1. About Us & Privacy Commitment
Your privacy is fundamentally important to clossie. This Privacy Policy outlines how clossie collects, uses, and processes your personal data when you visit our website, use our mobile applications, or purchase our products.
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Age Restriction: Our services are neither aimed at nor intended for children. If you are under the age of 18, you must inform your parent or guardian of this notice and obtain their consent before providing any personal information.
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Data Controller: clossie (referred to as "clossie", "we", "us", or "our" in this notice) is the primary data controller responsible for your personal data.
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Data Protection Officer (DPO): We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions, including requests to exercise your legal rights (such as data access or deletion), please contact our DPO.
2. The Data We Collect
Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you, grouped as follows:
2.1 Categories of Data Collected
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Identity Data: Full name, username or similar identifier, and date of birth (to verify age requirements).
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Contact Data: Billing address, delivery address, email address, and telephone numbers.
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Financial Data: Payment card details and bank account information (processed securely via third-party providers).
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Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
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Technical Data: Internet protocol (IP) address, login data, browser type/version, time zone setting and location, operating system, and platform used to access our website.
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Profile & Usage Data: Your password, purchase history, interests, preferences, and feedback, as well as information on how you interact with our website.
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Marketing Data: Your preferences in receiving marketing from us and your communication preferences.
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Customs & Compliance Data: For international shipments, we may process information required for customs clearance, including tax identification numbers where legally mandated by local authorities.
3. Failure to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you (such as these Terms and Conditions), and you fail to provide that data when requested, we may not be able to perform the contract we are trying to enter into with you.
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Consequences of Non-Provision: If you do not provide the necessary information (e.g., delivery address, payment details, or customs identification where required), we may be unable to fulfill your order or provide specific services.
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Order Cancellation: In such cases, clossie reserves the right to cancel the product or service. However, we will notify you at the time if this is the case.
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Legal Compliance: Certain data collection is mandated by UK and international law (e.g., for tax reporting or anti-fraud measures). Failure to provide this data may lead to the permanent suspension of your account or the cancellation of pending transactions.
4. How We Collect Your Data
We use various methods to collect data from and about you, including:
4.1 Direct Interactions
You may provide us with your Identity, Contact, and Financial Data by filling in forms or by corresponding with us via post, phone, email, or live chat. This includes personal data you provide when you:
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Inquire about or purchase our products/services.
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Create and manage an account on clossie.com.
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Subscribe to our newsletters or marketing communications.
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Enter a competition, promotion, raffle, or survey.
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Provide feedback or contact our customer support team.
4.2 Automated Technologies or Interactions
As you interact with our website or mobile applications, we will automatically collect Technical Data about your device and browsing patterns. We collect this data using:
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Cookies & Server Logs: To enhance site functionality and remember your preferences.
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Tracking Pixels: To measure the effectiveness of our marketing campaigns.
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Similar Technologies: To analyze how users move through our site. (For more information, please refer to our Cookie Policy.)
4.3 Third Parties or Publicly Available Sources
We may receive personal data about you from various third parties, including:
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Analytics Providers: (e.g., Google Analytics) for Technical and Usage Data.
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Payment & Technical Services: (e.g., Stripe) for Transaction and Financial Data.
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Advertising Networks: (e.g., Meta, TikTok) for Profile Data to show relevant advertisements.
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Social Media Platforms: If you link your account (e.g., via Google or Apple login), we may receive your Identity and Contact Data from those providers.
5. How We Use Your Data
We will only process your personal data when the law allows us to do so. Under the UK GDPR, we rely on the following legal bases:
5.1 Performance of a Contract
This is the primary basis for processing your data. It is necessary to perform the contract we have entered into with you (e.g., processing your payment, managing delivery, and providing customer support). Without this, we cannot fulfill your order.
5.2 Legitimate Interests
This is the primary basis for processing your data. It is necessary to perform the contract we have entered into with you (e.g., processing your payment, managing delivery, and providing customer support). Without this, we cannot fulfill your order.
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Improving our website performance and user experience.
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Preventing fraud and enhancing the security of our network.
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Analyzing customer trends to optimize our product offerings.
5.3 Compliance with Legal Obligations
We process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, such as tax reporting, anti-money laundering (AML) laws, and consumer protection regulations.
