety or property, and to allow us to pursue available remedies to limit the damages that we may sustain. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use personal information without your consent or court process.

Prevention of Fraud and Other Harm

We may use your information to detect, prevent, or investigate potential security incidents and fraudulent transactions,monitor against fraud, and to otherwise protect our customers and our business.

Research

We may invite you to take part in market research activities such as customer surveys, questionnaires, or focus groups.

How We Share Your Information

We may share your information with companies,organizations and individuals outside of Boots Retail USA, Inc. as described below. Please note that certain state laws have adopted a broad definition of a "sale" or "share" and may treat certain of these disclosures as sales or sharing under their definitions. Please see the "Information for California Consumers" and “State Privacy Laws”sections for additional information.

Internally

We may share your information with our parent company or affiliates, including but not limited to, Walgreens Boots Alliance Inc. and Walgreen Co.

When We Work With Third Parties

We may share your information with companies who provide services on our behalf that are related to our business. These tasks may include analyzing website usage data, customer service, electronic and postal mail service, and social and other media services.Service providers only receive your personal information to perform services pursuant to a contractual agreement.

Examples of the functions that may be carried out by external companies:

Customer service center

Mailing houses

Printers

Couriers

Delivery services

Manufacturers or suppliers

Companies that cleanse data

Payment providers

Companies that do fraud and money laundering checks

Companies that provide web hosting, content providers, competitions, and sweepstakes

Data storage facilities

IT services and support

We may work with other companies who place cookies, tags, and web beacons on our websites. These companies help operate our websites and provide you with additional products and services. We may also use third party advertising networks to serve advertisements on our behalf. The cookies received with the banner advertisements served by these networks may be used to collect and build behavioral profiles by these companies to deliver targeted advertisements on our website and unaffiliated websites.

We may work with other companies who operate their own websites or mobile applications, to allow them to offer our customers the ability to connect to our services. These services give you more options for ways to use our services from websites or applications that are not owned or operated by Boots Retail USA, Inc.

Non-identifiable or Aggregate information with Third Parties

We may share non-identifiable or aggregate information with third parties for lawful purposes.

Legal obligations

We may share your Information with third parties where required or permitted by law, if we believe we need to do so to protect our rights and interests, or to comply with legal proceedings, to enforce or apply our terms and conditions and other agreements, to facilitate the financing, securitization, insuring, sale, assignment, or disposal of all or part of our business or assets, or to protect the property or safety of our company, customers, or others. In such cases, we will always do so legally and with due regard to your privacy.

With Your Consent

At your direction or request, or where you otherwise consent, we may share your information.

Changes to our business

If ownership of all or part of our business changes or we undergo a reorganization (including a merger or transfer between Walgreens Boots Alliance companies), we will transfer your information to the new owner or successor company so we can continue to provide our services. We also may retain a copy of your information.

How Long We Retain Information

We retain your personal information for the business and commercial purposes described above in the “How We Use Your Information” section.Retention of your information may also be required to provide products and services you requested, to maintain our business relationship with you, or for us to fulfill a legal obligation. Once no longer needed for these purposes, we will not retain your information in our systems.

Your Choices

By interacting with us as described herein, you consent to the practices described in this Privacy Policy.However, we want you to know that you do have certain choices with regard to how your information is collected and used.

Email and Mobile Communications

We provide our customers with the opportunity to update their information or opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product order or servicing of your product. To opt-out of marketing communications, you may:

Send us an e-mail at customer.experience@thehutgroup.com;

Unsubscribe from our email communications at any time by clicking the unsubscribe button at the bottom of the e-mail.

Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. If you receive marketing communications from one or more company affiliates, you must opt out individually from each of the affiliates from which you are receiving brand-specific marketing communications.

Links to Third-Party Websites

Our services may contain links to, or otherwise make available, social media sites and other third party services, websites and mobile applications that are owned,operated, or controlled by third parties. We do not take responsibility for the content or privacy practices employed by third party sites. Unless otherwise stated, any information you provide to any such third party site will be collected by that party, and will be subject to that party’s privacy notice (if any), rather than this Privacy Policy. In such a situation, we have no control over, and shall not be responsible for, that party’s use of the information you provide to them.

