Last updated: August 2022 version: 202208_11
Burberry is committed to respecting your privacy and complying with applicable laws and regulations to ensure that the personal information you give us is kept appropriately secure and processed fairly and lawfully.
Burberry Limited is a company incorporated and registered in England and Wales with company number 00162636 (referred to in this Policy as "we, "us" and "our"). Burberry's representative in the European Union ("EU") is Burberry Italy srl, Via Manzoni, n.20, Milan 20121, Italy ("Burberry EU Representative").
- To analyse, profile and monitor customer patterns and better understand the interests and preferences of our key customer audiences so we can consistently improve our products and services.
- To offer an enhanced customer experience and service, including by ensuring we personalise the Site and Application and (if applicable) Burberry updates relating to products, services and events to make them more relevant to our customers’ specific preferences.
- To ensure the proper functioning and security of our services, Site and/or Applications, for example by identifying and preventing fraudulent transactions.
- To analyse the footfall in Burberry stores and at Burberry promotions or events for internal reporting purposes and to ensure adequate and appropriate product and resources.
- To ensure we continue to comply with applicable laws, for example in maintaining the accuracy of our records.
WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
We may collect the following information:
CONTACT INFORMATION AND OTHER IDENTIFYING INFORMATION: your name, postal address, phone numbers and e-mail addresses. You acknowledge that we may also obtain information about you as a result of authentication or identity checks (for example in connection with our standard fraud checks when you make a purchase on our Site or Application). We use this information to identify you as a customer, to process your order, to deliver products and services, to process payments, to update our records and to generally manage your account with us under our terms with you. Providing us with certain personal information is voluntary but we may not be able to process your order and/or send you the required order acknowledgement and shipping confirmation communications if you do not provide us with certain requested information.
We may also use your contact information to send you marketing communications and to contact you in relation to service-related matters, including aftercare services or to assist you in relation to prospective purchases on our Site and/or Application and, on occasion, to request and respond to feedback relating to Burberry. This feedback may relate to matters including Burberry’s brand, product and services and/or your experience and satisfaction with Burberry, including in-store, on our Site and/or Application. We will only use your contact information where permitted to do so in accordance with applicable laws or if we have your consent to do so (if required by applicable laws).
PAYMENT INFORMATION: information related to your credit card, debit card, and/or other payment information to process payments in connection with your orders.
DEMOGRAPHIC INFORMATION: we may ask you for your gender, birthday and age (and where you have a customer account we may infer your age bracket based on your engagement with our stores). You may also provide us with information about yourself, your product size preferences and lifestyle interests on our Site or Application or when using interactive content in Burberry store or events. We use this information and/or your customer account and profile information for our internal demographic insights into our customers, to offer you an enhanced service according to your preferences, including by identifying relevant products, services and events which may be of interest to you, and personalising your experience with Burberry.
OTHER ACCOUNT AND TRANSACTIONAL INFORMATION: if you have a customer account (whether created online or in-store) or, in certain cases, where you purchase Burberry products through our business partners (including department stores in which Burberry has a concession), we may also collect information about the products you browse online or purchase, where you purchased the products from and other information related to your purchases or which is otherwise relevant to your customer relationship with Burberry. We use this information, for our internal demographic insights into our customers, to offer you an enhanced service according to your preferences (including any style preferences you may share when using our Applications), such as identifying relevant products, services and events which may be of interest to you, personalising your experience with Burberry and sharing with you information about your past purchases.
Together with non-personal information, we may also use this information for our internal marketing analysis and demographic studies, to analyse, profile and monitor customer patterns so we can consistently improve our products and services. This means that we can offer more personalised and integrated shopping and interactive experiences to our customers across our stores, our Site and Applications.
INTERNET AND OTHER ELECTRONIC ACTIVITY: Where permitted under applicable laws or with your consent (if so required by applicable laws), we may use information about how you use our Site, Application and any in-store services to personalise our communications to you, tailor the advertisements you are shown and/or the content appearing on our Site content appearing on our Site and Application and to personalise our in-store service to you, so as to make the Site, our Application and our services and communications more relevant to you and to enable your use of any interactive features of our services. We also use this information to maintain and improve the Site, our Application, and our services.
