Attention is drawn to the terms and conditions set out below, in particular to clause 10 (limitation of Radley's liability). They are binding upon all purchasers and govern all orders and contracts for the sale or supply of all products by Radley.

In these terms and conditions ("Conditions") the following words and expressions shall have the following meanings:

"the Price"                 means the price of the Products, agreed between Radley and the Purchaser at the date of order, including any discount terms.

"the Products"            means the products sold or supplied by Radley to the Purchaser including any labelling and packaging. These include handbags and accessories.

"the Purchaser"      means the entity or individual named in the order which buys or has agreed to buy the Products from Radley.

"Radley"                    means Radley Retail Limited, whose principal place of business is at Unit 1B, Etheridge Avenue, Milton Keynes MK10 0BP, United Kingdom.

1            ORDER AND ACCEPTANCE

1.1        These Conditions shall apply to and form part of all orders and other contracts for the sale or supply of the Products by Radley to the Purchaser and any terms and conditions in the Purchaser's order or enquiries inconsistent with these Conditions shall be of no effect. All orders for the Products shall be deemed to be an offer by the Purchaser to purchase the Products in accordance with these Conditions.

1.2        The acceptance of orders for the Products shall be at the entire discretion of Radley. Acceptance of the Purchaser's order shall become binding on Radley only when Radley has confirmed in writing that it has accepted the order.

2            PRICES

2.1        Radley will supply the Products to the Purchaser at the Price.

5            PAYMENT

5.1        The time of payment shall be of the essence of any order or other contract to which these Conditions apply. Payment will be in advance of delivery.

5.2        Unless otherwise stated in writing, the Price is exclusive of delivery charges, but inclusive of VAT.

5.3        Payment shall be made by the Purchaser in GBP by debit or credit card, made via a digital payment request sent to the Purchaser by Adyen N.V., as initiated by Radley. Payment will be collected by Adyen N.V. on behalf of Radley.

5.5 Payment shall be construed as being received at the time that Adyen N.V. confirms the payment request has been satisfied.

6            DELIVERY

6.1        The delivery options available to you will be explained by the sales person with whom you are placing the order over the phone or using Whatsapp or a similar method of communication

6.2        All orders will be dispatched subject to payment card authorisation and stock availability.

6.3        We will use our reasonable endeavours to deliver the goods or services within the times indicated. However, where delivery times and dates are given, they are for general guidance only and we will not be held liable for late delivery of goods caused by circumstances beyond our reasonable control.

6.4        You are responsible for making arrangements to receive the goods and if the goods are held at the post office, a Radley Store or other delivery company's depot because no one was available when the goods were delivered then it is your responsibility to swiftly collect the goods. It is important that the addresses supplied by you to us are accurate.

6.5        We will not have any responsibility for any loss or damage which occurs to the goods after delivery. A signature and confirmation of receipt constitutes completion of delivery. On rare occasions, delivery will be made outside of the agreed timescale, but we will make every reasonable effort to get your order to you within the timescale we agree with you.

6.6        All orders are shipped from the UK. Deliveries outside the UK are subject to customs, legal, regulatory and certain practical restrictions. To comply with local legislation, you or the recipient may be required to pay additional taxes, fees or levies, import duty or other fees associated with formal customs entry when the good arrive in your country, before your local customs authority will release the goods to you. These are your responsibility. Please ensure that you enter the correct international delivery address and postcode. If the address is entered incorrectly or if customs duties or formal customs entry procedures are required, the delivery may be delayed. We are unable to offer you any assistance if either issue arises.

6.7        The charges outlined above must be paid by the recipient of the parcel. Where a customer fails or refuses to pay these charges, what happens to the goods is out of our control. In the event that the goods are returned without any charge to Radley we will refund the whole purchase price to the customer. In the event that the goods are returned to Radley but a delivery charge is levied on us, we will refund to the customer the purchase price less the charge levied on us to return the goods. It is possible that the goods will not be returned to us, in which case no refund of the purchase price will be given to the customer. In any event, goods that are returned due to the customer refusing or failing to pay any of the charges outlined in this paragraph will not be entitled to a refund of the delivery charge. Customs policies vary widely from country to country, therefore you are advised to check the local requirements in your country when placing an order.