Social Media and Ads

We engage with guests on multiple social media platforms (e.g., Facebook and Instagram). If you contact us on one of our social media platforms, request guest service via social media, or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other social media tools to interact with you.In these instances, your interactions with us are governed by this privacy policy as well as the privacy policy of the social media platform you use.

We may display targeted ads to you through social media platforms and other websites. These ads are sent to groups of people who share traits such as likely commercial interests and demographics. For example, we may target guests who have expressed an interest in shopping for cosmetics, skincare, etc.

You may see ads that are tailored to your interests, based on the information we hold about you. For example, your age or the products you have browsed on our website. See the policies of each social media platform for additional information about these types of ads.

Social Media Plug-Ins

Our online services may use social media plug-ins (e.g., the Facebook "Like" button, "Share to Twitter" button) to enable you to easily interact with certain social media websites (e.g., Facebook, Twitter, Instagram) and share information with others. When you visit our online services, the operators of the available social media plugins can place a cookie on your device enabling such operators to recognize individuals who have previously visited our online services. If you are logged into these social media websites while visiting our online services, the social media plugins allow the relevant social media websites to receive information that you have visited our online services or other information. The social media plugins also allow the applicable social media websites to share information about your activities on our online services with other users of the social media website. For example, Facebook Social Plugins allow Facebook to show your "Likes" and comments on our online services to your Facebook friends. Facebook Social Plugins also allow you to see your friends' Facebook activity on our online services. We do not control any of the content from the social media plugins. For more information about social media plugins from other social media websites, please refer to those websites' privacy and data sharing statements.

Our "Do Not Track" Policy

Please note that this website does not interpret or respond to "do not track" signals. However, you may set your Web browser to not accept new cookies, be notified when you receive a new cookie, or disable cookies altogether. Please note that by disabling these features, your experience will not be as smooth and you will not be able to take full advantage of our website's features. Please see the Help section of your browser for instructions on managing security preferences.

 Minors

We recognize the importance of protecting children’s privacy online. Our website and services are intended for a general audience and are not directed at children. We do not knowingly collect personal information from children under the age of 13.

If you are under the age of 18 and are a registered user of the site, you may request that we remove content or information that you have posted on our website. Please note that responding to your request may not ensure a complete or comprehensive removal (e.g., if the content or information has been reposted by another user.) To request removal of content or information, please contact us at through your account help center or at customer.experience@thehutgroup.com.

Accessing and Updating Your Information

If you wish to verify, correct, or update any of your personal information, you may visit the “Your Account Page” to sign into your account, or otherwise contact us at the address or e-mail in the “Contact Us” section below. If you choose to deactivate your account, we may still retain certain information for analytical purposes and record keeping integrity, as well as to prevent fraud, resolve disputes, enforce our Terms of Use or other policies, take actions we deem necessary due to technical and legal requirements, and as dictated by constraints related to the security, integrity and operation of our Site.

Interest-Based Advertising

To learn more about interest-based advertising, or to opt-out of having your web browsing information used by certain third party advertisers for behavioral advertising purposes, please visit either About ads or Network Advertising.

How We Protect Your Information

Security Measures

We maintain administrative, technical, and physical safeguards to protect your information. When we collect or transmit sensitive information such as credit or debit card number, we use industry standard methods to protect that information. However, no e-commerce solution, website, mobile application,database or system is completely secure. You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.If you have reason to believe that your interaction with us is no longer secure, please immediately contact us in accordance with the Contact Information section below.

Email Security

“Phishing” is a common e-mail scam where your email address is used to contact you and ask for personal or other sensitive information. Always be cautious when opening links or attachments from unsolicited third parties. Always know that Boots Retail USA, Inc. will not send you emails asking for your credit card number, social security number or other personally identifiable information. If you are ever asked for this information, you can be confident it is not from Boots Retail USA, Inc. If you believe a website or email purporting to be from Boots Retail USA may be fraudulent, please contact us using the Contact Information section below.

We may periodically update this Privacy Policy and therefore recommend that you check back here occasionally. We will notify you of material changes to this Privacy Policy by posting on our websites notification that the Privacy Policy has been revised and by updating the effective date of the Privacy Policy.

