We may update this Privacy Policy occasionally, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Website, update the "Last Updated" date, and take any other steps required by applicable law.

To provide the Services, we collect personal information about you from various sources as outlined below. The information we collect and use varies depending on how you interact with us. In addition to the specific uses described below, we may use the information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and protect or defend the Services, our rights, and the rights of our users or others.

The types of personal information we collect about you depend on how you interact with our website and how you use our Services. When we use the term "personal information," we are referring to information that identifies you, relates to you, describes you, or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

The information you provide to us directly through our Services may include:

• Contact details, including your name, address, phone number, and email.
• Order information, including your name, billing address, shipping address, payment confirmation, email address, and phone number.
• Account information, including your username, password, security questions, and other information used for account security purposes.
• Customer support information, including any information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to provide certain information directly to us. You may choose not to provide this information, but this may prevent you from using or accessing those features.

We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do so, we may use cookies, pixels, and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Website and your account, including device information, browser information, network connection information, your IP address, and other information related to your interaction with the Services.

Finally, we may obtain information about you from third parties, including suppliers and service providers who may collect information on our behalf, such as:

• Companies that support our Website and Services, like Shopify.
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment, fulfill your orders, and provide you with the products or services you requested, in order to execute the contract we have with you.

When you visit our Website, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software development kits, third-party libraries, and cookies.

Any information we obtain from third parties will be handled in accordance with this Privacy Policy. See also the section below, Third-Party Websites and Links.

• Providing products and services. We use your personal information to provide you with the Services, in order to fulfill the contract we have with you, including processing your payments, fulfilling your orders, sending you notifications related to your account, purchases, returns, exchanges, or other transactions, creating, maintaining, and managing your account, organizing shipping, facilitating any returns and exchanges, and other features and functionalities related to your account. We may also enhance your shopping experience by allowing Shopify to link your account with other Shopify services you may choose to use. In this case, Shopify will handle your information as set out in its Privacy Policy and the Consumer Privacy Policy.
• Marketing and advertising. We may use your personal information for marketing and promotional purposes, such as sending marketing communications, advertisements, and promotional communications via email, text messages, or postal mail, and showing you ads for products or services. This may include using your personal information to better tailor the Services and advertising on our website and other websites. If you are a resident of the EEA, the legal basis for these data processing activities is our legitimate interest in selling our products, in accordance with Art. 6 (1) (f) of the GDPR.
• Security and fraud prevention. We use your personal information to detect, investigate, or take action regarding potential fraudulent, illegal, or malicious activities. If you choose to use the Services and register an account, you are responsible for keeping your account credentials secure. We strongly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are a resident of the EEA, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, in accordance with Art. 6 (1) (f) of the GDPR.
• Communicating with you and improving services. We use your personal information to provide customer support and improve our Services. This is in our legitimate interest, so we can respond to you, provide effective services, and maintain our business relationship with you, in accordance with Art. 6 (1) (f) of the GDPR.

As with many websites, we also use cookies. For specific information about the cookies we use related to powering our store with Shopify, please refer to https://www.shopify.com/legal/cookies. We use cookies to power and improve our website and Services (including to remember your actions and preferences), to perform analytics, and to better understand your interaction with the Services (in our legitimate interest to manage, improve, and optimize the Services). We may also allow third parties and service providers to use cookies on our website to better tailor services, products, and advertising on our website and other websites.

Most browsers automatically accept cookies by default, but you can choose to configure your browser to remove or reject cookies through the respective controls. Please note that removing or blocking cookies may negatively impact your user experience and may cause some Services, including certain features and general functionalities, to function improperly or become unavailable. Additionally, blocking cookies may not fully prevent how we share information with third parties, such as our advertising partners.

In certain circumstances, we may disclose your personal information to third parties for the purposes of contract fulfillment, legitimate interests, and other reasons subject to this Privacy Policy. Such circumstances may include:

• With suppliers or other third parties that provide services on our behalf (e.g., IT management, payment processing, data analysis, customer support, cloud storage, shipping, and fulfillment).
• With business and marketing partners to provide you with services and advertising. Our business and marketing partners will use your information in accordance with their own privacy notices.
• When you direct, request, or otherwise consent to the disclosure of certain information to third parties, for example, to send you products or through your use of social media widgets or login integrations, with your consent.
• With our affiliates or otherwise within our corporate group, in our legitimate interest to manage a successful business.
• In connection with a business transaction, such as a merger or bankruptcy, to comply with applicable legal obligations (including responding to subpoenas, search warrants, and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We disclose the following categories of personal information and sensitive personal information about users for the purposes outlined above in "How we collect and use your personal information" and "How we disclose personal information":

