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PRIVACY & COOKIE POLICY

Last Updated December 2023


Introduction

Choosing to shop with us means you've placed trust in us to handle your personal
data responsibly. In sharing your personal data we hope you in return benefit
from a tailored and convenient shopping experience. With trust comes
responsibility and we take this responsibility very seriously.

This privacy policy helps you to understand how we use your personal data and
who we share it with. It applies if you shop on our websites, use our apps, shop
in our stores or if you otherwise share your personal data with us; for example
if you contact us with a query or where you tell us that you would like to
receive marketing communications from us.

We change the terms of this privacy policy from time to time and you should
check it regularly. The last updated date is shown at the beginning of the
document. If we make any material changes we will take steps to bring it to your
attention.

Who we are

When we say “we”, “our” or “us” in this policy we are referring to the companies
that make up the NEXT Group. This privacy policy applies to the following
companies:

Next Retail Limited, Next Holdings Limited, Next Distribution Limited, Next
Manufacturing Limited, Next Sourcing Limited, Next Retail Ireland Limited, Next
Germany GmbH, Next General Trading LLC, Next General Trading FZE, Next Beauty
Limited, Lipsy Limited, Victoria’s Secret (VS Brands Holdings UK Limited), GAP
(West Apparel UK Holdings Limited), Reiss (Pink Topco Limited), JoJo Maman Bébé
(Regent BidCo 1 Limited) and Joules (The Harborough Hare Limited).

The company named within the T&Cs on the website or app is the data controller
of your personal data, which means we are responsible for deciding how and why
your personal data is used. We are also responsible for making sure it is kept
safe, secure and handled legally.

We sometimes work with other organisations in connection with some of the
processing activities described in this privacy policy, such as social media
platforms. Where that data is collected and sent to other organisations for
processing that is for a common purpose, we will be making decisions together in
relation to that particular processing and will be ‘joint data controllers’ with
the organisations involved. As joint data controllers, we and the other
organisations involved in making these decisions will be jointly responsible to
you under data protection laws for this processing.

We operate to the highest standards when protecting your personal data and
respecting your privacy. If you have any questions about your personal data, or
how we use it, you can contact our Data Protection Officer via email at
dataprotection@next.co.uk or by writing to our registered office at the
following addresses:

UK registered address: Data Protection Officer, NEXT Group, Desford Road,
Enderby, Leicester, LE19 4AT.

EU registered address: Data Protection Officer, NEXT Retail (Ireland) Ltd, 13–18
City Quay, Dublin 2, D02 ED70, Ireland.

Your rights

You have a number of “Data Subject Rights”, we have explained below what they
are and how you can exercise them. You can read more about these rights on the
UK Information Commissioner's Office website at ico.org.uk/for-the-public, or on
your local Data Protection Authority website.

 * Right of access –You have the right to request a copy of the personal data
   that we hold about you.
 * Right to rectification –If you think any of your personal data that we hold
   is inaccurate, you have the right to request it is updated. We may ask you
   for evidence to show it is inaccurate.
 * Right to erasure– (also known as the right to be forgotten) - You have the
   right to request that we delete your personal data that we hold..
 * Right to restriction of processing–You have the right to request we restrict
   or suppress the personal data we hold about you.
 * Right to data portability –You have the right to ask us to electronically
   transfer your personal data to another organisation in certain circumstances.
 * Rights with regards to automated decision making, including profiling – You
   have the right not to be subject to a decision that is based solely on
   automated processing if the decision affects your legal rights or other
   equally important matters and to object to profiling in certain situations,
   including for direct marketing.
 * Right to withdraw Consent – Where we are relying on your consent for
   processing you can withdraw or change your consent at any time.

The above rights may be limited in some circumstances, for example, if
fulfilling your request would reveal personal data about another person, if you
ask us to delete data which we are required to have by law, or if we have
compelling legitimate interests to keep it. We will let you know if that is the
case and will then only use your data for these purposes. You may also be unable
to continue using our services if you want us to stop processing your personal
data.

If you have any general questions or want to exercise any of your rights, please
see the “how you can get in touch” section of this privacy policy. In order to
maintain the security of our customers' personal details, we may need to request
proof of identity before we disclose personal data to you in response to any
request.

