Privacy Policy

• All about you: We only use your data to improve your Dusk experience
• Keep it simple: We’ll talk to you straight—no stress, no worries
• No junk: You choose where and how we speak to you
• Super safe: Your data is protected 24/7/365

We take our customers privacy and security very seriously and we are 100% committed to protecting it so that you can shop without a worry.

We are committed to protecting your privacy. It is important that you understand how we look after your personal data and how we make sure that we meet our legal obligations to you under the data protection rules and regulations in the relevant territories (including associated guidance) (the "Data Protection Laws"). This privacy policy outlines how Dusk, a sub-brand of Roman Originals PLC will collect, use, store and share your personal data.

If you have any questions in relation to this policy, or as to how your personal data is processed by us in general, please contact our team by letter addressed to:

Alternatively, you may email [email protected].

This policy sets out how information about you is collected and used by Roman Originals PLC strictly in accordance with all current data protection laws, including the EU2016/679 General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

This policy applies to any personal data that we collect about you when you:

• Visit our one of our websites
• Purchase products from us
• Visit one of our stores
• Contact us (by telephone, email, post or submission of a contact form on our websites).

Where we use the terms "we", "us", "our", "Dusk", "Roman", and "Roman Originals", we are specifically referring to Roman Originals PLC.

For the purpose of the EU2016/679 General Data Protection Regulation (GDPR), the data controller is: Roman Originals, Unit 1 Vantage Point, 5 Wingfoot Close, Birmingham B24 9JH, United Kingdom.

The relevant controller above is responsible for your personal data. This policy applies to Roman Originals PLC as a whole. This central policy provides information to you about the basis on which Roman Originals PLC as a whole collects, uses, stores and shares your information. We will use your personal data fairly, lawfully and in a transparent manner and in accordance with the Data Protection Laws.

We may send you marketing messages by email, SMS, social media and post about ourselves and our products where you have not unsubscribed and where you have purchased similar products or otherwise signed up or consented to receive marketing messages from a brand or entity.

You have the right to withdraw your consent to processing of this nature at any time by contacting our customer care team. You can also tell us you no longer wish to receive marketing information from us by logging in to your online account.

If you have an account with us, make a purchase online with us, enter a competition or respond to a survey with us, we will collect your name and contact details (including address, telephone number, order details, and billing information where products are being purchased).

We also collect details of your interactions with us through our customer contact centres, in store, online or via our apps. For example, when you telephone one of our contact centres, we collect notes of our conversations with you and details of your query. From time to time we may also record your calls for training and monitoring purposes.

We also collect information about the purchases that you make, your saved items, shopping preferences, payment information and any complaints or comments that you make. We also collect CCTV images in all of our stores.

Each time you visit one of our websites, we will also automatically collect information and personal data about your computer for system administration purposes including (where available) your IP address, operating system and browser type. We do this to help us analyse how users interact with the websites (including behaviour patterns and the tracking of visits across multiple devices) to establish more about our website users and to assist us in managing your account and improving your online experience. We also collect information about your activities on our websites, for example what device you are using and what products you are looking at.

Please see our cookies section for further information about what information may be automatically collected when you visit our websites.

Please note that, from time to time, we will combine personal data that we receive from other sources with personal data you give to us and personal data we collect about you.

We collect some of your information directly from you; either during your visits to our websites and stores or through your communications with us and the information that you give to us. We may also obtain some information from third parties, including retail analytics companies, consumer insight companies, credit reference agencies and publicly available sources to assist us with understanding customer demographics and shopper behaviours, or where we merge with or otherwise acquire another business.

You may share personal data about yourself with us by:

• Filling in forms on our websites, including when you purchase products online, submit queries to us, create an account on one of our websites and/or sign up to receive promotional material and newsletters
• Responding to a survey or entering a competition with us
• Giving us information about yourself in any communication with us, either by telephone, e-mail, post or otherwise, either in connection with your account, purchases, or to report a complaint or issue.

You are not obliged to provide your personal data to us. However, if you do not provide your personal data to us, we may not be able to fulfil your order, respond to your queries or provide other services to you.

We collect personal data about you:

• When you visit our websites, including details of your visits that include but are not limited to, Internet Protocol (IP) address (used to connect your computer to the internet), MAC addresses, traffic data, location data, your login information, time-zone setting, browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access—for more information please see our cookies section
• When you link your Twitter, Instagram or Facebook accounts with us to enable you to log onto our websites simply and securely without having to create a new account
• When you visit one of our stores, including CCTV images
• When you contact us in relation to our products or services, or to raise a complaint, query or issue. In particular, calls to our contact centres may be recorded for training any monitoring purposes from time to time.

