We view the security of our customer’s data as paramount. Any personal data you provide to us and from which you can be identified is stored securely and confidentially and is processed in accordance with applicable legislation and this privacy policy, which sets out what personal data we collect about you when you interact with us and how we use your data.

We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of your personal data, including encrypting your information to applicable industry standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

So, you only need to look in one place to find out all you need to know about how the Group collects and processes your personal information, this policy covers our Website (being any website operated by NEW SENGER TRADING LTD), our App (being any app operated by NEW SENGER TRADING LTD. or a Group company), our stores and any correspondence you have with the Group in relation to our retail offering.

Any changes we make to this policy will be reflected on this page and notified to you by email, where appropriate.

Who we are?

As set out in our terms and conditions, this Website and the App are operated by NEW SENGER TRADING LTD, whose registered address is 5 HARVEY ROAD LONDON N8 9PD, UK

NEW SENGER TRADING LTD is the data controller in respect of information collected when you browse this Website and the App and purchase our products. If you have any queries regarding our use of personal information or this privacy policy, you can write to Data Protection: 5 HARVEY ROAD LONDON N8 9PD, UK or email to support@clotoral.com.

Information we may hold about you

When you register to use our Website or App, purchase a product, register to receive our emails, apply for a job, register for our Recognition Loyalty Programme, enter a competition or promotion run by the Group or contact us, personal data you provide, such as your name, date of birth, contact details (including social media accounts), telephone number, transaction history, log in and payment information, will be collected.

When you browse our Website or App, whether or not you are registered, purchase a product, register to receive our emails, receive and open or click our emails, register for our Recognition Loyalty Programme, or make a job application, we and our partner advertising networks, advertisers and advertising affiliates (Third Party Advertisers), will collect user information such as your location, language, assumed gender, IP address, when you visited our Website or App, how you arrived on our Website or App, where you visit after our Website or App, the pages you visited, how long you spend browsing individual pages on our Website or App, any products you have viewed, purchased, or put in your basket, and the browser (where applicable) and device you used to access our Website or App.

In our premises, including our stores, we use CCTV and Facial Recognition Technology to monitor and record images for the purposes of security and health and safety, and store the images centrally. You can find further information on the Facial Recognition Technology we use and how your data is handled on www.facewatch.co.uk/privacy 

In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes. Calls may also be monitored without your consent in the following circumstances: to provide evidence of a business transaction; to prevent or detect a crime; to ensure that the Group complies with regulatory procedures; to see that quality standards or targets are being met; and to secure the effective operation of the telecom system.

How we may use your personal data

We may use your personal data in the following ways:

  • to fulfil your order – we require your identification, contact and payment information to enable the relevant Group company to enter into a contract with you and are unable to do so without this information (please note that your details may need to be passed to another company within the Group and/or a third party, such as one of our couriers or one of their customs clearance agents, in order for them to supply or deliver the product that you ordered and certain products will be processed and delivered direct from some of our supplier partners either as part of our drop ship model or market place offering (“Direct Supply”). We may retain your details for a reasonable period of time after you have completed the transaction in order to fulfil any contractual obligations such as refunds, guarantees etc and to meet any legal obligations for the retention of transactional data).
  • to tell you about similar products and services, or products and services that you ask us to send you information about, by email, post, mobile, telephone and/or through other digital means (depending on your stated preferences) including social media platforms;
  • to provide you with services you request from us including, the sale and/or distribution of products made available to you through Direct Supply;
  • to register you on the Website or App (where this involves setting you up with an account, we will use your personal information to maintain and update your account (e.g. such as a change of address or change in your marketing preferences);
  • to administer our Website and App;
  • to analyse, and improve, the use of our Website, App and retail offering, including how you move around our Website, App or retail stores;
  • to administer any competition run by the Group. Please refer to the specific terms and conditions for each competition;
  • to measure and analyse our advertising;
  • to make suggestions and recommendations to you, other users of our Website and App, and users of the services of our Third Party Advertisers about products or services that may interest you or them;
  • to keep in touch with you regarding your marketing preferences;
  • to keep our Website, App and network safe and secure;
  • to process payments, and detect and prevent fraudulent transactions and/or any other criminal activity (we may pass your details to a third party to carry out these functions); and
  • to assess and process your job application.

We process this data where you have given us consent to use it, where it is necessary to perform our contract, to take steps at your request prior to entering into a contract, where required by law or in pursuit of our legitimate interests where these are not overridden by your rights and interests, such as to provide appropriate marketing and to maintain our services.

How long we keep your information

We will not keep your personal information for any purpose(s) for longer than is necessary and we will only retain the relevant personal information that is necessary in relation to the purpose.

We will retain the personal information you provided on registering an account on our Website or App so long as that account remains in existence.