6.8        Occasionally, the delivery of your order may be delayed. This can be for various reasons out of our control such as import delays or higher than anticipated demand. We will, of course, make every effort to keep you

informed. Orders which have a different billing and shipping address may also be subject to delays whilst we perform additional credit checks.

6.9        Radley will not be held responsible for delays and cancellations where the data supplied by customer is incorrect or inadequate.

7            RETURN OF PRODUCTS

Please note that we are not able to accept any returns of earrings or face masks (for hygiene purposes), or personalised products, unless the item is faulty.

UK Orders – Goods must be returned within 30 days for a refund of your purchase price. Returns are free using the Royal Mail UK returns label from your dispatch note. Items originally dispatched to the UK but returned from a non-UK address will be treated as being an order from the country where the goods are being returned from.

EU Orders – Goods must be returned within 30 days of receipt for a refund of your purchase price. For EU countries that do not offer free returns (please see here for the list of all countries for which we offer free returns), unless the goods are being returned due to being faulty or incorrect, the cost of return is non-refundable and Radley reserves the right to arrange collection, in which case the customer will be responsible for the collection charges. If returning the goods due to being faulty or incorrect, please contact us.

Non-EU Orders – Goods must be returned within 30 days of receipt for a refund of your purchase price. The delivery charge and, for non-EU countries that do not offer free returns (please see here for the list of all countries offering free returns), the cost of returning the goods will only be refunded in the event that the goods have been returned due to being faulty or incorrect, in which case please contact us.

Here’s what you need to do:

Products being returned must be unused, in their original packaging including dog tag, dust bag (where applicable), gift wrap, accessories and labels. All footwear must be tried on a carpeted surface until you are certain you are keeping it. Footwear should be returned unmarked and in the original, undamaged box as this is considered part of the product. Footwear that is returned without a box, in a damaged box or with marked soles may not be accepted and may be sent back to the customer. All Fragrance items must be returned unused and sealed in the original packaging. Fragrance items returned opened may not be accepted and may be sent back to the customer.

You can return any unwanted products during the first 30 days using one of the methods set out on your dispatch note – you can i) tick refund or replacement and select the reason for the return by selecting a reason code listed next to the item/items you want to return, and send the completed despatch note back to us alongside the unwanted product, or ii) if you wish to cancel your order, you may complete and return the Cancellation Form (available here) to us. We are legally required to provide you with this form. It is very important that when you return an item, we know the order number it relates to, your details and whether you want a refund or a replacement. Without these details we won't be able to take the action you want us to.

Put the product with the completed dispatch note inside the outer packaging and seal securely. Return your item via your selected method below and send to our returns address: Radley Website Returns Department. Radley + Co Unit 1 Site B Etheridge Avenue Brinklow Milton Keynes MK10 0BP, United Kingdom.

Please note that refunds can take up to 14 days to process from receipt by our Returns Department.

To take advantage of our free international returns, you will need to register your return and create your returns label by visiting our returns portal and following the below instructions:

RETURNS

Once you have completed the returns request, you will need to print the label, (you will also receive this via email). You must affix this label to your parcel.

Please follow the drop off/collection instructions on the label supplied to complete the return.

We will confirm by email when your return has been received and by email again when your refund or replacement has been processed.

We recommend that you use registered post, recorded delivery or another secure method of delivery from a reputable carrier, retaining the receipt until you have received credit for the returned items. We also recommend that you send your international parcel using a delivery service that insures you for the value of the goods. We cannot accept responsibility for international orders lost in transit. For orders within the UK please affix the free Royal Mail returns label from the dispatch note to your parcel, drop the parcel off at your local Royal Mail post office and obtain proof of postage.