We will receive personal data about you from third parties:

• In connection with any mergers or acquisitions where we obtain your information from another company
• When we work with retail analytics companies, consumer insight companies, credit reference agencies and through our use of information from publicly-available sources.

The main purpose for which we use your information is to provide you with the products that you purchase from us and to send you offers and promotions that you might be interested in.

In particular, we use your information:

• To provide you with the products that you have purchased from us and any receipts of purchase, including to deliver your products, and to send you order status updates
• To take payments for the products that you have purchased and to give refunds or exchanges
• To provide customer care and support to you
• To develop and improve our products and services
• To develop and improve our websites and set default options for you (such as language and currency) and to ensure that content is presented in the most effective manner
• To provide you with information that you request from us or which we feel may interest you; we may send you marketing information by email, SMS or post—this can include information about new products and offers that you may find interesting
• To research our customer preferences and trending products
• To run surveys and competitions
• To notify you about changes to our products
• As part of our efforts to keep our stores safe and secure (for example through the use of CCTV in our stores)
• To prevent and detect fraud or crime (for example, through the use of CCTV in our stores).

As a corporate group, there are certain laws we need to comply with. In particular, we will need to process your personal information to verify your identity and for fraud and crime prevention purposes.

Failure to provide the requisite personal information on sign-up or as you use our websites may mean we cannot provide our products to you as allowing you to purchase our products means we may be in breach of our legal obligations.

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.

When you enter into a transaction with us or one of our brands, a contract between you and the relevant brand will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order and receive products from us) we will need to collect and process your personal information.

Failure to provide the requisite personal information when signing-up to an account, placing an order, entering payment information or objecting to this type of processing, or exercising your deletion rights, will mean we cannot provide our products to you.

We use your personal data as set out in this privacy policy for the legitimate interests of our business to enable us to:

• Provide you with products as requested by you
• Carry out research to understand our customers and how they purchase and use our products
• Develop and improve our products.

We are required to carry out a balancing test of our legitimate business interests in using your personal data (outlined above) against your interests and rights under the Data Protection Laws and regulations in the relevant territory.

As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.

We have a legitimate interest in processing your information as:

• We both benefit from the effective management of your account(s) (where applicable)
• We both benefit from the effective management, operation and administration of our websites
• We both benefit from the provision of products, services and support and from improvements to our services
• We both benefit from updates to our websites
• We both benefit from the ability to enforce or apply rights under any contract between us
• We are required to ensure the health and safety of our customers and the security of our stored data and have a legitimate interest in ensuring any processes relating to the same are effective, and that fraud and other crimes are prevented and detected
• We would be unable to provide our products and services without processing your information
• We have a legitimate interest in processing your information in connection with any mergers, acquisitions or reorganisation of our business, in which case some of your information may be shared with a prospective buyer or otherwise but only so far as is strictly necessary for the purposes of such sale or administration.

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary to achieve the purpose outlined in this privacy policy.

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy.

As set out above, we will send you marketing communications where you have not told us that you wish to unsubscribe and where you have purchased similar products and/or services from the same brand or legal entity (as set out in the table above).

You have the right to withdraw your consent to processing of this nature at any time by contacting our customer care team using the details at the start of this privacy policy.

We do not, and will not, sell any of your information to any third party, including your name, address, email address or credit card information. However, we do share your information with a number of select third parties to enable us to provide our products and services to you, to send marketing information and to improve our business operations as set out below:

• Companies that do things to get your purchases to you, such as payment service providers, warehouses, order packers and delivery companies
• Our trusted service providers, such as marketing agencies, advertising partners, website hosts and other third parties who provide services to help us to tailor our marketing to you
• Credit reference agencies, law enforcement and fraud prevention agencies
• Companies and social media sites approved by you, including companies such as Facebook and Google
• We will provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

We will only share your information with third-party suppliers where it is necessary for them to provide us with the services we need.

We may disclose your information to other companies in connection with any merger, acquisition, insolvency situation or otherwise, in which case we will only disclose your information so far as is necessary.

We may also need to disclose personal data to third-parties to comply with a legal or regulatory obligation, or if necessary, for legal proceedings.