Information for California Consumers:

If you are a California resident, we are required to provide additional information to you about how we collect, use and disclose your information that may be considered "Personal Information" under California Law ("CA Personal Information"), and you may have additional rights with regard to how we use and disclose your CA Personal Information. We have included this California-specific information below.

Collection. Consistent with the "Information We Collect" section above, we collect certain categories and specific pieces of CA Personal Information about individuals that reside in California. Specifically, we may collect the following types of categories of CA Personal Information:

Identifiers: such as name, address, telephone number, email address, age, date of birth, username and password for our websites, online identifiers, IP address;

Characteristics of protected classifications under California or Federal Law: such as sex, gender, age (40 or older);

Commercial information: such as products or services purchased,obtained or considered, other purchasing or consuming histories or tendencies and payment information;

Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard we blog information;

Geo location information: such as physical location information through the use of our Services on your mobile phone or device by, for example using satellite, cell phone tower,WiFi signal, beacons, Bluetooth and near field communication protocols;

Audio, visual, or similar information: such as photographs you share, customer service audio recordings; and

Inferences drawn from the above categories of CA Personal Information: such as consumer preferences, characteristics, predispositions, and behavior.

Sources. We may collect certain categories of CA Personal Information from you and third parties as described in the "Information We Collect" section above. The categories of sources from which we may collect CA Personal Information include the following:

On our websites and mobile applications (parent,subsidiary and affiliate brands)

When you communicate with our Customer Care Center

Third party websites and mobile applications (e.g., websites that share information with us or our advertising partners regarding your online activities)

Online advertising companies

Delivery partners/carriers

Social media companies

Other service providers

Purposes. We collect CA Personal Information for the business and commercial purposes described in the "How We Use Your Information" section above.Specifically, we collect CA Personal Information to respond to your inquiries, fulfill your requests and improve your experience; for marketing, advertising and promotional purposes; for reporting and analytics; to improve the effectiveness of our services, conduct research and analysis, or for other internal operations purposes; to detect, prevent or investigate potential security breaches, fraudulent transactions and monitor against theft.

Retention. We retain CA Personal Information for the business and commercial purposes described in the "How We Use Your Information" and “Purposes” sections above. Retention of you CA Personal Information may also be required to provide products and services you requested, to maintain our business relationship with you, or for us to fulfill a legal obligation. Once no longer needed for these purposes, we will not retain your CA Personal Information in our systems.

Sharing your CA Personal Information for business purposes: As described above in the "How We Share Your Information" section, we may share the following categories of CA Personal Information with third parties who are considered “service providers” as defined under California law since we disclose CA Personal Information to them for our business purposes:

Identifiers: such as name, address, telephone number, email address, age, date of birth, username and password for our websites, online identifiers, IP address;

Characteristics of protected classifications under California or Federal Law: such as sex, gender, age (40 or older);

Commercial information: such as products or services purchased,obtained or considered, other purchasing or consuming histories or tendencies, payment information;

Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard we blog information;

Geo location information: such as physical location information through the use of our Services on your mobile phone or device by, for example using satellite, cell phone tower,WiFi signal, beacons, Bluetooth and near field communication protocols;

Audio, visual, or similar information: such as photographs you share, customer service audio recordings; and

Inferences drawn from the above categories of CA Personal Information: such as consumer preferences, characteristics, predispositions, and behavior.

As described above, examples of business purposes include product and service fulfillment, internal operations, prevention of fraud and other harm, and legal compliance.

The categories of third party service providers to which we may share the above described categories include Payment Processing Companies, Data Analytics Providers, Fraud Prevention Providers, Cloud Storage Providers, IT Service Providers, Professional Service Providers, Delivery Partners, and Marketing Companies.

In addition, we may share the aforementioned categories of CA Personal Information with third parties involved in the evaluation of or entry into the sale or purchase of stores or company assets, mergers, or acquisitions. The categories of third parties to which we may share the above described categories of CA Personal Information include potential Business Partners or Purchasers, Professional Service Providers (e.g., consultants, lawyers, accountants), and Data Analytics Providers.In the event of sale, merger, or acquisition, customer information (including CA Personal Information)generally is one of the transferred business assets, as is permissible under law.