We may process information about the device you are using to connect to the services on our Site, Applications or any interactive content we may provide. This may include the type of device you use, your internet browser, your location based on the unique identifier for your device such as an Internet Protocol address (“IP address”) or a code for an Application running on your device. When you attend a Burberry store or event, we may also use technologies that connect to the functionality on your mobile device (such as Bluetooth and GPS) and collect information based on Wi-Fi, mobile phone masts, beacons and other in-store technology. See further information regarding Wi-Fi usage below.
We use this information to ensure the proper functioning and security of our Site and Application, to optimise our services to you and to better understand how our content and services are used and their effectiveness. The information collected in-store through your mobile device using these technologies also gives us aggregated and anonymous statistics about footfall traffic in our stores and information about the average gender, size, height, ethnicity and country/region of origin of our visitors but it is not used for, or available to, Burberry at an individual visitor level.
LOCATION INFORMATION: When you visit our Site we may seek to determine your country/region-level location in order to direct you to the appropriate domain (internet location) of the Site, based on the region you appear to be visiting the Site from. We will do so using information being transmitted publicly via the internet, including your IP address. Where you request location services provided by us, for example in order to find the nearest store to you or to provide more precise location based content, we will either: (i) do a look up against address information given by you, such as using your postcode to find our nearest store; (ii) look at the country/region in which you are in according to the unique identifier (e.g. an IP address) for your device; or (iii) if you enable location services on your mobile device, we may establish your real time location relating to the latitude and longitude of your mobile device, through GPS signals, Bluetooth or Wi-Fi connection information including MAC addresses perceived by your device, where this is available. In the case of mobile device location services, you can change your location preferences at any time by managing your device settings.
WI-FI USAGE INFORMATION: If you register for our free Wi-Fi service at our stores or events, we will collect certain information about your device, including MAC or IP address, connection date and time and the location(s) at which you connected to our Wi-Fi Service, for the purpose of providing the Wi-Fi service under our terms with you. When you connect to our Wi-Fi service you will be directed to our Site and we may collect and process information using “cookies” and other similar technologies. For more details please see “LOCATION INFORMATION” above and “COOKIES” below.
INFERENCES: We may create inferences drawn from the categories of personal information described above in order to create a profile about you to reflect your preferences, characteristics, behaviour and attitudes. We use this information to personalise and improve our services and to better understand the interests, to preferences of our key customer audiences, and to provide advertisements about goods and services likely to be of interest to you.
HOW PERSONAL INFORMATION MAY BE COLLECTED
SOURCES OF PERSONAL INFORMATION
FROM YOU. We collect personal information from you directly. We may also collect personal information from you indirectly, including through your use of our Site and/or Application and/or where we draw inferences about you (both as described above).
FROM THIRD PARTIES. We may supplement information we collect about you with marketing and demographic information which we receive from our business partners (which may include departments in which Burberry has a concession) and affiliated third-party companies, in addition to other information which is available in the public domain or which we are otherwise lawfully permitted to be provided with in order to ensure the accuracy of our records, better understand the interests and preferences of our key customer audiences and improve our service to our customers. If you don’t want us to use your personal information in this way then you can contact us at any time to ask us to stop (see “Contacting Burberry" below).
Transaction-related information may be shared with us by our business partners (which would include department stores in which Burberry has a concession) and other third parties (including law enforcement agencies and insurance providers) in order to identify and investigate suspected fraudulent transactions, for sanctions-related screening purposes and to support the security of our services, where permitted in accordance with applicable laws.
INFORMATION FROM OR ABOUT YOUR FRIENDS. We sometimes run promotions (for example on social media platforms) where you can tell us about a friend or someone else who you have a personal relationship with and two-way communications based on your shared interests, experiences, opinions and any other relevant factors (a “Friend”) who may be interested in our products, services, Site or Application. We may therefore also receive information about you from your friends and acquaintances who chose to provide it.
