1. WHAT YOU NEED TO KNOW AND WHO WE ARE

Purpose of this Privacy policy

This Privacy Policy gives you information about how Bags of Luxury collects and uses your personal data as a customer. This principally relates to your use of our website, whether you are using it to sign up to our mailing list, make an enquiry, purchase a product or service, or otherwise.

Bags of Luxury is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this Privacy Policy.

Finally, our website is not intended for children and we do not knowingly collect data relating to children.

Who we are

We are Maia Luxury Limited (trading as Bags of Luxury) (collectively referred to as "Bags of Luxury", "we", "us" or "our" in this Privacy Policy) and are responsible for your personal data. We are registered in England & Wales under registration number 07071536. Our registered address is 4 Old Park Lane, Mayfair, London, United Kingdom, W1K 1QW.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK data protection laws If you are located in the European Economic Area (EEA), we are also subject to the EU General Data Protection Regulation (EU GDPR) and other local laws in relation services we offer to individuals in the EEA.

2 . WHAT WE COLLECT

"Personal data" means any information about an individual from which that person can be identified. It does not include anonymised data, that can no longer be associated with you.

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

• Identity Data includes first name, last name, any previous names, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card 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, device ID 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 interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share "Aggregated data" such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We do not collect any "Special Category Data" about you. Special Category Data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and  information about your health, genetic or biometric data. Nor do we collect any information about criminal convictions and offences.

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 our products or services). In this case, we may have to cancel a product delivery or service you have with us (but we will notify you if this is the case at the time).

3. HOW WE COLLECT

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or give us feedback or contact us.
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the cookies section below for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below: Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services, including our identity verification service providers (which may be based outside of the UK).
• Technical Data is collected from the following parties:
  • analytics providers;
  • advertising networks; and
  • search information providers.
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services, including our identity verification service providers (which may be based outside of the UK).

4. WHAT WE DO WITH YOUR DATA

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: We may use your personal data where it is necessary to perform a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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 the various categories of 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.







Direct marketing
We may use your personal data to send you updates (by email, text or Whatsapp message, telephone or post) about our products and services, including newsletters, exclusive offers, promotions or information about new products.

You will receive marketing communications from us if you expressly opted-in to receive them (in which case we rely on your consent) or if you have purchased goods or services from us or requested specific details about our products and services and you have not opted out of receiving the marketing (in which case we rely on our legitimate interests).

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing
We will not share your personal data with any third party for their own direct marketing purposes without your express consent.

Opting out of marketing
You can ask to stop sending you marketing communications at any time by selecting the unsubscribe option within marketing emails, or by texting "STOP" via WhatsApp in response to any marketing communications which we send youor by emailing us at info@bagsofluxury.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

5. HOW WE USE 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.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• 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 your interests.

The table below provides more information on the cookies we use and why.



Please note that the following 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:

• Stripe — View Stripe Privacy Policy
• DHL — Link to DHL Privacy Policy
• Verdict — Link to Verdict Privacy Policy

To deactivate the use of third party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies [insert to consent management].

You can set your browser to accept or reject certain cookies or, if you prefer, you can set your browser to alert you each time a cookie is detected. Previous cookies that have been stored on your device can also be deleted. However, if you block our cookies or you subsequently delete a cookie that has been placed on your device, it will not be possible for you to use our website effectively as our systems rely on cookies to identify you as the user.

6. WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with the following external service providers:

• Third parties we use to help provide our products and/or services to you, such as:
  • Stripe, Apple Pay, Shop Pay our payment and billing service providers;
  • Google Analytics our data analytics provider;
  • DHL & Addison Lee our delivery service provider; and
  • Verdict / Real ID our third party identification verification service provider.
• Other third parties we use to help us run our business, such as:
  • Gmail our email provider; and
  • Xero our accounting software provider.

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.

We may also share personal data with the following categories of third parties:

• professional advisers including lawyers, bankers, auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others. This includes exchanging information with: (a) the police or other investigatory or law enforcement authorities; and (b) companies and organisations involved in fraud protection and credit risk reduction; and/or
• 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. Usually, data will be anonymised but this may not always be possible. The recipient of the data will be bound by confidentiality obligations. 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 Policy.

7. TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE UK

To provide our products and services to you, it is sometimes necessary for us to share your personal data outside the UK or EEA, for example, with our service providers that are either located outside the UK or that transfer personal data outside of the UK and EEA.

Transfers of personal data outside of the UK are subject to special rules under UK data protection law. This is because non-UK countries do not have the same data protection laws as the UK.

Transfers of personal data outside of the EEA are subject to special rules under EU data protection law. This is because non-EEA countries do not have the same data protection laws as the EEA.

We will ensure that any transfer of personal data outside of the UK or EEA as applicable, complies with data protection laws and that all personal data will be secure.

As a result, when we transfer personal data outside of the UK or EEA, we will ensure that the transfer complies with data protection laws by following one of the below steps:

• confirming that the recipient is located in a country which has been recognised as having an adequate level of protection for personal data;
• putting in place safeguards (such as approved standard contractual clauses) so that you have enforceable rights and effective legal remedies; or
• confirming that a specific exception applies under data protection law.

For more information about our international transfers, please contact us using the information below.

8. 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.

Please note that, notwithstanding the steps we take, the transmission of information via the internet can never be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site.

9. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other 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.

In some circumstances we will 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.

10. YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us using the details set out in the “Contact Details” section. A summary of the rights you have is set out below:

• Access: You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction: You have the right to 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.
• Erasure: You have the right to request we erase 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.
• To object: You have the right to object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Opting-out of Marketing: You can ask us or third-parties to stop sending you marketing communications at any time by (a) by using the “unsubscribe” link at the bottom of any marketing communications which we send to you; (b) text “STOP” via WhatsApp in response to any marketing communications which we send you or (c) by contacting us at any time using the details set out in the “Contact Details” section.
• Data portability: You have the right to request we transfer 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.
• Withdrawing consent: You have the right to withdraw your consent to processing where we are relying on that consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Processing Restriction: You have the right to request we restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• 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
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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 could 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 could 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.

11. CONTACT DETAILS

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us by emailing info@bagsofluxury.com.

12. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), being the UK regulator for data protection issues (www.ico.org.uk), or any relevant European data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

13. CHANGES TO THE PRIVACY POLICY OR YOUR PERSONAL DATA

We keep our Privacy Policy under regular review. This version was last updated on April 2024 .

If we change our privacy policy from time to time, we will post the details of any changes on our website. We may also take reasonable steps to notify you if such changes affect how your personal data is processed. Historic versions can be obtained by contacting us.

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, for example a new address or email address.

14. 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 policy of every website you visit.