If you return your product in line with the Timeframes and Returns Procedure above, we will:

refund you the price you paid for the products. However, please note we are permitted by law to reduce your refund to reflect any reduction in the value of the goods, if this has been caused by your handling them in a way which would not be permitted in a shop (e.g. products being returned must be treated in line with point

1 of the Returns Procedure above). If we refund you the price paid before we are able to inspect the goods and later discover you have handled them in an unacceptable way, you must pay us an appropriate amount;

refund any delivery costs you have paid to receive your order. Although, as permitted by law, the maximum refund will be the costs of delivery by the least expensive delivery method we offer (provided that this is a common and generally acceptable method). For example, if we offer delivery of a product within 3-5 days at one cost but you choose to have the product delivered within 24 hours at a higher cost, then we will only refund what you would have paid for the cheaper delivery option;

process your refund to the original method of payment. Should the purchase have been made using more than one method, i.e. gift card and credit/debit card the refund will always be processed to the gift card in the first instance and the balance to the credit/debit card. We will contact you by email to let you know that your refund has been processed. Please note that refunds can take up to 15 working days to process from receipt by our Returns Department;

we will contact you by email to let you know that your refund has been processed. Please note that refunds can take up to 14 days to process from receipt by our Returns Department;

Any refund out of policy will be at the discretion of the online team, and will normally be given in Store Credit to the value of the current selling price.

What happens if your product is faulty?

If you find a fault with your product when you receive it, please explain this to us on your dispatch note/cancellation form or call our Customer Service team on +44 (0)207 741 1055 to discuss. We will deal with faulty products on a case by case basis.

Please note that if you have purchased Radley products from an alternative retailer and you find a fault with the product you should return the faulty product to the relevant retailer.

If your goods become faulty over time:

Radley + Co products are made to the highest standards, with rigorous quality control checks made throughout the manufacturing process. Please be aware that leather is a natural product and a level of marking on the hide is to be expected. We consider this an important aspect of each Radley product’s individuality.

Where products do not perform to expected quality standards we offer the following guarantees:

Handbags, Small Leather Goods and Umbrellas: 1 year from date of purchase* Jewellery: 1 year from date of purchase*

Luggage Items: 2 years from date of purchase* Wheeled Luggage Items: 5 years from date of purchase*

Watches: 2 years from date of purchase. Items not covered by the warranty are batteries, straps and bracelets. Damage caused from accidents or mishandling to any part of the watch, including strap, buckles, bracelets and watch glasses. Water penetration, except in watches marked as water resistant. Tarnishing of the watch case or bracelet caused by external agents.

*Please note that removable items such as dog tags, charms, luggage tags etc are not included in the product guarantee.

This guarantee covers faults caused by manufacturing or the material used. It does not cover normal wear and tear or misuse. If a problem develops with a product during regular use, please contact our Customer Services Team on +44 (0) 207 741 1055 between 10am-6pm Monday to Friday (GMT/BST) excluding UK bank holidays, 10am-4pm (GMT/BST) Saturday to Sunday, or contact us.

PROOF OF PURCHASE

You must have your receipt, gift receipt or delivery note available for us to refund your goods. We will refund the original method of payment used to purchase the returned goods.

PRIVACY POLICY INTRODUCTION

Welcome to the Radley + Co Limited privacy notice. Radley+Co Limited is the 100% owner of Radley Retail Limited, and all references to Radley+Co Limited below also apply to Radley Retail Limited.

Radley + Co respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you visit any of our stores and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at the back of the notice to understand the meaning of some of the terms used in this privacy notice.

This notice will be updated from time to time as and when we make changes in our approach. We will update the date on our notice whenever we make changes and would encourage you to revisit it from time to time to stay up to date. This version was last updated on 18.03.2021 and historic versions can be obtained by contacting us.