Sale and Sharing of CA Personal Information: As described above in the "How We Share Your Information" section, we may share the following categories of CA Personal Information with third parties who are considered “third parties” as defined under California law since we disclose CA Personal Information to them which they may use for secondary purposes. Our disclosure of CA Personal Information to the third parties who use the information for secondary purposes may constitute a "sale” or “share” of CA Personal Information as defined under California law.We share the following categories of CA Personal Information (which may constitute a "sale" or "sharing" of CA Personal Information under California law):

Identifiers: such as online identifiers, IP address;

Commercial information: such as products or services purchased,obtained or considered, other purchasing or consuming histories or tendencies;

Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard we blog information;

Geo location information: such as physical location information through the use of our Services on your mobile phone or device by, for example using satellite, cell phone tower,WiFi signal, beacons, Bluetooth and near field communication protocols; and

 Inferences drawn from the above categories of CA Personal Information: such as consumer preferences, characteristics, predispositions, and behavior.

The categories of third parties to which we may sell or share (as defined by California law) the above-described categories of CA Personal Information include Online Advertising Networks, Marketing Companies, Financial Services Partners and Social Media Companies.

Opting Out of the Sale and Sharing of CA Personal Information.You may stop our disclosure of your CA Personal Information to these entities for their use for secondary purposes by opting-out of the sale or sharing of your CA Personal Information. You can do so by submitting an opt-out request by clicking the“Do Not Sell or Share My Personal Information” link in the footer or by contacting us at customer.experience@thehutgroup.com.

Opt-out Preference Signal. You may opt out of the sale and sharing of your CA Personal Information at a browser level. Browser level opt outs are based on your unique browser and device. In addition to manually opting out at a browser level through clicking on the "Do Not Sell or Share My Personal Information" link in the footer, we also have processes in place to recognize opt-out preference signals you set on your browser or device and honor those signals when you visit our website as a request to opt out of the sale and sharing of your CA Personal Information. To enable an opt-out preference signal, you must use a platform or internet browser with technology to set and communicate your preferred privacy setting.

Deidentified Information.We may also maintain and use information that does not identify an individual and cannot reasonably be used to identify an individual which is derived from CA Personal Information. We will not attempt to re identify deidentified CA Personal Information unless permitted by law.

Business to Business Consumers.This "Information for California Consumers” section, including the “California Consumer Rights” subsection below also applies to CA Personal Information collected from individuals acting as an employee, owner, director, officer, or contractor of another company, partnership, sole proprietorship, nonprofit, or government entity, in the context of conducting business with us.

California Consumer Rights. Subject to certain exceptions, as a California resident, you have the right to request and access, including in a portable, machine-readable format,any or all of following types of information regarding the CA Personal Information we have collected about you:

Specific pieces of CA Personal Information we have collected about you;

Categories of CA Personal Information we have collected about you;

Categories of sources from which such CA Personal Information was collected;

Categories of CA Personal Information we sold or disclosed for a business purpose about you; and

The business or commercial purpose for collecting or selling your CA Personal Information.

You also have the right to request correction or deletion of your CA Personal Information and to opt out of the sale or sharing of your CA Personal Information. In addition, you have the right to appeal our refusal to act on your request.

Exercising California Consumer Rights.You or your authorized agent may exercise your California Consumer Rights by submitting a request using one of the following designated methods:

Email us at customer.experience@thehutgroup.com and indicate which California Consumer Right(s) you wish to exercise.

To submit a request to opt-out of the sale or sharing of your California Personal Information, click the“Do Not Sell or Share My Personal Information” link in the footer.

Responding to Requests. For requests for access, correction, deletion, or appeal, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We provide a substantive response to your request as soon as we can,generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

For requests to opt out of the use of your CA Personal Data for purposes of targeted advertising and sale we will comply within 15 business days after receipt of your request.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests.When this is the case, we will endeavor to provide you with an explanation as to why.

Requests By Authorized Agents.You may designate an agent to submit requests on your behalf. If you would like to designate an agent to act on your behalf, your agent must provide us your CA Personal Information and provide signed documentation demonstrating that you authorized the agent to submit a request on your behalf.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with your state’s law pertaining to powers of attorney.