5.4 Consent
Generally, we do not rely on consent as a sole legal basis for processing your personal data, except in relation to sending third-party direct marketing communications to you via email or text. You have the right to withdraw your consent to marketing at any time by contacting us or using the "unsubscribe" link in our emails.
6. Purposes and Lawful Bases for processing your Personal Data
We have set out below a description of the ways we process your personal data and the legal bases we rely on.
Purpose / Activity | Type of Data | Lawful Basis for Processing |
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New Customer Registration | Identity, Contact | Performance of a contract with you. |
Order Processing & Delivery
(Payment management, shipping, debt recovery) | Identity, Contact, Financial, Transaction, Marketing | (a) Performance of a contract.(b) Legitimate interests (to recover debts due to us). |
Relationship Management
(Terms update alerts, Review requests, Surveys) | Identity, Contact, Profile, Marketing | (a) Performance of a contract.(b) Legal obligation.(c) Legitimate interests (to keep records updated). |
Promotions & Competitions
(Raffles, prize draws, or surveys) | Identity, Contact, Profile, Usage, Marketing | (a) Performance of a contract.(b) Legitimate interests (to study how customers use products). |
Business Administration & Security
(Troubleshooting, data analysis, system maintenance) | Identity, Contact, Technical | (a) Legitimate interests (running our business, IT services, network security, fraud prevention).(b) Legal obligation. |
Marketing & Ad Effectiveness
(Delivering relevant content and measuring ad performance) | Identity, Contact, Profile, Usage, Marketing, Technical | Legitimate interests (to grow our business and inform our marketing strategy). |
Data Analytics (Improving website, products, and customer experience) | Technical, Usage | Legitimate interests (to define customer types and keep our website updated). |
Personalized Recommendations
(Suggesting products of interest) | Identity, Contact, Technical, Usage, Profile | Legitimate interests (to develop our products and grow our business). |
7. Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
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Compatibility Check: If we need to process your personal data for a purpose unrelated to the original collection, we will notify you and explain the legal basis which allows us to do so.
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Explanation Requests: If you wish to receive an explanation as to how processing for a new purpose is compatible with the original purpose, please contact our Data Protection Officer (DPO).
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Processing Without Consent: Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law (e.g., for criminal investigations, regulatory audits, or tax compliance).
8. Marketing and Exercising Your Right to Opt-Out
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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Marketing Communications: You may receive marketing communications from clossie if you have requested information from us, purchased goods, or registered for a promotion and, in each case, you have opted in to receive such communications. We will only send these via your preferred channels.
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Personalized Marketing: To ensure our communications are relevant, we may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This means you may not receive every type of communication we send, as we aim to tailor material based on your previous spending behavior.
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Opting Out: You can ask us to stop sending you marketing messages at any time by:
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Following the "unsubscribe" or opt-out links on any marketing message sent to you.
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Contacting our support team or DPO directly through our website.
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No Impact on Service: Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, or other service-related transactions.
9. No Third-Party Marketing
We value your trust. clossie does not share, sell, or rent your personal data with any company outside of clossie for their own marketing purposes. Should we ever wish to do so in the future, we will obtain your express opt-in consent before any such sharing takes place.
10. Cookies
Cookies are small text files that are stored within your internet browser by the websites that you visit. Similar to many other websites, clossie uses cookies and similar technologies to understand more about your visit and to enhance your overall experience.
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How We Use Cookies: We use cookies to collect information and store your online preferences. These small pieces of data sent by our web server to your browser allow us to uniquely identify your browser on each page, ensuring a seamless shopping experience.
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Website Analytics: We utilize tools such as Google Analytics to study and improve how customers interact with our website. These analytics cookies help us understand:
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The number of visitors to clossie.com.
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How frequently users visit our site and specific webpages.
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User journey patterns to optimize site navigation.
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Privacy of Analytics: While analytics cookies gather specific information about the pages you visit, they are anonymized and cannot be used to identify personal details such as your name or home address.
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Managing Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies, some parts of our website or mobile applications may become inaccessible or fail to function properly (e.g., items in your shopping cart may not be saved).