1. [IMPORTANT INFORMATION AND WHO WE ARE]
   1. [THE DATA WE COLLECT ABOUT YOU]
2. [HOW IS YOUR PERSONAL DATA COLLECTED]
   1. [HOW WE USE YOUR PERSONAL DATA]
   2. [DISCLOSURES OF YOUR PERSONAL DATA]
   3. [INTERNATIONAL TRANSFERS]
3. [DATA SECURITY]
4. [DATA RETENTION]
5. [YOUR LEGAL RIGHTS]
   1. [GLOSSARY]

1. IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Radley + Co collects and processes your personal data through your use of our website, your use of our stores, or your participation in a Radley + Co event, including any data you may provide when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

CONTROLLER

Radley + Co Limited is the controller and responsible for your personal data (referred to as “Radley + Co”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

CONTACT DETAILS

You can contact our Data Privacy Manager at:

Post:

Radley + Co Limited Unit 1B

Etheridge Avenue

Milton Keynes MK10 0BP FAO: Data Privacy Manager

Email:     dataprivacy@radleyandco.com

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.

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit.

1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, and social media account names.

Contact Data includes billing address, delivery address, email address, telephone numbers.

Financial Data includes bank account details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes 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 website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, emails, postal mail, digital ads, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties via email, postal mail and ads, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

PHISHING

Phishing is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an email to a user, in an attempt to get the user to send private information that will be used for identity theft and fraud.

Radley will never ask you to send any personal details via email. If we require such details, for security reasons we will ask you to contact us by telephone. Should you receive an email claiming to be from Radley + Co requesting this kind of information please do not respond but contact us immediately.

1. HOW IS YOUR PERSONAL DATA COLLECTED?

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

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:

Buy or express an interest in our products or services, in-store or on our website; create an account on our website;

subscribe to our newsletter;

request that we send marketing materials to you; enter a competition, promotion or survey;

take part in a Radley + Co event; submit a product review; and speak to customer services.

Automated technologies or interactions. As you interact with our website, emails, postal mail and digital ads on platforms such as Google, Bing, Facebook, Twitter and Instagram, and display or banner advertisements on third party websites we contact you through, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our IP Addresses and Cookies policy for more details.

1. HOW WE USE YOUR PERSONAL DATA

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:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where we have your consent.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to email marketing at any time by unsubscribing via the link provided with each marketing email we send to you or by contacting us on dataprivacy@radleyandco.com .

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data

Lawful basis for processing including basis of legitimate interest To register you as a new customer

(a)  Identity

(b)  Contact

Performance of a contract with you

To process and deliver your order including:

(a)  Manage payments, fees and charges

(b)  Collect and recover money owed to us

(a)  Identity

(b)  Contact

(c)  Financial

(d)  Transaction

(e)  Marketing and Communications

(a)  Performance of a contract with you

(b)  Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a)  Notifying you about changes to our terms or privacy notice

(b)  Asking you to leave a review or take a survey

(a)  Identity

(b)  Contact

(c)  Profile

(d)  Marketing and Communications

(a)  Performance of a contract with you

(b)  Necessary to comply with a legal obligation

(c)  Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in an event, prize draw, competition or complete a survey

(a)  Identity

(b)  Contact

(c)  Profile

(d)  Usage

(e)  Marketing and Communications

(a)  Performance of a contract with you

(b)    Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

(c)  Consent

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a)  Identity

(b)  Contact

(c)  Technical

(a)   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)

(b)  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 Transaction Profile Usage

Marketing and Communications Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, stores, products/services, marketing, customer relationships and experiences

Identity Contact Transaction Technical Usage Profile

a)   Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy); or

b)  Consent

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a)  Identity

(b)  Contact

(c)  Technical

(d)  Usage

(e)  Profile

a)  Necessary for our legitimate interests (to develop our products/services and grow our business); or

b)  Consent

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Customers without an online profile may update their choices emailing customercare@radley.co.uk. You may also click ‘unsubscribe’ in any of the marketing emails we send to you.

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 (this is “marketing”).

You will receive marketing communications via email and/or via postal mail from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from us if you have provided us with your details when you entered a competition or registered for a promotion and gave us your consent as part of that process.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you email marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us.

You can ask us or third parties to stop sending you postal marketing communications by contacting us on the contact details provided in each postal marketing communication or by contacting us on dataprivacy@radleyandco.com.

Opting out of marketing messages will not prevent you receiving non-marketing messages from us, for example relating to products ordered from us, responses to customer service queries etc.

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

1. 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 the table in paragraph 4 above.

External Third Parties as set out in the Glossary.