Verification of Requests.Once we receive your request via email, we may request additional information related to your account and/or your recent interactions with us, such as recent purchase history, to prevent fraudulent requests and ensure we accurately locate your Personal Data.

Nondiscrimination.Should you wish to request the exercise of your rights as detailed above with regard to your CA Personal Information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products or services, based solely upon this request. You may receive a different level or quality of goods or services as permitted by California law in connection with programs such as Balance Rewards if you exercise your right to request deletion of, or your right to opt-out of the sale or sharing of, your CA Personal Information. To the extent you provide CA Personal Information in connection with programs such as Balance Rewards,additional information about the terms applicable to those programs, including our use of CA Personal Information in exchange for the applicable financial incentives, can be found in the terms and conditions for those programs.

No Sale of Minors’ Personal Information.California law requires California residents under the age of 16 to opt-in to the sale or sharing of CA Personal Information.As a result, certain programs and services may be unavailable to California residents under the age of 16.

Metrics. California law requires recording of metrics regarding requests for Access, Correction, Deletion, and Opting-out of Sale/Sharing submitted by California residents pursuant to the California Privacy Rights Act. The metrics below reflect the time period from January 1, 2024, to December 31, 2024.

	Access	Correction	Deletion	Opt-out of Sale/Sharing
Requests Received	0	0	11	94,775
Completed	0	0	11	94,775
Expired/Rejected	0	0	0	0
Median Days to Fulfill	0	0	1	1

State Privacy Laws

If you are a Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia resident, we are required to provide additional information to you about how we collect, use and disclose your information that may be considered "Personal Data" under your State’s Privacy Law, and you may have additional rights with regard to how we use and disclose your Personal Data. We have included this State Privacy Law-specific information below.

Processing. Consistent with the "Information We Collect" section above, we process certain categories and specific pieces of Personal Data about individuals who reside in the States listed above. In the 12 months prior to the date of this Privacy Policy, we collected the following types of categories of Personal Data, which we will continue to collect:

Identifiers: such as name, address, telephone number, email address, age, date of birth, username and password for our websites, online identifiers, IP address;

Commercial information: such as products or services purchased,obtained or considered, other purchasing or consuming histories or tendencies, payment information, and loyalty program participation information;

Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard we blog information;

Geo location information: including location data and precise location data such as physical location information through the use of our services on your mobile phone or device by, for example using satellite, cell phone tower,WiFi signal, and beacons;

Audio, visual, or similar information: such as photographs you share, and customer service audio recordings; and

Inferences drawn from the above categories of Personal Data: such as consumer preferences, characteristics, predispositions, and behavior.

Deidentified Information. We may also maintain and use information that does not identify an individual and cannot reasonably be used to identify an individual which is derived from Personal Data. We will not attempt to reidentify deidentified Personal Data unless permitted by law.

Purposes. We collect Personal Data for the business and commercial purposes described in the "How We Use Your Information" section above. Specifically, we collect Personal Data to respond to your inquiries, fulfill your requests and improve your experience; for marketing, advertising and promotional purposes; for reporting and analytics; to improve the effectiveness of our services, conduct research and analysis, or for other internal operations purposes; to detect, prevent or investigate potential security breaches, fraudulent transactions and monitor against theft.

Sale and Targeted Advertising.  As described above in the "How We Share Your Information" section, we may share the following categories of Personal Data with third parties who are considered "third parties" as defined under State Privacy Laws. In the 12 months prior to the date of this Privacy Policy, we shared your Personal Data with third parties for purposes of “targeted advertising,” which may constitute a "sale" of Personal Data under State Privacy Laws, and may continue to share the following categories of Personal Data for “targeted advertising”:

Identifiers: such as online identifiers, IP address;

Commercial information: such as products or services purchased,obtained or considered, other purchasing or consuming histories or tendencies;

Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information; and

Inferences drawn from Personal Data: such as consumer preferences, characteristics, predispositions, and behavior.

The categories of third parties to which we may share the above-described categories of Personal Data include Online Advertising Networks, Marketing Companies, and Social Media Companies.