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Notification: You will be notified of our cookie usage via a cookie banner when you first visit our website. For detailed information about the specific cookies we use, please refer to our Cookie Notice.
11. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes described in this Privacy Policy.Data Security Commitment: We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes; they are only permitted to process your personal data for specified purposes and in accordance with our strict instructions.
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Service Providers: Third-party providers who provide IT, system administration, and logistics services (e.g., cloud hosting, payment gateways like Stripe, and international couriers).
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Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
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Government Authorities: HM Revenue & Customs (HMRC), regulators, and other authorities based in the United Kingdom or other relevant jurisdictions who require reporting of processing activities in certain circumstances.
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Business Transfers: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Policy.
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Legal & Fraud Investigations: Third parties making inquiries concerned with:
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(a) The prevention or detection of crime.
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(b) The prosecution or apprehension of offenders.
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(c) Protecting the vital interests of a person.
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Note: Requests from police or external fraud investigators (such as card providers) will only be met upon the submission of a formal Data Processing Agreement (DPA) or legal warrant.
12. International Transfers
In some cases, the third parties we use to process personal data on our behalf are based outside the UK and the EEA (European Economic Area). Therefore, their processing of your personal data will involve a transfer of data outside these regions.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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Adequacy Decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant authorities (such as the UK Government or the European Commission).
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Standard Contractual Clauses (SCCs): Where we use certain service providers, we may use specific contracts approved for use in the UK (the International Data Transfer Agreement or Addendum) and the EEA, which give personal data the same protection it has within those regions.
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Specific Safeguards: If you would like further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA, please contact our Data Protection Officer.
13. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.
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Access Control: We limit access to your personal data to those employees, agents, contractors, and other third parties who have a strictly defined business need to know. They will only process your personal data based on our specific instructions and are subject to a formal duty of confidentiality.
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Technical Safeguards: We employ industry-standard encryption and security protocols to ensure the integrity and safety of your data during transmission and storage.
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Breach Procedures: We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
14. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements and for the establishment or defense of legal claims.
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Determining Retention Periods: To determine the appropriate retention period for personal data, we consider:
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The amount, nature, and sensitivity of the personal data.
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The potential risk of harm from unauthorized use or disclosure.
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The purposes for which we process your personal data and whether we can achieve those purposes through other means.
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Applicable legal, tax, and regulatory requirements.
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Statutory Retention: By law, for tax and accounting purposes, we are required to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers.
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Anonymization: In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
15. Your Data Protection Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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Your Right of Access: You have the right to ask us for copies of your personal information.
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Your Right to Rectification: You have the right to ask us to rectify personal information you think is inaccurate or complete information you think is incomplete.
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Your Right to Erasure: You have the right to ask us to erase your personal information in certain circumstances (also known as the "right to be forgotten").
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Your Right to Restriction of Processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
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Your Right to Object to Processing: You have the right to object to the processing of your personal information where we are relying on a legitimate interest.
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Your Right to Data Portability: You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.
15.1 Exercising Your Rights
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No Fee Usually Required: You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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Identity Verification: We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
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Response Time: We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
15.2 Complaints to the Regulator
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.Note: We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact our DPO in the first instance.
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ICO Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
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Helpline: 0303 123 1113 | Website: www.ico.org.uk
16. Changes to This Notice and Your Duty to Inform Us of Changes
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Periodic Updates: We may update this Privacy Policy from time to time. Any future changes will be posted on this page. If we make significant changes, we will notify you through our website or via email where required by law.
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Accuracy of Data: It is crucial that the personal data we hold about you is accurate and current. Please keep us informed if your personal data (such as your delivery address or email) changes during your relationship with us.
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Updating Your Information: You can easily update your personal details through your clossie account settings or by contacting our support team directly.
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Review: We encourage you to periodically check this site to stay informed about how we collect, use, and share your information.
17. Third-Party Links
Our website may include links to third-party websites, plug-ins, and applications (such as social media platforms). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
18. Automated Decision-Making
We may use automated systems to help us prevent fraudulent transactions. If a transaction is flagged as high-risk by our payment processors (e.g., Stripe), we may automatically decline the order. If you believe this has happened in error, you have the right to request a human review of the decision by contacting us.
Last updated: February 22, 2026.