This website, https://www.withnothingunderneath.com// (Website) is owned and operated by With Nothing Underneath Ltd (We). With Nothing Underneath is a company registered in England and Wales under registration number 1127856 with registered address at 1 Knowle Road, Devon, TQ8 8EQ. Our correspondence and trading address is 47 Elizabeth Street, SW1W 9PP. Our VAT number is 289 7480 35. When we say, 'With Nothing Underneath’ or 'WNU’ we mean the website (withnothingunderneath.com) operated by or on behalf of With Nothing Underneath Ltd.
What are cookies and how do we use them?
Types of cookies
How to reject or opt out of receiving cookies
How to ask questions or contact us about this policy
- WHAT ARE COOKIES AND HOW DO WE USE THEM?
Cookies are small text files that can be used by websites to make a user's experience more efficient.
1.2 The cookies we and our business partners use on our online services can be grouped into the following categories:
1.2.1 Essential cookies: Some of the cookies on our online services are essential for us to be able to provide you with a service you have requested. An example of this would be a cookie that enables you to log into your account on our Website or use a shopping cart. The ability to use our Website may be inhibited without these cookies.
1.2.2 Functionality cookies: These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
1.2.3 Analytical or Performance cookies: We use these cookies to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This allows us to continuously improve our Website and your experience for example, by ensuring that users are finding what they are looking for easily.
1.2.4 Targeting cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- TYPES OF COOKIES
The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission. This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
- (a) FIRST PARTY COOKIES
A first-party cookie is a cookie set by the domain name that appears in the browser address bar (i.e. our Website), for example:
Facebook Targeting Cookie: This cookie helps us track the effectiveness of our Facebook advertising campaigns.
More information about this cookie can be found here: www.facebook.com/about/basics/facebook-and-advertising/from-businesses-and-organizations/
- (b) THIRD PARTY COOKIES
A third-party cookie is a cookie set by a domain name that is not the domain name that appears in the browser address bar. These third party cookies are likely to be analytical or performance or targeting cookies, for example:
Google Analytics Cookie: Google Analytics is Google's analytics tool that helps website and app owners to understand how their visitors engage with their properties. It may use a set of cookies to collect information and report website usage statistics without personally identifying individual visitors to Google.
More information about this cookie can be found here: www.google.com/intl/en/policies/privacy/
DoubleClick Targeting Cookie: Advertisements are received from Google Double Click servers to your browser along with a cookie to anonymously identify you as you visit websites which serve advertising from Google Double Click servers.
More information about this cookie can be found here: www.google.com/settings/ads/onweb/
Rakuten Targeting Cookie: Targeting cookies used by Rakuten Advertising Affiliate Network. Cookie ID: rmuid
More information about this cookie can be found here: https://go.rakutenadvertising.com/hubfs/Services-Privacy-Policy-English.pdf
- HOW TO REJECT OR OPT OUT OF RECEIVING COOKIES.
You can at any time change or withdraw your consent by emailing us at firstname.lastname@example.org
- HOW TO ASK QUESTIONS OR CONTACT US ABOUT THIS POLICY.
Your privacy is extremely important to us. If you have any questions or suggestions about data or privacy, please do not hesitate to contact us at email@example.com
- HOW AND WHEN WE COLLECT PERSONAL INFORMATION FROM OR ABOUT YOU?
2.1 We collect and process personal information when you:
2.1.1 visit our Website (including when registering an account, or filling in forms on our Website, such as when you sign up for newsletters or enter a competition);
2.1.2 purchase any products from our Website or subscribe to any of our services;
2.1.3 attend any of our events we may organise or host from time to time;
2.1.4 contact us or request information from us in any other way;
2.1.5 participate in our competitions, customer satisfaction surveys or other market research;
2.1.6 communicate with us via social networking websites, third party apps or similar technologies; or
2.1.7 send us a CV, whether speculatively or in response to a job advertisement.