You may only provide us with information about your Friend with their permission. If your Friend gives you their permission to provide us with their details, then we will only use their information for that reason and not to send them any other unrelated offers. We may also mention that it was you who shared their details with us in the message we send to them.
China customers – WeChat official accounts and WeChat mini-programmes (the “WeChat Applications”)
We collect and process your WeChat openid when you access and use Burberry WeChat Applications and may also collect and process your unionid and other WeChat profile data if you authorise the Burberry WeChat Application to access this. We process this information to identify you and understand your browsing behaviour and interactions with the Burberry WeChat Application so that you can unlock user experiences and we can personalise our services to you. We will also collect information that you directly input into any Burberry WeChat Application in order to provide the services and/or perform the action requested, for example, when you book an in-store service, make a purchase and/or when you upload any content. With your consent, we will use your WeChat profile data and other information you input into any Burberry WeChat Application to send WeChat notifications or contact you in relation to a particular user experience or requested in-store services.
Cookies are small text files that are sent to or accessed from your web browser or your device’s memory. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e. when it expires) and a randomly generated unique number or another identifier We also use similar technologies (which are also called cookies for the purposes of this policy) such as web beacons (also called pixel tags or clear gifs), tracking URLs, software development kits (SDKs) and local storage on the Site and Applications. A cookie will allow us to collect information about your device, such as user settings, browsing history and activities conducted while using the Site and Applications. By linking the information in these cookies with other customer information that you provide to us, for example, when you log-in to the Site or Application, we may be able to identity the cookie information relates to you.
Please see the Cookies Policy for more information about cookies which are used on our Site and Application, including information on how you can manage your cookie choices and preferences.
ADVERTISING AND ONLINE TRACKING
We may allow third-party companies to serve ads and collect certain anonymous information when you visit our Site. These companies use information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) collected during your visits to the Site and other websites, and may use other similar identifying information and/or contact information (where lawfully permitted to do so) in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information and will use identifiers in order to recognise a user (including linking them across different devices and browsers) and to more effectively measure and provide targeted advertisements).
We may also engage Service Providers who are social media or internet search platforms so that Burberry advertisements appear on those platforms (see ‘Burberry Updates’).
COMMUNICATIONS AND INTERACTIONS WITH BURBERRY
Please note that your calls with Burberry are recorded in order to enable us to better serve our customers, for quality assurance purposes and to ensure an accurate record relevant to any transaction under our terms.
If you contact Burberry by live chat from our Site or Application, by email or phone, Burberry will collect your personal information and use this information to identify you as a customer, help with your query, process your order/reservation, deliver products and services, process payments, update our records and to generally manage your account with us under our terms with you. Burberry may also use information, including our chat history with you, to better understand the interests and preferences of our customer audiences.
When you are chatting to Burberry through live chat, the stylist or Customer Service representative that you are chatting with may be able to see the country that you are browsing from, the Burberry pages that you are navigating to and/or the products that you have viewed and/or purchased on our Site, in order to better understand your preferences and help you with your browsing.
We may also obtain personal information where you “like” us, create posts, mention us in public posts or otherwise interact with our pages on social media platforms and may in response, use this information to communicate with you, to provide relevant content via those social media platforms about our products, events and promotions where permitted to do so in accordance with applicable laws.
We may also analyse public social media posts (including where you mention us and/or interact with our content in public posts) as part of our internal marketing analysis and demographic studies, in order to better understand and monitor trends and patterns so we can improve our products and services and understand what may be of interest to you and others.
Please refer to the privacy policies of the social media platforms for information about how they collect and use your personal information.
RECEIVING AND UNSUBSCRIBING FROM BURBERRY UPDATES
We will only send you Burberry updates about our products, services and events if you want to receive them (and, if required under applicable laws, you have provided your consent). You can opt out of receiving updates (which would signify withdrawing your consent if you have provided consent), at any time (see "Unsubscribe from Burberry updates" below).
When sending you Burberry updates we will use the preferred communication method you selected, where applicable (e.g. by e-mail, post, phone or messaging services). If you have enabled push notifications on the Application or your mobile device, we will send you Burberry updates on your phone.