Category

• Identifiers, such as basic contact data and certain order and account information
  Commercial information, such as order information, purchase information, and customer support information
• Internet or other similar network activity, such as usage data
• Geolocation data, such as locations determined by an IP address or other technical measures

Categories of recipients

• Suppliers and third parties that provide services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners, and data analysis providers)
• Business and marketing partners
• Affiliates

We do not use or disclose sensitive personal information without your consent or for the purpose of inferring characteristics about you. With your consent, we share personal information for the purpose of participating in advertising and marketing activities as follows.

Our website may provide links to websites or other online platforms operated by third parties. If you follow links to websites not affiliated with or controlled by us, you should review their respective privacy and security policies, as well as other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these websites, including the accuracy, completeness, or reliability of the information found on them. The information you provide in public or semi-public areas, including information you share on third-party social media platforms, may also be viewed by other users of the Services and/or users of those third-party platforms, without limitation regarding its use by us or third parties. Our inclusion of such links does not imply, by itself, any endorsement of the content of those platforms or their owners or operators, except as disclosed in the Services.

The Services are not intended for use by children, and we do not intentionally collect any personal information about children. If you are a parent or guardian of a child who has provided us with their personal information, you can contact us using the contact details below to request its deletion.

As of the Effective Date of this Privacy Policy, we have no actual knowledge that we "share" or "sell" (as those terms are defined in applicable law) personal information of individuals under the age of 16.

Please note that no security measure is perfect or impenetrable, and we cannot guarantee "perfect security." Additionally, any information you send to us may not be secure during transmission. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

The length of time we retain your personal information depends on various factors, such as the need for the information to maintain your account, provide the Services, comply with legal obligations, resolve disputes, or enforce other applicable contracts and policies.

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute and may only apply under certain circumstances, and in some cases, we may refuse your request if the law permits us to do so.

• Right of access/knowledge: You may have the right to request access to the personal information we hold about you, including details related to how we use and share your information.
• Right of deletion: You may have the right to request the deletion of the personal information we hold about you.
• Right of correction: You may have the right to request the correction of any inaccurate personal information we hold about you.
• Right of portability: You may have the right to receive a copy of the personal information we hold about you and request its transfer to third parties, under certain circumstances and with some exceptions.
• Right to opt out of sale, sharing, or targeted advertising: You may have the right to instruct us not to "sell" or "share" your personal information or to opt out of processing your personal information for purposes considered "targeted advertising" as defined in applicable privacy laws. Please note that if you visit our website with the opt-out preference signal from the Global Privacy Control activated, depending on your location, we will automatically treat this request as an opt-out request for the "sale" or "sharing" of information for the device and browser you use to visit the website.
• Right to restrict processing: You may have the right to ask us to stop or restrict our processing of your personal information.
• Withdrawal of consent: When we rely on your consent to process your personal information, you may have the right to withdraw that consent.
• Right to appeal: You may have the right to appeal our decision if we refuse to process your request. You can do this by responding directly to our refusal.
• Managing communication preferences: We may send you promotional emails, and you can opt-out of receiving them at any time using the unsubscribe option provided in our emails. If you choose not to participate, we may still send you non-promotional email messages, such as those related to your account or orders you’ve made.

You can exercise any of these rights as indicated on our website or by contacting us through the contact details provided below.

We will not discriminate against you for choosing to exercise any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a specific response to your request. Under applicable law, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof that you have authorized them to act on your behalf, and we may need to verify your identity directly with you. We will respond to your request in a timely manner as required by applicable law.

If you have complaints about how we handle your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on your place of residence, you may have the right to appeal our decision by contacting us through the contact details provided below or file your complaint with the local data protection authority. For the EEA, you can find a list of the authorities responsible for overseeing data protection [here].

Please note that we may transfer, store, and process your personal information outside of the country where you reside. Your personal information may also be processed by employees and third-party service providers and partners in those countries.

If we transfer your personal information outside of Europe, we will rely on recognized transfer mechanisms, such as the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the competent authority of the United Kingdom, as applicable, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to exercise any of the rights you have, please contact us by phone or by email at thomsonclub.brand@gmail.com.

For the purposes of applicable data protection legislation, and unless explicitly stated otherwise, we are the data controller of your personal information.