Privacy Notice
When you shop with Bravissimo, or request information from us, we collect your personal data so that we can process your orders and send them to you, and so that we can contact you.
Below is some more information about the types of personal data we may collect about you when you interact with us. It also explains how we store and handle that data and keep it safe.
We know that there’s a lot of information here but it’s important to us that you are fully informed about your rights and how Bravissimo uses your data; for example, we will explain things like our credit checking procedure, and how we combine data across channels if you visit us on-line, in our shops, or if you call our customer services team.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes (if you have opted into emails), but you’re welcome to come back and check it whenever you wish at bravissimo.com/privacy.
Contents
Who are we?
Explaining the legal basis we rely upon
When do we collect your personal data?
How can you stop the use of your personal data for direct marketing?
What sort of personal data do we collect?
How and why do we use your personal data?
Combining your data for personalised direct marketing
How we protect your personal data
How long will we keep your personal data?
Who do we share your personal data with?
Where your personal data may be processed
What are your rights over your personal data?
Contacting the Regulator
If you live outside the UK
Any questions?
1. Who are we?
Bravissimo Limited is a company registered in England and our company number is 03315389. We are a data controller registered with the Information Commissioner.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Bravissimo Limited of Bravissimo HQ, Athena Drive, Tachbrook Park, Warwick, CV34 6RQ.
2. Explaining the legal basis we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent. For example, when you enrol in our reward points scheme. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you place an order for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
Legal compliance
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting Bravissimo to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
3. When do we collect your personal data?
When you visit our website, and use your account to buy products and services, or redeem vouchers from Bravissimo on the phone, in a shop or online.
When you add an item to basket, make an online purchase, and check out as a guest (in which case we just collect transaction-based data).
When you create an account with us.
When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
When you engage with us on social media.
When you contact us by any means with queries, complaints etc.
When you enter prize draws or competitions.
When you book any kind of appointment with us
When you choose to complete any surveys we send you.
When you comment on or review our products and services.
Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Consultant who provided that service, it may be passed on to them if requested.
When you fill in any forms. For example, if an accident happens in store, a Consultant may collect your personal data.
When you’ve given a third party permission to share with us the information they hold about you.
When you use our shops which usually have CCTV systems operated for the security of both customers and Consultants. These systems may record your image during your visit.
4. How can you stop the use of your personal data for direct marketing?
The only marketing messages we send you will be for the products and information directly related to Bravissimo.
Can I be removed from your email mailing list?
There are several simple ways that you can stop direct marketing communications from us:
‘Click to unsubscribe’ on the link at the bottom of any email communication that we send you.
If you have an account, log in into your account on Bravissimo.com, visit the My Account area and change your preferences.
Contact our Customer Services team on 01926 459859 or by email at customer.services@bravissimo.com
Ask a Consultant in one of our shops
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
How can I stop receiving your magazine?
If you have an account, log in into your account on Bravissimo.com, visit the My Account area and change your preferences.
Contact our Customer Services team on 01926 459859 or by email at customer.services@bravissimo.com
Ask a Consultant in one of our shops
Please note that you may receive one more magazine from us after changing your preferences, as our magazines are printed in advance.
Will you pass on my data to third parties?
We only obtain your details in the course of a sale, or if you make contact with us for another reason (fittings, magazine requests, competitions etc.)
We may share your personal information with our suppliers, service providers and other contractors to fulfil orders you place with us and to provide the services you request.
Your personal data is shared with Experian Ltd for the purposes of managing a service called Club Canvasse, a home shopping and direct retailer data co-operative of which Bravissimo are members. By sharing information on what customers buy and pooling that with contributions from other members of the co-operative, the service allows Bravissimo to better understand our customers and to communicate with you more effectively. Please note, your personal information is not shared with any of the other members of the co-operative, and only aggregated data on the number and value of purchases is provided to members e.g. we will receive a report which states how many customers who have bought from us in the last 0-12mths, and who have also bought from other members of the co-operative in the last 0-12mths, or the last 24mths, last 36mths etc. To understand more please click through to Experian’s website to understand more about their marketing services.
We partner with another company, Epsilon, to provide you with personalised advertising and content. Epsilon use first - and third- party cookies and other techniques to recognize your browser and collect information about your web browsing activity when visiting our website. These cookies and techniques collect personal data, for example browser type, browsing activity, cookie ids, IP-addresses and transactions made. We also provide Epsilon with other information about you, such as name, address, and email, to enable personalised advertising. Please contact us if you no longer want us to share such information. Detailed information about Epsilon’s processing can be found in their privacy policy. You can visit the European Interactive Digital Advertising Alliance to learn more about personalised interest-based advertising, and to opt-out of receiving this from their respective members. You can also visit Epsilon’s data subject request tool here.