2.2 The information we collect about you may be directly identifiable or indirectly identifiable personal information. Identifiable information refers to something directly identifiable to you, for example, an email address or name. Indirectly identifiable information is information we may use which tracks your actions on or off our Website but does not include directly identifiable information. We may, as an example, collect details about your visits to our Website, including traffic data, location data and other communication data, used for analytics to improve your experience with our Website. We use this data for reporting and for monitoring the effectiveness of advertising or marketing campaigns.
2.3 We will indicate where any personal information we have requested is mandatory or optional. We will also explain the consequences should you decided not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain service or product.
- WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect and process the following personal information about you:
3.1 We may collect and process the following personal information about you which you provide to us:
3.1.1 contact details (such as your name, address, email address and telephone number);
3.1.2 demographic information (such as age and/or other information that may identify you as an individual);
3.1.3 password and other authentication information;
3.1.4 responses to any customer satisfaction surveys or market research (unless these are provided anonymously);
3.1.5 financial and credit card information;
3.1.6 your marketing preferences; and
3.1.7 employment and background data such as your academic and work history, qualifications, skills, projects and research that you are involved in (if you have sent us a CV or responded to a job advertisement).
3.2 We will collect and store your purchase history with us.
3.3 If you contact us with a complaint or query, we may keep a record of any phone number used to contact us, as well as the correspondence and the period of time it took for us to deal with a query or any request you had. We may also record your levels of satisfaction with the services we have provided.
3.4 At some of our events, we may photograph, record or film onsite activities. In which case, you may be filmed, photographed or recorded as part of any such activities.
- information about your device, operating system and IP address;
- your login information;
- browser type and version; or
- information about your visit, including URL, clickstream (i.e. your journey to, through and from our site), length of visits to certain pages, and page interaction information.
- PURPOSES FOR PROCESSING YOUR PERSONAL INFORMATION
4.1 We may process your personal information for the following purposes:
4.1.1 to provide you with the information, products and services you have requested and send you marketing and advertising materials;
4.1.2 to authenticate your access to our Website and other digital properties;
4.1.3 for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
4.1.4 to monitor your use of our Website and other digital properties to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
4.1.5 to provide user support and ensure we provide a good level of customer service;
4.1.6 to tailor any marketing or advertising so that it is more relevant to you;
4.1.7 to notify you of any changes to our services;
4.1.8 to conduct marketing analysis to allow us to assess trends and the effectiveness of our advertising and marketing campaigns (including using your personal information to evaluate, analyse or predict certain personal aspects relating to you, such as your preferences, economic situation, interests, and/or location);
4.1.9 if you are filmed, photographed or recorded as part of any onsite activities at one of our events, your image or likeness may be used in promotional material, sponsor, exhibitor and media partner coverage in print, online and on broadcast television;
4.1.10 to run and administer our competitions;
4.1.11 for recruitment purposes;
4.1.12 for security and fraud prevention;
4.1.13 to ensure that our Website and digital properties are safe and secure; and
4.1.14 to comply with applicable laws and regulations.
4.2 We may also match personal information that you provide to us directly with other information about you obtained from or held by third party sources (such as social media platforms). This may include your contact details, demographic data, your social media interactions, preferences, interests, geographic location and age or age range. We may use this personal information to tailor and show advertisements more relevant to you either on our Website or on third party websites (including social media platforms).
- LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
5.1.1 Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the "unsubscribe" link at the bottom of any marketing email we send you or by contacting us at firstname.lastname@example.org
5.1.2 Our legitimate business interests: Where it is necessary for us to understand our users, promote our services and operate effectively as a digital platform provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this legal basis when we conduct certain market analysis to understand our users in sufficient detail, so we can create new services and improve the profile of our brand.
5.1.3 Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.