We carry out some profiling of you for the purposes of improving and developing our products and services and to help us to tailor our marketing to you.

The impact of any automated decision is to ensure you experience the best service possible.

We use information that we learn about you such as your gender, preferences, hobbies, interests and purchase history to make sure that the marketing you receive from us and the way our websites are displayed are appropriate and tailored to you.

The information which we collect about you may be transferred outside the European Economic Area. In the event of such transfer, we will ensure the adequate standard of security is in place, for example by incorporating the European Commission approved clauses into our agreements with such third parties to ensure the security of your personal data.

A copy of the European Commission approved model clauses is available here.

We will only keep your information for as long as is necessary to carry out the purposes we collected it for, as set out in this privacy policy (unless a longer retention period is required by the applicable law).

We typically keep your personal data for 6 years from the purchase in order to enable us to deal with any issues or concerns you may have about the products or services you have received, and to allow us to bring or defend legal proceedings.

In some circumstances, some of your data will be deleted in much shorter timescales, for example:

• Cookies are deleted in accordance with our cookies policy
• CCTV images are kept for 60 days
• Marketing consents will be refreshed/deleted after 6 years, however, our aim is only to market to you for as long as we believe you want to continue hearing from us based on how you interact with us.

If reasonably necessary, or if required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions, we will also keep hold of some of your information, even it is no longer needed to provide the services to you.

Transmission of information via the internet is not and cannot be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; 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.

We may also collect non-personally identifiable information (that is, information that does not specifically identify you), for the purposes of aggregates and statistics.

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.

In some instances, we may be unable to carry out your request, in which case we will contact you to explain why.

We always give you the choice of whether or not you wish to receive marketing communications from us.

By contacting us at [email protected], you can tell us that you do not wish to receive marketing communications from us and we will update your records. You can also click on the 'unsubscribe' link in any promotional emails.

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request made by you, or would otherwise like to make a complaint, please contact our customer contact centre in the first instance using the details at the start of this privacy policy, so that they can do their best to sort out the problem.

You can also contact the Information Commissioner's Office at: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF; www.ico.org.uk.

Our websites may, from time to time, contain links to and from the websites of third-parties. 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 these policies, or for your use of those websites.

To make full use of the online shopping and personalised features on our websites, your computer, tablet or mobile phone will need to accept cookies. This is because the shopping basket needs to use cookies to function and because we can only provide you with certain personalised features of this website by using them.

Our cookies don't store sensitive information such as your name, address or payment details. They do hold a 'key' that allows us to associate information with your computer when you are shopping with us or when you come back to visit us.

We split the cookies that we use into 4 different types.

These cookies are essential for you to use the shopping features of our websites; they enable you to add items to your shopping basket, to checkout and to use the 'My Account' section of the site.

These cookies are not used to advertise products or services to you.

These cookies collect information about how you use our websites, for instance the pages you visit most often or any error messages you may see on the pages you visit. These cookies don’t collect your personal information. The information we collect is used to improve how our website works.

These cookies are not used to advertise products or services to you.

These cookies allow our websites to remember items such as your username, the region you are shopping in and more personal features like product recommendations. The information these cookies collect is anonymous and cannot be used to track your activity on other websites.

These cookies are not used to advertise products or services to you.

These cookies are used to advertise products and services to you.

These cookies are used to make our advertising more relevant to you and your interests. We also use them to limit the number of times you see an advertisement and to measure the effectiveness of our advertising campaigns.

These cookies may be placed on your computer, tablet or mobile phone by us or by a third-party with our consent.

When these cookies are placed by us, they may be used only by us. When these cookies are placed by a third party with our consent, they may be used by that third party and other parties to make adverts more relevant to you and your interests. Examples of this include various social networks such as Facebook, Twitter and Pinterest. These social network sites may place cookies on your device and use these to target advertising to you on their own or other websites.

When you use our websites, you may notice some cookies that aren't directly from Roman and Dusk.

For example, pages that contain content from websites like YouTube or Facebook may send cookies from these websites when you view that content. We don't control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

If cookies are not enabled on your computer, tablet or mobile then you will not be able to shop on our websites; you will be limited to browsing our products and the content on the site.

There are a number of websites that can help you understand more about cookies and how to manage them.

Websites that explain more details about cookies, how they work and how you can manage them include:

• www.allaboutcookies.org
• www.aboutcookies.org.