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, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

1. INTERNATIONAL TRANSFERS

Some of our external third parties are based in Asia Pacific and the USA, outside of the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK authorities and/or the European Commission. For further details, see https://ec.europa.eu/info/law/law- topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data- non-eu-countries_en

Where we use certain service providers, we may use specific contracts approved by the UK/European Commission which give personal data the same protection it has in Europe.         For              further           details,   see              https://ec.europa.eu/info/law/law-topic/data- protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third- countries_en

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

1. 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.

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.

1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

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. We also keep this basic information about our customers for up to seven years following your most recent purchase from us, to enable us to deal efficiently with any after-sales queries that you may have. We keep customer profile information that you have indicated you are happy for us to have in order to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data, or until a maximum of seven years following your most recent positive interaction with a marketing communication (e.g. clicking on a link in an email taking you to our website) – whichever of these two periods is shorter.

Any calls to the Radley call centre that are recorded for training and monitoring purposes are automatically deleted after 45 days.

No customer information will be retained from communications with us on WhatsApp for Business Chat (“WAB Chat”). A customer’s name and phone number will be deleted either after 48 hours, if the WAB Chat does not result in a purchase, or once a purchase has been made and the items have been despatched.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymise 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.

1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

[Request access to your personal data]. [Request correction of your personal data]. [Request erasure of your personal data]. [Object to processing of your personal data].

[Request restriction of processing your personal data].

[Right to opt-out of automated profiling of your personal data] [Request transfer of your personal data].

[Right to withdraw consent].

If you wish to exercise any of the rights set out above, please contact us. NO FEE USUALLY REQUIRED

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. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

YOUR CALIFORNIA PRIVACY RIGHTS

Under Californian law, California residents who provide personal information to us in obtaining products or services for personal, family or household use are entitled to request and obtain from us information about the customer information that we disclose, if any, to other businesses for their own marketing purposes. Radley does not sell or otherwise disclose your information to anyone else for their own marketing purposes.

1. GLOSSARY LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means you have explicitly given us permission to process your personal data. In such circumstances we will have asked you a specific question and you will have entered information or ticked a tick-box to indicate your consent.

THIRD PARTIES EXTERNAL THIRD PARTIES

Service providers acting as processors based in the UK or EU who provide marketing, IT, e-commerce and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and EU who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Customer service call, email, webchat, display advertising and website behavioural service providers, acting as processors or controllers, based in the UK, EU or USA; Social media platforms, search engines and service providers based in the USA. YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Request to opt out of automated profiling of your personal data. You have the legal right to opt-out of any automated profiling of your personal data that could have a legal consequence for you, and have a human being involved in the processing decision rather than it being automated. The only profiling of this type that we undertake is in our marketing activities, in which we tailor our marketing communications to your transactional history and product preferences. If you wish to opt-out of this automated profiling please contact us, though please be aware that our systems are not configured to send un-tailored marketing communications to you, so in practice opting out of automated profiling will result in you being opted out of receiving marketing communications from us.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

IP ADDRESSES AND COOKIES

What are cookies?

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your device if you agree when you visit the website. These may be cookies, web pixels, beacons or other web files and will all be referred to as “cookies” in this policy.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. They help us to improve our site and to deliver a better and more personalised service. They enable us:

To estimate our audience size and usage pattern.

To store information about your preferences, and so allow us to customise our site according to your individual interests.

To speed up your searches.

To recognise you when you return to our site.

We may use your data to provide you, via email, post, telephone or SMS with information, products or services that you request from us or which we feel may be of interest to you, or share your details with selected third parties which we believe may be of interest to you, where you have consented to be contacted for such purposes.

We will use information held about you to carry out our obligations arising from any contracts entered into between you and us.

Adjusting your cookie settings

By adjusting the privacy and security settings on your device, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Our use of cookies

The cookies that we use fall into five categories:

Strictly Necessary Cookies - These cookies are required for the operation of our website. They enable services you have specifically asked for, they allow you to move around the website and use certain features, such as accessing secure pages. Session Cookies – These cookies allow the site to ‘remember’ content from page to page for example shopping basket. These cookies expire when the user leaves the site or closes the browser.

