zulily UK Limited ("We") are committed to protecting and respecting your privacy.
This policy (together with our Website Terms and Conditions and any other documents referred to on it) sets out the basis on which any Personal Data (as defined below) we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is zulily UK Limited of 25 Eccleston Place, London SW1W 9NF.
1.1 We may collect and process Personal Data (as defined in section 2.1 below) and Anonymous Data (as defined in section 3.2 below) from you when you visit our site www.zulily.co.uk (the “Website”) and when you send us information or communications.
1.3 We will not disclose information about our customers to third parties except where it is part of providing a service to you, such as arranging for a product to be sent to you, carrying out credit and other security checks and for the purposes of customer research and profiling or where we have your express permission to do so, and/or as set out below.
2.1 We collect Personal Data and Anonymous Data from you when you visit our Website and when you send us information or communications. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. We collect Personal Data, as described below.
2.2 Personal Data you provide to us. We collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, password, and various demographic information when you sign up for a zulily Account (as defined in our Website Terms and Conditions) and make purchases on the Website. When you order Products (as defined in our Website Terms and Conditions) on our Website, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and delivery address. We will record your purchasing history. We also retain information on your behalf, such as your credit card information for future purchases and addresses you add to your address book.
If you provide us with feedback or contact us via e-mail (for example, in response to an employment opportunity posted on our Website), we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply, and any information that you submit to us (for example, a CV). If you participate in any of our surveys, promotions, contests or sweepstakes, or subscribe to newsletters or other offerings via our Website, we may collect additional profile information. When you post messages on the message boards of our Website, the information contained in your posting will be stored on our servers and other users will be able to see it.
We may also collect Personal Data, such as demographic information or personal preferences, from you via other points in our Website which state that Personal Data is being collected. We may also collect Personal Data from you at events, during personal interactions and/or by telephone. Finally, we may obtain Personal Data from other sources (such as third party websites, or any interaction you may have with us of a kind not listed above), and combine it with Personal Data already held.
2.3 Personal Data Collected via Technology (including Cookies). To make our Website, Products, and related services more useful to you, our servers (which may be hosted by a third party service provider) collect Personal Data from you, including your operating system and version, browser type and version, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. As your IP address reveals your location, we may record that too. You may choose, however, not to share your geo-location information with us by adjusting your device’s location services settings. Our servers may also collect data about the pages you visit and, if you link from our Website to other websites, the addresses of such other websites.
On our site we use four kinds of Cookies: (1) authenticated user session Cookies, which expire when you close your browser or log out; (2) user preference data Cookies, which store information about how your account is set up, in encrypted form and without storing your username or password; (3) website state information Cookies, which help show state or feature information such as image type; and (4) user tracking information Cookies, which track what users do on our site. We use the last type for internal analysis and website optimisation.
We may use both the session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. In addition to Cookies, we may use web beacons, which link pages to servers and their Cookies and transmit information collected by Cookies back to servers. We may also allow certain third-party analytics service providers to include Cookies and web beacons on our Website and retain and use data so collected themselves. Cookies can be removed by following Internet browser help file directions. Some web beacons can also be rendered unusable by rejecting their associated Cookies. Please note that if you choose to block cookies, this will impair our ability to recognize you as a member of zulily for purposes of allowing your access to sales events on the website and likely will prevent your ability to shop at our website
2.4 Personal Data that we collect from you about others. If you decide to invite others to the Website or create a zulily Account for a third party to join the Website, we will collect your and the third party’s names, e-mail addresses, and/or phone numbers in order to send an e-mail or text message and follow up with the third party. You hereby agree to obtain the third party’s consent to this before giving us their personal details, unless the person is a child is under 12, in which case such consent must be obtained from his or her parent or guardian. We will inform any third party you invite that you gave us his or her details in the invitation email.
Consent must also be obtained in the same way before you upload or post onto the Website any information or photograph which identifies any third party. The express consent of the third party must be obtained if any Personal Data considered sensitive under the Act (see section 2.2 above) is uploaded.
Please note that at any time you or the third party may contact us at [insert address] to request the removal of this information from our database.