5.1.4 Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
- WHERE WE STORE YOUR PERSONAL INFORMATION
6.1 The personal information that we collect may be transferred to, and stored at, a destination outside the UK or the European Economic Area (the EEA), including countries, which have less strict, or no data protection laws, when compared to those in UK and Europe.
6.2 Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as the EU "Standard Contractual Clauses" and the EU-US "Privacy Shield") to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
- HOW WE KEEP YOUR PERSONAL INFORMATION
7.1 We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. For example, if you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing and tax purposes. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim. If you have submitted a CV to us we keep CVs from successful applicants for 6 months, whereas unsuccessful applicants' CVs are deleted after the position they applied for has been filled.
7.2 Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. You can do so by emailing us at email@example.com. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
Our Website and other digital properties are not intended for, and should not be used by, children under the age of 13. We do not knowingly collect personal data from children under 13.
- SECURITY OF YOUR PERSONAL INFORMATION
9.1 Our Website currently uses high-level Secure Socket Layer (SSL) encryption. You can therefore rest assured that we take the security of your payment and personal details very seriously. We may vary this in the future if we feel you will benefit from greater security whilst using our Website.
9.2 You can tell whether a webpage is secure as 'https' will replace the 'http' at the front of the withnothingunderneath.com in your browser address window, also a small locked padlock will appear in the bottom bar of your browser window. Our Website and our servers have appropriate technical and organisational measures in place to protect against unauthorised or unlawful use of your personal information as well as the accidental loss, destruction or damage of your personal information whilst under our control. We conduct regular audits of data processing activities and security controls to ensure we have an appropriate level of security at all times.
9.3 We also ensure that personal information systematically destroyed, erased, or anonymised when it is no longer legally required to be retained or to fulfil the purpose(s) for which it was collected.
9.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information as described above, we cannot guarantee the security of your information transmitted during your use of our Website and other digital properties.
- DO WE SHARE YOUR PERSONAL INFORMATION WITH ANYONE ELSE?
10.1 We may share your data with any third parties which are our suppliers and service providers, who need your data in order to fulfil a service, such as reporting or taking payment for an order, on behalf of With Nothing underneath.
10.2 We may disclose your personal information to other third parties in the following limited cases:
10.2.1 for the purposes of research, evaluation, and analysis;
10.2.2 in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
10.2.3 if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers and visitors to our Website/ digital properties will be one of the transferred assets;
10.2.4 if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or
10.2.5 to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
10.3 Except as described above, if we give your data to any other third party who is not providing a service, for example, an advertiser who has paid for a competition on our Website, we will only share this data if we have been given consent by you to do so.
10.4 We may share your personal information within our group of companies (i.e. our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
10.5 We invite you to review the below privacy policies. These are suppliers and service providers that handle your personal information on behalf of With Nothing Underneath. While these companies are trusted by us to handle your personal information, it is important that you review them as well so that you are fully aware of how your data is processed. If you have any questions regarding this do not hesitate to contact us on firstname.lastname@example.org
10.5.1 Facebook: www.facebook.com/ads/about/ We serve ads to people on Facebook based on their user profiles on Facebook and Instagram, this might include what they like, dislike or things they have shown an interest in.
10.5.2 Google: policies.google.com/technologies/partner-sites. We use Google Analytics to track any orders through our Website by using an order number as the identifier. While this does not show a name or email, we can use that order number internally to analyse what country a customer was in when they purchased, or for example, what marketing campaign they clicked through before purchasing. This enables us to analyse how our various marketing campaigns are performing, and opportunities for launching new marketing campaigns in different areas. We only use this information internally to monitor performance and never share this with third parties. If you would like your details to be removed from this analysis please email email@example.com
10.5.3 Klaviyo: klaviyo.com/legal/privacy-notice. We use Klaviyo to send out email campaigns to email addresses that have been subscribed to receive newsletter campaigns from us. We track how often a particular email address will open or click through our campaigns, or purchasing behaviour of our database. This allows us to send out campaigns based on an email address' behaviour, so that we can be more targeted in our messaging. We also use this service to send out unique order-based offers, for example, sending a discount code for a product when a customer purchases a magazine.