Opting Out of Sale and Targeted Advertising. You may stop our disclosure of your Personal Data to these entities for purposes of targeted advertising by opting-out of the sale of your Personal Data.You can do so by submitting an opt-out request by clicking the “Do Not Sell or Share My Personal Information” link in the footer or by contacting us at customer.experience@thehutgroup.com.

Opt-out Preference Signal.You may opt out of targeted advertising and the sale of your Personal Data at a browser level. Browser level opt outs are based on your unique browser and device. In addition to manually opting out at a browser level through clicking on the "Do Not Sell or Share My Personal Information" link in the footer, we also have processes in place to recognize opt-out preference signals you set on your browser or device and honor those signals when you visit our website as a request to opt out of targeted advertising and the sale of your Personal Data. To enable an opt-out preference signal, you must use a platform or internet browser with technology to set and communicate your preferred privacy setting.

Consumer Rights. Depending on your State of residence, you may have certain rights regarding your Personal Data, including:

Right to Know and Access. You may have the right to know and access what Personal Data we have collected about you, including the categories of sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, the categories of Personal Data disclosed to third parties, and the specific pieces of Personal Data we have collected about you (“Access Report”).

Right to Data Portability. You may have the right to request your Access Report be provided in a portable, readily usable format.

Right to Delete. You may have the right to request we delete Personal Data that we have collected from or about you, subject to certain exceptions.

Right to Correct. You may have the right to request we correct inaccuracies in the Personal Data we maintain about you, subject to certain exceptions.

Right to Opt-Out. You may have the right to opt out of the use and disclosure of your Personal Data for purposes of targeted advertising and sale.

Right to Appeal. You may have the right to appeal our refusal to act or a decision we made in relation to your request.

Exercising Consumer Rights. You or your authorized agent may exercise your Consumer Rights by submitting a request using one of the following designated methods:

Email us at customer.experience@thehutgroup.com and indicate which Consumer Right(s) you wish to exercise.

To submit a request to opt-out of targeted advertising of the sale of your Personal Data, click the“Do Not Sell or Share My Personal Information” link in the footer.

For requests to opt out of the use of your Personal Data for purposes of targeted advertising and sale we will comply within 15 business days after receipt of your request.

Requests By Authorized Agents.You may designate an agent to submit requests on your behalf. If you would like to designate an agent to act on your behalf, your agent must provide us your Personal Data and provide signed documentation demonstrating that you authorized the agent to submit a request on your behalf.

No7 Loyalty Program. If you enroll and participate in the No7 Loyalty Program, the following information about how we collect,use and disclose your Personal Data applies.

The categories of Personal Data collected from participants of the No7 Loyalty Program include those listed under the “Processing” section above and the categories of Personal Data sold or processed for targeted advertising include those listed above under the “Sale and Targeted Advertising” section.

The categories of third parties that may receive the categories of Personal Data listed above under “Sale and Targeted Advertising” include Online Advertising Networks, Marketing Companies, and Social Media Companies.

If you request deletion of your Personal Data and are a No7 Loyalty Program member, your loyalty profile may be deleted. We use your loyalty profile to provide loyalty program benefits to you as a loyalty member. Without a loyalty profile, you would lose rewards and other benefits such as sales prices and personalized offers.

How To Contact Us:

If you have questions or concerns about our Privacy Policy, you may contact us by email at customer.experience@thehutgroup.com. Alternatively, you may contact us by mail at: Customer Services, Meridian House,Gadbrook Park, Cheshire, CW9 7RA, United Kingdom.

Live Chat Monitoring Feature:

As part of our move to Ring Central, we have implemented a feature that allows us to view the content being typed by customers in real time before they click send. This feature is designed to assist with the smooth handling of longer or more complex messages and improve response times. We ensure that this information is used solely to enhance customer support and is not stored or shared for any other purpose.

Transparency and Privacy:

We are committed to maintaining your privacy and ensuring that your personal data is protected. This real-time typing visibility is part of our efforts to provide better service and is in line with standard practices adopted by many other leading chat providers. Rest assured, no information is processed or used inappropriately, and we take all necessary precautions to ensure your data remains secure. We collect customers' email addresses at the start of live chat to send them transcripts of the conversation.

Last Updated: 11/03/2025