Privacy Policy

Clarke Bennett ("Clarke Bennett", "we", "us" or "our") operates this online store and website, including all related content, features, products and services (the "Services"). This Privacy Policy explains what personal information we collect when you visit our website, place an order, or otherwise communicate with us, why we collect it, how we use and share it, how long we keep it, and what rights you have.

Because we are established in the European Union (the Netherlands), this Privacy Policy is written to comply with the EU General Data Protection Regulation (GDPR). It also applies to customers outside the EU, including in Canada. Our store is hosted on the Shopify platform, which helps us provide the Services to you.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Services.

1. Who we are (data controller)

The controller responsible for your personal information is:

Clarke Bennett
Email: support@clarkebennett.com

The controller is the party that decides why and how your personal information is processed. If you have any questions about this Privacy Policy or wish to exercise your rights, contact us at the email address above.

2. Personal information we collect

When we say "personal information", we mean information that identifies you or can reasonably be linked to you. We may collect the following categories, depending on how you use the Services:

• Contact and order details: your name, email address, telephone number, shipping address and billing address, and the contents of your order.
• Payment information: your payment is processed directly by our payment provider and/or the Shopify platform. We do not store full card numbers ourselves; we receive confirmation of payment and limited transaction details (such as form of payment and order total).
• Transaction information: items you view, add to your cart, purchase, return, exchange or cancel, and your order history.
• Communications: the information you provide when you contact us, for example a customer-support email.
• Newsletter data: if you sign up, your email address and a record of your consent (date and method).
• Technical and usage information: information collected automatically by the platform, our payment provider and — where you have consented to advertising cookies — our advertising tools, such as your IP address, device and browser type, and basic interaction data needed to keep the site working, secure, and to measure our advertising.

We do not knowingly collect more data than we need to run our store and fulfil your orders.

3. Where we collect your information from

• Directly from you — when you place an order, sign up for our newsletter, or contact us.
• Automatically through the Services — from your device and through cookies and similar technologies when you visit the site.
• From our service providers — such as our e-commerce platform, payment provider and shipping carriers, who collect or process information on our behalf.

4. How we use your information and our legal basis

Under the GDPR we must have a legal basis for each use of your data. We rely on the following:

• To provide the Services and fulfil your order — taking payment, arranging shipping, sending order and delivery updates, and handling returns, exchanges and refunds. Legal basis: performance of a contract with you (Art. 6(1)(b) GDPR).
• To communicate with you and provide customer support. Legal basis: performance of a contract and our legitimate interest in supporting our customers (Art. 6(1)(b) and (f) GDPR).
• To keep the Services secure and prevent fraud and abuse. Legal basis: our legitimate interest in protecting our business and customers (Art. 6(1)(f) GDPR).
• To comply with legal obligations, such as tax, accounting and consumer-law record-keeping. Legal basis: compliance with a legal obligation (Art. 6(1)(c) GDPR).
• To send our newsletter, where you have signed up. Legal basis: your consent (Art. 6(1)(a) GDPR).
• To measure and improve our advertising and show you relevant ads, where you have consented to advertising cookies (see Section 10). Legal basis: your consent (Art. 6(1)(a) GDPR).

5. Newsletter and marketing (double opt-in)

We send marketing emails only to people who have actively signed up for them. We use a double opt-in process: after you enter your email address, we send you a confirmation email, and you are added to our newsletter only after you click the confirmation link. We keep a record of your consent (such as the date of confirmation).

You can withdraw your consent at any time by clicking the "unsubscribe" link in any newsletter, or by emailing support@clarkebennett.com. Withdrawing consent does not affect the lawfulness of emails sent before you unsubscribed. We do not sell your email address.

6. How we share your information

We do not sell your personal information. We share it only with parties that help us operate our store, and only to the extent necessary:

• Our e-commerce platform (Shopify), which hosts our website and processes orders on our behalf.
• Our payment provider (such as Shopify Payments and/or the payment methods shown at checkout), to take and verify payment.
• Our overseas warehouse and fulfilment partner, located outside the EEA, who receives the name and shipping address needed to pack and ship your order directly to you.
• Shipping carriers and postal services, to deliver your order and provide tracking.
• Advertising partners (such as Meta), where you have consented to advertising cookies, to measure and deliver our advertising (see Section 10).
• Professional advisers and authorities, where we are legally required to disclose data (for example tax authorities or in response to valid legal requests), or to establish, exercise or defend legal claims.
• In a business transaction, such as a merger, acquisition or insolvency, your information may be transferred to a successor or buyer, subject to this Privacy Policy.