Bravissimo will never pass on your personal information to a third party for third party marketing purposes.
5. What sort of personal data do we collect?
If you have a web account with us: your name, title, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
Details of your interactions with us through Customer Services, in store or online.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items added to your basket or saved, voucher redemptions, and how and when you contact us.
Details of your shopping preferences.
For example, which of our shops you prefer to visit and where you redeem your vouchers.
Details of your visits to our websites, and which site you came from to ours.
Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
Personal details which help us to recommend items of interest. For example, you might tell us your bra size, which we’ll use to guide our suggested items.
Payment information.
Your comments and product reviews.
Your image may be recorded on CCTV when you visit a shop.
To deliver the best possible web experience, we collect technical information about your internet connection and browser, as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
6. How and why do we use your personal data?
We want to give you the best possible service and experience with us. One of the things that helps us to do this is combining the data we have about you to give us a really good understanding of you. We then use this to offer you promotions, products and services that are most likely to interest you. In the case of our loyalty scheme members, we’ll also offer you relevant rewards. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
To process any orders that you make by using our website, Customer Service team or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds and so on.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our website. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
To protect our customers, premises, assets and Consultants from crime, we operate CCTV systems in our stores which record images for security. We do this on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, direct mail, web, text, telephone and through our Customer Service teams about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites and emails, we’ll use data we hold about your favourite products and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device.
For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history, bra fit finder quiz results and any other data you’ve shared with us.
To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll capture information about your browser session, such as your browser version and screen size to help us understand more when you leave us online feedback about any problems you’re having
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from Bravissimo, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country.
To process your booking/appointment requests (for example for a fitting with a Consultant at one of our shops). We do so to maintain our appointment with you.
Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). Without sharing your personal data, we’d be unable to fulfil your request.
7. Combining your data for personalised direct marketing
We want to make sure that the communications we send to you are as relevant to you as possible. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Bravissimo as described above; for example, your shopping history.
For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
We only obtain your details in the course of a sale, or if you make contact with us for another reason (fittings, magazine requests, competitions etc.)
The only marketing messages we send you will be for the products and information directly related to Bravissimo.
8. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all areas of our websites using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as your contact details) is secured by SSL encryption.
When you enter payment card information, it is passed directly from your browser to a secure payment gateway, who then give us a reference to it. We do not, and cannot, store your card number.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
For example we store the emails you send to us for 2 years so we can ensure that your request has been fully dealt with
10. Who do we share your personal data with?
We only use your data for Bravissimo purposes. We don’t sell or rent your data to third parties for marketing purposes. However sometimes, to enable us to comply with our contractual obligations to you, we need to share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Operational companies such as delivery couriers.
Direct marketing companies who help us manage our electronic communications with you.
Google/Meta/Epsilon to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
We may, from time to time, expand, reduce or sell Bravissimo, and this may involve the transfer of part or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
For further information please contact our Data Protection Officer.
To help personalise your journey through our website we currently use the following companies, who will process your personal data as part of their contracts with us:
• PayPal
• Apple
• Adyen
• Vee24
• Google
• DoubleClick
• Facebook
• Twitter
• TikTok
• HotJar
• Scene Stealer
• AB Tasty
• SLI Systems
• Adestra
• More2
• Sub2
• SiteGainer
• Wunderkind
11. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
International orders
If you are based outside the UK and place an order with us, we will store the personal data that we collect from you in the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. For example, this might be required in order to fulfil your order, process your payment details or provide support services. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by a consultant of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that Bravissimo holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Bravissimo Ltd, Bravissimo HQ, Athena Drive, Tachbrook Park, Warwick, CV34 6RQ, or email DPO@Bravissimo.com. To ask for your information to be amended, please update your online account, or contact our Customer Services team on 01926 459859
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them by calling 0303 123 1113, online at ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 14.
14. If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
We only store your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
15. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at DPO@Bravissimo.com
Or write to us at Data Protection Officer, Bravissimo Ltd, Bravissimo HQ, Athena Drive, Tachbrook Park, Warwick, CV34 6RQ
This notice was last updated on 09/01/2023