In the case of any contact you may have with our customer services department, we will retain those details for as long as is necessary to resolve your query and for a short period after the query is closed.

On making a purchase through our Website or App, we will retain certain limited personal information such as your name, email address and postal address until you ask us to update or delete those details for the purpose of reporting new and existing users to our affiliate advertisers. We retain transaction information for the longer of as long as you hold a Recognition Loyalty Programme Account or required by law. We will retain information regarding your website browsing history for a similar period.

If we are legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also retain some of your personal information for a limited period of time, even after you have closed your account.

We retain CCTV recordings centrally for up to 30 days, and for a longer period if they are relevant to an incident, complaint, investigation or legal proceedings. You can find information on the retention of any data collected via the Facial Recognition Technology we use on www.facewatch.co.uk/privacy

We will retain information relating to any job application for as long as it takes to process your application and, if it is unsuccessful, for an additional period of around 6 months. If your application is successful, your information will be retained in accordance with our staff privacy policy.

We will retain your information for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place.

How we might share your personal data

We may share your personal data with other companies in the Group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may also share your personal data with carefully selected third parties who assist us in providing you with products, advertisements and services. This will include the following types of third party:

  • Our professional advisers, including, without limitation, our insurers;
  • Our suppliers, business partners and sub-contractors;
  • Our Third Party Advertisers;
  • Our Direct Supply partners, who will provide certain products/services directly to you and will require your personal data to process and deliver your order (including warehousing, order packing, delivery, returns and general administration);
  • Our Direct Supply middleware providers, who operate the platform through which the order you place on this Website is shared with the relevant Direct Supply partner; and,
  • Search engine and web analytics providers.

We will only share your personal data with third parties where it is necessary for them to provide us with the services we need.

In the event that we were to sell our business or assets, we may disclose your personal data to any prospective/actual purchaser and/or their advisers. We may also disclose your personal data where we are subject to a legal obligation to do so, in connection with the prevention or detection of crime, for the purpose of establishing, exercising or defending our legal rights, or where we consider that we receive a valid request for disclosure. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

You should be aware that if we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information or any other information we obtain about you, we are entitled do so.

Our Website and App may, from time to time, contain links to and from the websites of third parties or utilise a piece of software or a service which requires your personal information be shared with a third party. Please note that these third-party websites/providers have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites. 

Where we store your personal data

The information that we collect from you may be transferred to, and stored outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, third party providers, including, Direct Supply partners and middleware providers. Where we do so, the third country’s data protection laws will have been approved as adequate by the European Commission, or other applicable safeguards are in place

Your rights

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you, by accessing the customer preference centre or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, with some exceptions, to ask us to provide a copy of any personal data we hold about you. If you chose to exercise this right, then in certain circumstances any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data if you withdraw your consent, it is no longer necessary for us to use your personal data, you object to the use of your personal data and we don’t have a good reason to continue to use it, or we haven’t handled your personal data in accordance with our obligations.

To exercise these rights, we need to be suitably satisfied of your identity and so may request you provide identification documents or confirm other details we may hold about your (such as a recent delivery reference or address).

If you have any queries or concerns regarding how we use your personal data, please write to Data Protection, 5 HARVEY ROAD LONDON N8 9PD, UK or email to support@clotoral.com. If you are not happy with our response, you can contact the Information Commissioner’s Office: https://ico.org.uk

Cookie Policy

This policy explains what cookies are, how we use them and how you can switch them off.

What are Cookies and other tracking technologies?

Cookies are small files which are stored on your internet browsing device (e.g computer, tablet or phone) when you visit one of our websites, use our app, receive and open or click into our emails or see one of our adverts elsewhere on the internet. Cookies don’t store personal details such as your credit card details, your name or your date of birth. They play an important role in helping us to enhance the usability and performance of our websites and your experience using them. Some cookies are also essential to enable you to move around our website and use its features. Other tracking technologies, like web beacons, clear GIFs, page tags and web bugs, are used to understand how people are using our services and to target advertising.

As well as the cookies we use on our website, we use cookies and similar technologies in our emails. These help us to understand whether you’ve opened an email and how you’ve interacted with it. If you don’t want to accept cookies in emails, you can set your browser to restrict or reject cookies, or you can close the email before downloading any images or clicking on any links.

When you first use our Website, we will ask you to consent to our use of cookies and give you information about them. If you continue to browse our website and don’t take steps to change your preferences, you are consenting to our use of cookies.

What types of Cookies do we use?

Our Website uses session cookies and persistent cookies. Session cookies operate from the moment you enter the website until the moment you leave. Once you log off, session cookies are deleted. Persistent cookies will not be deleted after each session.

Strictly necessary cookies are essential to our website. If these are disabled, your experience on our website may be interrupted and you may not be able to use a shopping basket or make payment. Performance cookies collect anonymous data about visitors. We use the data to improve your future experience and identify issues that our users may be experiencing.