Each party may use your data only to provide its service to us, or as required by law.

7. Our platform (Shopify)

Our Services are hosted by Shopify, which collects and processes information about your use of the Services in order to host and operate our store. Information you submit may be transmitted to and stored by Shopify, including in countries other than the one you live in. For information about how Shopify processes personal information and the rights you may have, see Shopify's consumer privacy policy at privacy.shopify.com.

8. International transfers (outside the EEA)

We may transfer, store and process your personal information outside the European Economic Area (EEA), including by our platform and — importantly — through our overseas warehouse and fulfilment partner, who needs your name and delivery address to ship your order to you.

Some countries outside the EEA are not covered by an EU "adequacy decision". We rely on the following grounds and safeguards for transfers outside the EEA:

• The transfer of your delivery details to our overseas warehouse is necessary to perform our contract with you — that is, to ship the product you ordered (Art. 49(1)(b) GDPR); and
• Where applicable, we and our partners put in place appropriate safeguards such as the European Commission's Standard Contractual Clauses (SCCs), unless the transfer is to a country recognised as providing an adequate level of protection.

We limit the data sent abroad to what is strictly necessary to deliver your order. For more information about the safeguards in place, contact support@clarkebennett.com.

9. Cookies

Our website and payment provider use cookies and similar technologies. Some are strictly necessary to make the site function and process your order securely (for example, remembering the contents of your cart). Others, such as advertising cookies, are non-essential and are only placed with your consent, which you can give or refuse through the cookie banner or settings shown on our site. You can also manage or delete cookies in your browser settings; if you block cookies, some features of the site may not work properly.

10. Advertising and the Meta Pixel

If you have consented to advertising cookies, we use the Meta Pixel, a tool provided by Meta Platforms Ireland Ltd., to measure the effectiveness of our advertising and to show you relevant ads on Meta's platforms (such as Facebook and Instagram). The pixel allows us to understand actions you take on our site after seeing or clicking one of our ads, and to build audiences for future campaigns.

This processing takes place only if you accept advertising cookies through our cookie banner, and you can withdraw your consent at any time through the cookie settings on our site. Legal basis: your consent (Art. 6(1)(a) GDPR).

Meta may process this data as an independent controller and may transfer it outside the EEA under appropriate safeguards, such as Standard Contractual Clauses. For more information about how Meta uses this data, see Meta's Privacy Policy.

11. How long we keep your information

We keep personal information only for as long as necessary for the purposes described above:

• Order and transaction data: for as long as needed to fulfil your order and handle returns, and afterwards for the period required by tax and accounting law (in the Netherlands generally up to 7 years).
• Customer-service communications: for as long as needed to resolve your request and a reasonable period afterwards.
• Newsletter data: until you unsubscribe or withdraw your consent.

When data is no longer needed and there is no legal reason to keep it, we delete or anonymise it.

12. Your rights

Under the GDPR you have the right to:

• access the personal information we hold about you (Art. 15);
• request rectification of inaccurate or incomplete data (Art. 16);
• request erasure of your data ("right to be forgotten") (Art. 17);
• request restriction of processing (Art. 18);
• data portability — receive your data in a structured, machine-readable format (Art. 20);
• object to processing based on our legitimate interests, and to direct marketing at any time (Art. 21);
• withdraw consent at any time where we rely on it, such as for the newsletter or advertising cookies (Art. 7(3)).

These rights are not absolute and may apply only in certain circumstances; in some cases we may decline a request where the law allows, and we may need to verify your identity first. To exercise any right, email support@clarkebennett.com. We will respond within the period required by law (generally within one month).

If you believe we have not handled your data properly, you have the right to lodge a complaint with a supervisory authority. In the Netherlands this is the Autoriteit Persoonsgegevens (www.autoriteitpersoonsgegevens.nl). You will not be treated unfairly for exercising any of your rights.

13. Data security

We take reasonable technical and organisational measures to protect your personal information against loss, misuse and unauthorised access, and payment processing is handled by PCI-compliant providers. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security. Please do not send sensitive information to us through unsecured channels.

14. Third-party links

Our Services may link to websites operated by third parties. We are not responsible for the privacy practices or content of those sites. We encourage you to review their privacy policies before providing them with your information.

15. Children

Our website and products are not directed at children under 16, and we do not knowingly collect personal information from them. If you believe a child has provided us with personal information, contact us and we will delete it.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or operational reasons. When we do, we will post the updated version on this page. We encourage you to review it periodically.

17. Contact

For any question or request regarding this Privacy Policy or your personal information, contact:

Clarke Bennett Email:
support@clarkebennett.com