Naked Apparel Privacy Notice

Last Updated: January 2026

This Privacy Notice explains how Naked Apparel Ltd. ("we," "us," or "our") collects, uses, and protects your personal data when you visit our website (the "Site"), purchase our products, or interact with us.

We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018 (DPA 2018).

1. Important Information and Who We Are

Naked Apparel Ltd is the data controller and responsible for your personal data.

• Company Name: Naked Apparel Ltd
• Registered Address: Unit 7 Sandbrook Park, Sandbrook Way, Rochdale, England, OL11 1RY
• Email: customerservice@nakedapparel.co.uk

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

2. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Personal Data Category	Description
Identity Data	First name, last name, title, date of birth.
Contact Data	Billing address, delivery address, email address, and telephone numbers.
Financial Data	Payment card details and bank account information. Note: We do not store full payment card details; this is handled by our PCI-compliant payment processor.
Transaction Data	Details about payments to and from you and other details of products and services you have purchased from us.
Technical Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
Profile Data	Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data	Information about how you use our website, products and services.
Marketing and Communications Data	Your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

3. How Your Personal Data is Collected

We use different methods to collect data from and about you, including through:

3.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• purchase our products;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

3.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

3.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:

• Analytics providers (e.g., Google based outside the UK/EEA).
• Payment and delivery services.

4. How We Use Your Personal Data and Lawful Basis

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Purpose of Processing	Type of Data Used	Lawful Basis for Processing (GDPR/UK DPA 2018)
To register you as a new customer.	Identity, Contact	Performance of a contract with you.
To process and deliver your order, manage payments, fees and charges, and collect and recover money owed to us.	Identity, Contact, Financial, Transaction	Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you, including notifying you about changes to our terms or privacy notice.	Identity, Contact, Profile, Marketing and Communications	Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and analyse how customers use our products/services).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity, Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Identity, Contact, Profile, Usage, Marketing and Communications, Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, grow our business and inform our marketing strategy).
To send you marketing communications where you have specifically requested or consented to receive them.	Identity, Contact, Marketing and Communications	Consent.

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.

5. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

• Promotional offers from us: 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 is how we decide which products, services and offers may be relevant for you (we call this marketing).
• Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
• Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at the contact details above.

6. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in section 4.

6.1 Internal Third Parties: Other companies in the Naked Apparel Ltd. group acting as joint controllers or processors and who are based in the UK/EEA and provide IT and system administration services and undertake leadership reporting.

6.2 External Third Parties:

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers providing consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Payment processors (e.g., Shopify Payments, PayPal) and delivery companies (e.g., Royal Mail, DPD) necessary to fulfil your order.
• Marketing platforms (e.g., Klaviyo, Mailchimp) for managing email communications.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers

We do not generally transfer your personal data outside of the UK and the European Economic Area (EEA).

If, however, our third-party service providers (such as hosting or marketing platforms) transfer your data outside the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (an adequacy decision) by the UK government.
• Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner's Office (ICO) which give personal data the same protection it has in the UK.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, by law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us using the details provided in section 1.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

11. Changes to the Privacy Notice

We may change this Privacy Notice from time to time by updating this page. We encourage you to review this page periodically to ensure you are happy with any changes.