3.1 General Use. We may use Personal Data we collect from you for the following purposes:
a) for our everyday business purposes, such as establishing, securing and managing your customer account, sending you a welcome e-mail to verify ownership of the address provided when your account is created, identifying you as a user in our system, sending you administrative e-mail notifications (such as security or support and maintenance advisories), providing for the proper administration of our Website and Product sales, responding to your inquiries (including any related to employment opportunities) and requests, providing products and services you request, processing and collecting payments and providing customer support;
b) to provide information about our business and offer our Products or services to you and products and services of others that we think you may find of interest;
c) to communicate about, and administer your participation in, special events, programmes, surveys, contests, sweepstakes and other offers or promotions;
d) to enable you to interact with zulily, our Website and our customers through our message boards, blogs and social media;
e) to evaluate and improve our business, including developing new products and services and analysing the effectiveness of products, services and websites and soliciting your feedback through e-mail communications, telephone calls, and/or focus groups;
f) to tailor our offerings to your personal interests and the manner in which you interact with us, and send you promotional materials as described in section 6.1 below, as well as electronic newsletters;
g) to perform data analyses, including market and consumer search, trend analysis, demographic analysis and financial analysis;
h) to comply with legal recommendations, applicable legal requirements and our policies and practices;
i) to respond to your enquiries relating to employment opportunities;
j) to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and
k) to undertake demographic analysis of our membership base.
3.2 Creation of Anonymous Data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable as yours. We use this Anonymous Data to analyse request and usage patterns so that we may enhance the content of our Products and services and improve Website navigation. We reserve the right to use and disclose Anonymous Data to third parties at our discretion.
4.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
4.2 We may disclose your personal information to third parties:
a) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
b) if zulily UK Limited or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets;
c) if we are under a duty to disclose or share your personal data in order to comply with any legal advice, process or obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or
d) to protect the rights, property, or safety of zulily UK Limited, our customers, or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4.3 We may disclose your Personal Data to third parties on terms set out in section 5 below.
4.4 We may disclose Anonymous Data to any third party for any lawful purpose without notice to you.
5.3 Third Party Applications on our Website. We may include applications from third parties on this Website (such as Facebook “Share” or “Like” buttons). Your interaction with these programmes may allow the relevant third parties to collect data, including Personal Data, about you via cookies placed on your device when you register for their application or service. In some cases, the third parties may recognise you even when you do not interact with their application. Please consult each third party’s own website for information about its data protection policy.
5.2 Disclosure to Third Party Service Providers. Except as otherwise stated in this policy, we do not generally sell, trade, share, or rent the Personal Data collected from our services to other entities. However, we may share your Personal Data with third party service providers to provide you with the Products and related services that we offer you through our Website; to conduct quality assurance testing; to provide technical support; or to provide specific services, such as synchronization of your contacts with other software applications, in accordance with your instructions. These third party service providers are required not to use your Personal Data other than to provide the services requested by us. They may be located outside the European Economic Area (“EEA”) (please see section 8 below for further information). You expressly consent to the sharing of your Personal Data with such contractors and other service providers for the sole purpose of providing services to you.
5.3 Disclosure to Advertising Networks. We may partner with advertising networks, which deliver targeted advertisements to consumers and generate statistics and metrics related to the delivery of such advertisements. Such networks use information collected via cookies, web server logs or web beacons to provide customisation, auditing, research and reporting for us and for others. They collect data both on this Website and on participating third party sites. This process enhances the deployment of our marketing programmes and helps us to track the effectiveness of our advertising efforts. Networks may, in addition, use data they collect to determine or predict the characteristics and preferences of advertising audiences, measure the effectiveness of advertising and for other purposes. All data we share with advertising networks is Anonymous Data.
5.4 Disclosure via Promotions. In the event that you participate in a survey, sweepstake, contest or other promotion on our Website that is sponsored by zulily and a third party, such participation serves as your consent for zulily to share your Personal Data collected in conjunction with the survey, sweepstake, contest or promotion with the third party. After the information is provided to such third parties, the subsequent use or disclosure of such information will be subject to the privacy policies and practices of such third parties.
6.2 Changes to Personal Data. You may change any of your Personal Data in your zulily Account by logging into your zulily Account page or by sending an e-mail to email@example.com. You may request deletion of your Personal Data by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
7.1 We are committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorised access, use, or disclosure. We also require you to enter a password to access your zulily Account information. You are responsible for keeping your zulily Account password confidential. We ask you not to share your password with anyone.
7.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we take all appropriate steps in compliance with applicable law to protect your personal data, please note that in spite of the above, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.