10.5.4 PayPal: www.paypal.com/en/webapps/mpp/ua/privacy-full. PayPal is used to process payments on our Website
10.5.5 Social media: we use four other companies for scheduling and commenting on social media posts. Namely, these are Sprout Social, Buffer, Planoly and Later. These tools are only used for our scheduling and commenting on Facebook, Instagram and Twitter.
10.5.6 Under the legislation, California residents can choose to opt out of the “sale” of their personal information to third parties. Based on the CCPA definition, “sale” refers to data collection for the purpose of creating advertising and other communications. Mange your personal data here.
- REPORTING & ADVERTISING TOOLS
We, and the below service providers, share the indirectly identifiable data in order to enable various reporting or advertising tools. We do not share any directly identifiable information, such as a name or an email, for the performance of these tools.
11.1 Heatmap: this tool is used to analyse what our Website users' activity is on each webpage. We look at the webpage through 'heat maps', which shows where users click on a page. This allows us to optimise our Website, so that we can position our content in the most relevant place.
11.2 Google AdWords: we serve ads to people on Google based on their browsing behaviour, this might include what they like, dislike or things they have shown an interest in.
11.3 Facebook and Instagram ads: we serve ads to people on Facebook and Instagram based on their user profiles on Facebook and Instagram, this might include what they like, dislike or things they have shown an interest in.
11.4 Facebook: we run ads on Facebook and Instagram that use identifiers of our customers or users who have signed up to receive newsletters from us, we take the profile of these customers or newsletter subscribers and show ads to new users based on similarities between likes and dislikes of our customers or newsletter subscribers. We collect the data for Facebook ads through cookies on our Website and through order data collected when a customer purchases. If you would like to opt out from this you can opt out of cookies here, or email firstname.lastname@example.org and we will remove your details from our lists.
11.5 Google Analytics: we analyse our Website user data, i.e., how someone navigates our Website, to understand what areas of our Website or which marketing campaigns work best. This might include what country a user is in, whether they are a new visitor or returning user, which marketing campaign they came to our Website through. Google Analytics will associate the visitation information that it collects from With Nothing Underneath with Google information from accounts of signed-in users. This means we can track a user across devices if they are signed in to their Google accounts, however we cannot see which user has visited across different devices, so the data is not directly identifiable.
11.6 Klaviyo: we track overall clicks and opens for a newsletter. This means we can analyse how newsletters perform.
11.7 Shopify: we track article views with this tool, so that our staff can track the progress of each web page when they are editing. This tracks how many views each page has attained since being published.
- YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
12.2 We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights, please contact us using the contact details below.
12.3 You may also have the right to complain to a data protection authority such as the UK Information Commissioner's Office (https://ico.org.uk/) (or relevant authority in your country of residence) if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.
12.4 Our Website and other digital properties may, from time to time, contain links to and from third party websites and services such as our business partners and advertisers. If you follow a link to any of these websites and/or services, please note that they have their own privacy notices and we do not accept any responsibility or liability for them. Please check any such third party privacy notices before you submit any personal information to these websites or services.
12.5 Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.
- CHANGING YOUR PERSONAL INFORMATION AND OPT-IN OR OPT-OUT MARKETING PERMISSIONS
13.1 Personal information should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date. You can log in to your account to access and amend your details. If you are having any difficulties accessing these details or would like to change your marketing consent status, contact us at email@example.com .To manage and/or opt out of cookie tracking, you can do so here.
13.2 All our marketing emails also have unsubscribe links featured in the footer. Clicking this link may be the fastest way to stop receiving these communications.
We realise that there is a lot of information in this policy, we are very happy to discuss the details in greater depth or answer any questions if there is anything you do not understand. We would also love your feedback. Email us at firstname.lastname@example.org