UNITED STATES: Note that if you are registering an account with us (whether on our Site or Application or in-store) from the United States, or making a purchase on our Site from the United States for the first time or as a guest, you will need to uncheck the marketing consent box if you do not wish to receive Burberry updates.
OTHER LOCATIONS: in certain cases, where permitted in the country that you are browsing from, or the domain (internet location) of the Site that you are browsing, please note that if you are making a purchase on our Site for the first time or as a guest, you will need to check the marketing consent box if you do not wish to receive Burberry updates.
UNSUBSCRIBE FROM BURBERRY UPDATES
If you are registered to receive Burberry updates relating to our products, services and events, and you no longer wish to receive these, you can request that we amend your preferences. You can do that either as indicated in the particular communication, e.g.by using the unsubscribe link which is included on all email updates, or by amending your preferences online (see ‘Your rights in relation to your personal information’ below). Burberry will stop sending updates in respect of which you opt out (or withdraw your consent, where applicable) within a reasonable period (as required by applicable law) and in any event within 28 days of receiving your request, in order to allow sufficient time for the change to be administered. You may opt out of receiving push notifications on your phone by changing through the settings on your mobile device or in the ‘Account Settings’ on the Application.
If you opt out of receiving Burberry updates relating to our products, services and events, we may still send you non-marketing communications such as emails about your account or purchases you have made from the Site or Application, and/or emails to request and respond to feedback relating to Burberry. We will only use your contact information where permitted to do so in accordance with applicable laws.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
Where we share your personal information with third parties (whether our Affiliated Companies or selected service providers), we will put in place contractual measures to require Affiliated Companies and Service Providers to take reasonable precautions to safeguard your personal information, as required by applicable laws.
We may share information about you with companies we have chosen to handle our order dispatch service, any delivery company that we may use from time to time and with other companies that provide support services to us, including website hosting companies, IT service providers and fraud management solution providers. We may also share your information with other companies who sell or promote Burberry products and services, (including social media and internet search platforms who you independently subscribe to), in order to provide you with an enhanced customer experience. In addition, we may also share certain limited information with companies who assist Burberry with other services, for example, in analysing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers. In each case, we will only provide these companies with the information which they need to carry out their services and they will not be permitted to use the information for other purposes. They will only be allowed to use your information in the way in which we instruct them and as permitted by applicable laws.
DIGITAL AND SOCIAL MEDIA PARTNERS
We may share information about you with digital partners, including social media companies and internet search platforms, in relation to services they provide to us (as described above). However, in some cases these partners may also process your information for their own purposes and their own privacy policies will apply.
In relation to certain Meta (formerly known as Facebook) products, including use of the Meta pixel on our Site (see ‘Cookies’ and ‘Advertising and Online Tracking’ above and our Cookies Policy for further information regarding digital advertising and cookies and similar technologies), Meta Platforms Ireland Limited (‘Meta Ireland’) acts as a joint controller of processing with Burberry within scope of the General Data Protection Regulation (“GDPR”). Meta Ireland’s ‘Controller Addendum’ applies to determine respective responsibilities between us and Meta for compliance with applicable GDPR obligations relating to the joint processing. Information about how Meta processes your information, the legal basis for the processing, and how to contact Meta to exercise your rights with regard to information stored by Meta can be found at https://www.facebook.com/about/privacy.
ORDER DISPATCH AND DELIVERY PARTNERS
FINANCIAL INSTITUTIONS, PAYMENT PROCESSING PARTNERS AND FRAUD MANAGEMENT SOLUTION PROVIDERS
Payments using our Site or Application are made through our payment solutions providers. We may also direct you to our providers’ sites if you wish to make a remote purchase when speaking to our Customer Service and/or store teams. In each case, you will be providing credit or debit card information direct to our providers who process payment details further.
When you make a payment we may share your information, including details of your transaction, with service providers who provide fraud detection and management solutions related to your transaction, and, in certain circumstances, for the purposes of carrying out sanctions screening services.