Functionality cookies customise the look and appearance of our Website. For example, a functionality cookie will remember your username and language preferences next time you visit.

Targeting or advertising cookies deliver advertisements which are tailored to your web activity. A targeting cookie tracks what you click on whilst on our website and may share details of what you click on with other organisations (such as advertisers). These cookies can also help us to measure the effectiveness of an advertising campaign.

Third party cookies may be used on our website by approved organisations to provide services on our website.

A list of all the cookies that we, our advertising network and technology partners use can be found in our cookie list details below.

How we use Cookies and other tracking technologies

We use a combination of our own cookies, third party cookies and other tracking technologies to enhance your browsing experience and to enable our website and app to function efficiently. We use cookies to:

  • enable you to set up an account, place orders and make payments
  • remember items you place into your shopping basket
  • remember items you have been looking at so that you can quickly and easily go back to an item you looked at previously
  • enhance and personalise your shopping experience

The default setting on your web browser is to prohibit cookies, but you may have changed this during the installation process. You can also choose which cookies the Group places on your computer when you access our website and can manage this in our preference centre. Further information on cookies, including instructions on how to amend your browser settings to turn off cookies, is available widely online. However, if you disable or delete certain cookies you may not be able to shop or access important parts of our website.

Cookie List:

Cookie/tracking technology nameCategory [strictly necessary, performance, functionality, third party]Purpose
Criteo, Facebook and GoogleThird partyThese partners use cookies to provide you with personalised adverts when you visit other selected websites. Banner advertising appears on websites which we are affiliated with and we use the information we have learned from cookies to tailor this advertising to things we think you will like, based on your browsing history on our website.
Affiliate Window and GoogleThird PartySometimes we’ll advertise on third party websites. Each individual advertiser uses its own tracking cookies and the data taken is not confidential or interchangeable.
User ReplayThird PartyThese cookies enable us to track individual customer journeys on our website (excluding any checkout pages) which are used to identify and fix bugs to make the online experience better for customers.
Google AnalyticsThird PartyGoogle Analytics uses these cookies to discover when you first visited our site, how often you come back and how long you spend shopping. The information stored by these cookies can be seen only by the relevant teams at NEW SENGER TRADING LTD and Google and never shows any confidential information, we also use Google Analytics to track the performance of our website. For more information on the use of Google Analytics, please see:Google’s Privacy & TermsSafeguarding your data
Facebook, Twitter, Instagram and YouTubeThird PartySocial sharing, social login and other social media services we offer are run by other companies. These companies may drop cookies on your computer when you use them on our site or if you are already logged in to them.
Crazy EggThird PartyThese cookies allow our partner CrazyEgg to collect anonymous usage data which we use to make our website easier to use.
ASPXANONYMOUS, [Website]_AuthenticationCookie, um_IsMobile, X-SD-URep, StateKey, .DOTNETNUKE, authentication, mp__utmb, mp__utma, mp__utmc, mp__utmz, X-Origin-CookieStrictly NecessaryThese cookies are used to allow you to add to your basket and place orders and allow us to recognise registered customers
AdvertCookie, ChosenSite, CountryRedirectCheckIsDone, newsletterPoppedUp, acceptedCookies, [Website]_AnonymousUserCurrencyFunctionalityThese cookies are used to remember your selected preferences and what messages you have already seen so they aren’t shown again.
ak_bmsc, TS01a19d95FunctionalityThese cookies are used to protect our website against bots.

User Generated Content Addendum 

This Addendum reflects the introduction of User Generated Content data processing, created by you and posted to our social media channels, websites or apps.

This Addendum will inform you as to how we collect, process and use your personal data in connection with the Use of User Submitted Content Termsand in compliance with all applicable legislation.

Information we may hold about you:

Social Media Interaction and User Generated Content

Where you provide your images to us via social media platforms, including where you tag us, and when you interact with us on our social media channels . We will be using the images you provide for our campaign communications, marketing and promotional activities. We will obtain rights to your image with your consent and through a licence agreement in the form of our Use of User Submitted Content Terms . By submitting your images via social media platforms to us, by our invitation or at your own initiative, you will agree for us to use your images as described in the licence agreement. You can request a copy of your User Content or request for it to be removed from NEW SENGER TRADING LTD or Frasers Channels by sending a Data Subject request to support@clotoral.com 

How we may use your personal data

  • To use for our own marketing and promotional activities. Please refer to the Use of User Submitted content terms. 

 How long we keep your information

We will not keep your personal information for any purpose(s) for longer than is necessary and we will only retain the relevant personal information that is necessary in relation to the purpose, and for no longer than 2 years.

Contact us

Tel: (+44)7361630374

Email:support@clotoral.com

Address:5 HARVEY ROAD LONDON N8 9PD, UK