Analytical or Performance Cookies - These cookies collect information about how you use the website, for example pages you go to and any error messages you experience. These cookies don't gather information that identifies you, they are anonymous and help to improve how the website works.

Functionality Cookies - These cookies are used to recognise you when you return to our website and allow our website to remember choices you make, and tailor the website to provide enhanced content for you.

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 you. They are also used to limit the number of times you see an advertisement. We may also share this information with third parties for this purpose.

Persistent cookies - This type of cookie is saved on your computer for a fixed period (usually a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to know who you are for more than one browsing session. For example, we use this type of cookie to store your preferences, so that they are remembered for the next visit.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Strictly necessary cookies

Cookie Title

Cookie Name Module/Service

Purpose VIEWED_PRODUCT_IDS

Enterprise/PageCache

Provide viewed product ids from cookie. geoip

MX/Geoip

Geoip functionality. Redirect if cookie enabled. frontend

Core

Session ID on the server BIGipServerPOOL SERVERID

Load balancing scarab.visitor scarabresearch.com

Store and track visits across websites. category_id

Core

Current category ID ow_cookie_notice Optimiseweb/CookieNotice

Notice block shown\hidden\closed nocache

MX/Varnish

Turn Off\On Varnish Cache

Analytical or performance cookies

Cookie Title Cookie Name Module/Service

Purpose

_uetvid

_uetsid

_dc_gtm_UA-10478651-1 Google Tag Manager

Store and track visits across websites.

_gcl_au

Google Tag Manager

Store and track conversions.

_ga

_gid

Google Analytics

Count and track pageviews.

GA Event - EE Add to Cart GA Event - EE Checkout

GA Event - EE Checkout Option GA Event - EE Product Click

GA Event - EE Product Detail

GA Event - EE Product Impression GA Event - EE Promotion Click

GA Event - EE Purchase

GA Event - EE Remove from Cart GA Event - Email Click

GA Event - Empty Cart GA Event - Exit Click GA Event - JS Error

GA Event - Scroll Tracking GA Pageview - All pages GA Pageview - Error Page

Google Analytics

Support marketing and onsite analytics on each page and key behaviours, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. And buying behaviour such as items

purchased, spends, vouchers used.

_fbp Facebook

Store and track visits across websites.

Content Square - Delivery Content Square - Payment Contentsquare - E-commerce Contentsquare - Main UK Contentsquare - Main US

Content Square

Support onsite analytics, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site, and buying behaviour such as items purchased, spends, vouchers used.

Fifty Tag Fifty

Support analysis of paid social marketing activity on Facebook and Instagram, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. And buying behaviour such as items purchased, spends, vouchers used.

Targeting cookies

Cookie Title Cookie Name Module/Service

Purpose

Affilinet - Add to Cart Affilinet - Profiling - Cat Page

Affilinet - Profiling - Default Pages Tag Affilinet - Profiling and Order Confirmation Affilinet - Profiling- Product Page

Awin / Affilinet

Support affiliate marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Bing

Bing Revenue Tracking Bing

Support paid per click Microsoft ads on Bing marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Connexity - Conversion Tag Connexity

Gather conversion insights.

Conversant - Conversion Conversant - Pageview Conversion Linker

Conversant Epsilon

Support understanding of onsite customer journey behaviour collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Emarsys Emarsys

Tags & cookies to support email marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Facebook - Add To Cart Facebook - All Pages Pixel Facebook - Checkout Facebook - PDP

Facebook - Purchase Facebook

Support Paid social marketing activity on Facebook and Instagram, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Mention Me - Checkout

Mention Me - Purchase Mention me

Support refer a friend marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Pinterest Pinterest

Support social media marketing activity on Pinterest, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Rakuten - All pages

Rakuten - Channel Cookie Set Rakuten - Purchase

Rakuten

Support affiliate marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Twitter Twitter

Support paid social media marketing activity on Twitter, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Unidays - Purchase Unidays

Support student discount marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

Ve Interactive - DE Ve Interactive - UK

VE Interactive Conversion Tags Ve Interactive

Support abandoned basket email marketing activity, collecting browser behaviour data. This includes recognising onsite behaviours such as products, category, content and checkout pages. Technical information such as device, browser type and time on site. Buying behaviour such as items purchased, spends, vouchers used.