In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may disclose personal information relating to you to third parties (including in other jurisdictions) in order to conform to any requirements of law, to comply with any legal or regulatory process, for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent and detect fraud, for sanctions screening purposes and/or to protect and defend the rights and property of Burberry and other members of the Burberry group. At all times where we disclose your information for the purposes of credit risk reduction, fraud prevention and/or sanctions screening, we will take all steps reasonably necessary to help ensure that it remains secure.
BUSINESS OR PROCESS CHANGE PARTNERS
In the event that we or a part of our business undergo re-organisation or are sold or licensed to a third party, any personal information we hold about you may be transferred to that re-organised entity, licensee or third party.
OVERSEAS TRANSFERS OF DATA
The personal information that you provide through the Site and/or Applications is processed in the United Kingdom and is stored on servers in the following countries: United States of America, Ireland and Germany.
We may transfer information that we collect from you to other companies in the Burberry group, joint ventures, franchisees, licensees, other companies who promote and sell Burberry products and services and to selected service providers who perform functions on our behalf (as described above), based in countries/regions outside of the U.K. and the European Economic Area ("EEA") or your country/region of residence, where permitted by applicable laws, or if we have your consent (if so required by applicable laws) and this information may be stored and processed in such countries/regions.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
You may have the right under applicable data protection laws to ask:
- For details of the personal information we hold and process about you (including information regarding how your information may be shared),
- For a copy of your personal information,
- That we correct your personal information where it is inaccurate and/or that we complete your information where it is incomplete,
- That we limit or restrict your personal information in certain cases,
- That we delete your personal information in certain cases,
- To receive your personal information in a structured, commonly used and machine-readable format, and for Burberry to transmit that data to another controller (data portability) in certain cases
- To de-register your account if you have registered a customer account with us,
- To object and opt out of important decisions which were based solely on automated decision-making.
You can also limit or withdraw any consent you give to us at any time and may have the right under applicable law to object to us using your personal information for Burberry’s legitimate purposes. You may ask us for further information regarding withdrawal or refusal of consent and the consequences of such refusal. If you do withdraw your consent, this will not affect the lawfulness of any previous processing based upon such consent.
If you would like to exercise any of these rights in relation to the personal information we hold about you or wish to change your preferences at any time, please contact our Customer Service Team at firstname.lastname@example.org. If you have an online customer account, you can also access, amend or update your information by logging into My Account on the Site or Application and amending your details as appropriate. If you have created a customer profile in a Burberry store, you can also access, amend or update your information by visiting a store and speaking to one of our sales associates.
Please note that we may require you to verify your identity in order to process a request made to exercise your rights in relation to your personal information. If we are unable to match this information, we may ask you to provide additional identifying information, such as a copy of your passport or drivers’ license. You may designate a third party to act on your behalf provided they have appropriate written authority to do so.
If you make a request to delete your personal information, note that we may not delete all of your information. We may still process your personal information if it is necessary to do so and we are lawfully permitted. For example, in the following circumstances:
- Transactional: to complete a transaction for which the personal information was collected, provide goods or services requested by you, or perform a contract we have with you;
- Security and Maintenance: in the context of detecting and/or preventing security incidents and/or to debug or repair any errors; or
- Legal: to protect against fraud or illegal activity or to comply with applicable laws or resolve legal claims or exercise rights under applicable laws.
If you remain unhappy with a response you receive from us you can refer the matter to your local data protection supervisory authority (for example, see European authorities here).
NOTICE TO CALIFORNIA RESIDENTS/YOUR CALIFORNIA PRIVACY RIGHTS
To opt out of sharing your personal information with third parties for their direct marketing purposes, please e-mail us at email@example.com and clearly state your request, including your name, mailing address, e-mail address and phone number. Please see "Unsubscribe from Burberry updates" for additional information. You also have the right to opt out of the sale of your personal information to third parties. Please click here to find out more.
If you exercise any of your personal information rights detailed in this section, we will not discriminate against you and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services.