We may change the cookies we use from time to time so we recommend that you review this cookies policy and your cookie settings regularly.

Third Party Cookies

Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. Please see the list set out above.

Certain Radley third party providers use cookies and other similar technologies such as log files and pixel tags to collect information regarding your interests and preferences (e.g. products or pages you have viewed on our website) in order to provide personalised and tailored advertisements to you online, including on other third party websites. This also involves tracking such information across multiple devices. We provide these third party providers’ affiliates and processors with personal data, who then make this information pseudonymous before then providing it to the third party provider. Therefore, these third party providers will not have access to any personally identifiable data, but rather data that has been made pseudonymous by their affiliates and processors, with whom they have a contractual relationship. “Pseudonymous” means the information cannot be attributed to a specific person without the use of additional information. The third party provider will match this pseudonymous data with other data, for example collected via the use of cookies and other similar technologies such as log files and pixel tags, to provide tailored advertisements to you.

To learn more about the use of this information or to make choices about receiving personalised advertising provided by third parties, please visit the European Digital Interactive Advertising Alliance by clicking here: http://www.youronlinechoices.eu or view individual partners by clicking on the links below:

Vendor Role

Data & Privacy Policy Affilinet / Awin Affiliate Marketing

https://www.awin.com/gb/legal/privacy-policy Bing

Paid Search Advertising

https://about.ads.microsoft.com/en-gb/resources/policies/privacy-and-data- protection-policies

Content Square

Conversion Rate Optimization & Analytics https://contentsquare.com/gb-en/privacy-center/ Conversant Epsilon

Display Marketing https://emea.epsilon.com/privacy-policy Emarsys

Email Service Provider https://emarsys.com/privacy-policy/ Facebook

Social Platform https://www.facebook.com/policy.php Fifty

Social Media Agency https://fifty.io/privacy-policy.php Google

Analytics & Paid Search Advertising https://policies.google.com/privacy?hl=en-US Mention Me

Refer a Friend Program

https://mention-me.com/help/privacy_policy_s Pinterest

Social Platform

https://policy.pinterest.com/en-gb/privacy-policy Rakuten

Affiliate Marketing

https://www.rakuten.com/help/article/privacy-policy-360002101688 Twitter

Social Platform https://twitter.com/en/privacy Unidays

Student Discount Scheme https://www.myunidays.com/GM/en-GB/privacy-policy

We may use the data in accordance with the preferences expressed in your acceptance of the Radley cookie policy and terms and conditions of use of the Radley website. Our website uses cookies/advertising IDs for the purpose of advertising. This enables us to show our advertisements to visitors who are interested in our products on partner websites and apps. Re-targeting technologies use your cookies or advertising IDs and display advertisements based on your past browsing behaviour.

Back to top SECURITY

We realise how important it is to securely store any information that you provide us. The Radley transactional web site currently uses high-level Secure Socket Layer (SSL) encryption technology, the most advanced security software currently available for online transactions. 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.

You can tell whether a webpage is secure as 'https' will replace the 'http' at the front of the www.radley.co.uk in your browser address window, also a small locked padlock will appear in your browser window.

Back to top PHISHING

Phishing is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an email to a user, in an attempt to get the user to send private information that will be used for identity theft and fraud.

Radley will never ask you to send any personal details via email. If we require such details, for security reasons we will ask you to contact us by telephone. Should you receive an email claiming to be from Radley & Co requesting this kind of information please do not respond but contact us immediately.

Back to top COMPLAINTS

If you feel that Radley is not abiding by its posted privacy policy, you should first contact the Online Customer Service Department or telephone +44 (0) 207 741 1055. You can also write to us at:-

Radley & Co, Unit 1B, Etheridge Avenue, Milton Keynes MK10 0BP