RETENTION AND DELETION OF PERSONAL INFORMATION
We will only keep your information as long as you remain an active customer and for a period thereafter or otherwise as required for our business operations or by applicable laws. Recordings of calls to Customer Service are retained for 6 months unless it is reasonable or legally required in the circumstances to hold such recording(s) for a longer period (for example, due to a potential dispute, complaint or ongoing customer service enquiry).
We may need to retain certain personal information even once a customer account has been closed or deleted to enforce our terms, to comply with legal or regulatory obligations, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes. We may also retain a record of any stated objection by you to receiving Burberry updates for the purpose of ensuring we can continue to respect your wishes and not contact you further. Your personal information will be deleted or destroyed in a manner that cannot be restored or reproduced.
SECURITY AND THIRD PARTY LINKS
We take reasonable steps to protect your personal information against unauthorized or accidental access, processing, erasure, loss or use. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us and any transmission is at your own risk.
We do however use strict procedures and security features to try to prevent unauthorised access wherever possible. Personal information may be accessed by persons within our organization, or our third-party service partners, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law.
Personal information provided to Burberry via the Site, Application and online credit card transactions are transmitted through a secure server using Secure Socket Layering (SSL), encryption technology. When the letters "http" in the URL change to "https," the "s" indicates you are in a secure area employing SSL; also, your browser may give you a pop-up message that you are about to enter a secure area or display a padlock image. The Site and the Application use this encryption technology to protect your information during data transport. SSL encrypts ordering information such as your name, address and credit card number. Our customer service centre and stores also operate over a private, secure network. Please note that e-mail is not encrypted and is not considered to be a secure means of transmitting credit card information.
IN-APPLICATION VIRTUAL ACTIVATION
When you choose to (and your device enables you to, subject to your device model and settings) virtually ‘try on’ Burberry products such as glasses, using the in-Application virtual activation technology (“Virtual Activation”), the Application will request access to your device’s camera. Where you permit the Application to access your device’s camera, the Virtual Activation will access the image of your face through your device’s front camera, and, using third party software, detect the co-ordinates of your facial features and measure these by distance. These measurements will result in the formation of a generic face model within the Application to match the dimensions, shape, and current expression of the detected face. This model is then used as the basis for overlaying content that follows the shape of your face (for example, overlaying an image of glasses or beauty products). Neither the Application nor Burberry will be able to uniquely identify you based on this data and neither Burberry, the Application, nor Burberry’s third party Service Providers shall capture or otherwise collect or record any personal information from this experience, including any images of you, or the co-ordinates. The data generated by the Virtual Activation will be stored locally on your device and once you have finished with the experience and exited the Application, the data will be deleted. Where you are offered the option to have this data emailed to you, your email address will be stored temporarily and deleted after the data has been sent to you.
The use of the Virtual Activation is voluntary and you will have the option to agree to or deny access to your device’s camera in order to use the Virtual Activation. Unless you choose to activate the Virtual Activation and permit access to your device’s camera, the Application will not have access to your device’s camera.
If you are in the EU, you can contact the Burberry EU Representative at EUDPrepresentative@burberry.com or Burberry Italy srl, Via Manzoni, n.20, Milan 20121, Italy.
South Korea Local Privacy Representative
Burberry Limited’s Local Privacy Representative, for the purposes of the South Korea Personal Information Protection Act, is Burberry Korea Limited with its representative Claudia Kim, registered address details (Cheongdam-dong) 459, Dosan-daero, Gangnam-gu, Seoul, Republic of Korea, email address firstname.lastname@example.org and telephone number 0079844341257.
Brazil Chief of Data Treatment (encarregado)
BURBERRY BRASIL - COMÉRCIO DE ARTIGOS DE VESTUÁRIO E ACESSÓRIOS LTDA., a subsidiary of Burberry Limited, has appointed a Chief of Data Treatment, for the purposes of the General Data Protection Law (LGPD), with office at Rua do Rocio, 350 3º Andar, Vila Olimpia, SÃO PAULO – SP, CEP 04552-000, Brazil and telephone number +55 11 3638-3431. The Chief of Data Treatment can also be contacted via DPO@burberry.com.