We encourage you to get in touch if you have any concerns with how we collect or
use your personal data. You have the right to lodge a complaint directly with a
Data Protection Authority. The Data Protection Authority in the UK, where we are
based, is the Information Commissioner's Office (ICO), you can contact the ICO
here: ico.org.uk/make-a-complaint. Our main supervisory authority in the EU is
the Data Protection Commission (DPC) based in the Republic of Ireland, you can
contact the DPC here: forms.dataprotection.ie/contact

The lawful bases we use to process data

We will only ever process your data if we have a lawful basis to do so. The
lawful bases we rely on are:



 * Contract – This is where we process your data to fulfil a contractual
   arrangement we have made with you or because you have asked us to carry out a
   service before entering into a contract.
 * Consent –This is where we have asked you to provide permission to process
   your data for a particular purpose.
 * Legitimate Interests - This is where we rely on our interests as a basis for
   processing. Generally this is to provide you with the best products and
   services in the most secure and appropriate way, but not where our interests
   are overridden by your interests.
 * Legal Obligation –This is where we have a statutory or other legal obligation
   to process the data, such as to comply with regulatory requirements and/or
   requests.
 * Vital interests –This is where the processing of personal data is necessary
   to protect someone’s life.



The Data we collect and how we use it

We collect and use the data that you provide to us directly, for example; when
you register for an account; we use cookies and other similar technologies to
collect data from your devices when you interact with our advertising or use our
website (you can find out more information in the “Cookie Policy” section
below); we keep records when you speak to our customer service teams; we use
CCTV in our stores for security monitoring and market research purposes; we take
personal data from a number of third parties to help us manage your account and
improve your shopping experience.

To process any orders that you place with us and to facilitate any returns
Lawful basis: Contract



 * We take payment details to process payment for any credit or debit card
   orders you place with us. We share these details with our chosen payment
   processors.
 * We use your account data plus your chosen delivery address details to;
   deliver your purchases and keep you informed of their status, and to process
   any returns including (where appropriate) collecting the item from you.
 * Additionally, where you consent our chosen payment processors may store your
   payment card details at your request to speed up your checkout in the future.



To provide you with access to an account Lawful basis: Contract



 * To register an account with us we capture data such as your name, contact and
   delivery information, and a password to protect your account (account data).
   We use the same data on an ongoing basis to manage and provide secure access
   to your account, and provide you with the services you request.



To provide customer service to you Lawful basis: Legitimate Interest in
providing customer support



 * We record calls and and keep correspondence (customer service records) when
   you contact our customer service teams or interact with us on social media.
   Using these customer service records is necessary to manage your queries or
   complaints effectively, for quality monitoring, for the defence of any claims
   and to continually improve our services.
 * We may use automated machine learning systems to generate responses when you
   communicate with our customer contact centres. This helps us to resolve
   common queries quickly, provide you with a more efficient service and reduce
   the average response time for our customers.



To offer and manage any credit we provide to you Lawful basis:
Contract/Legitimate Interest in ensuring product suitability and managing debts



 * When you apply for and use credit with us we will use your account data to
   make searches with third parties who will give us data about you, such as
   your financial history. We do this as it is necessary to assess your
   creditworthiness and product suitability.
 * We use purchase and payment history, along with your account data on a
   cyclical basis as it is necessary to manage your credit facility with us.
 * We use your account data, purchase history, payment history and third party
   data as it is necessary to collect and recover money that is owed to us (debt
   recovery) should your account fall into arrears. Please see the section on
   “third parties we share data with and receive data from” below for more
   information.



To personalise and improve your experience when you shop Lawful basis:
Consent/Legitimate Interest in providing relevant and personalised experiences
when you shop with us

 * We keep a record of how you interact with our website and any marketing you
   are exposed to. We use this data, along with purchase history across the NEXT
   Group, demographics, account data and third party data. We do this so we can
   create a profile about you, which helps us to tailor your shopping
   experience, to show you products and offers from across our brands that we
   think you will be most interested in, and find ways to improve our stores,
   apps and websites.
 * We use your account data, information about the devices you use to access our
   sites and your interactions with us to operate personalised features across
   our websites, apps and communication.
 * In our stores we use CCTV footage for market research purposes so that we can
   best arrange our stores and stock the ranges our customers will be most
   interested in.
 * We record your purchases made in one of our stores using tokenised data from
   your payment card. Your payment card(s) have a unique tokenised reference
   number and this is used to match it to your profile.
 * We will send you a receipt by email if you have requested this when you shop
   in one of our stores.

To inform you about products and services that may interest you Lawful basis:
Consent



 * We use technologies such as cookies within digital marketing networks, ad
   exchanges and social media networks such as Facebook’s Custom Audience to get
   relevant marketing messages across to you and other customers. We share
   aggregated and anonymised data about the customer segments we are interested
   in reaching with advertising partners, so they can focus on showing adverts
   to those who are most likely to be interested in our products, services and
   offers, and to prevent them showing you irrelevant or repetitive
   advertisements.
 * We share limited data with selected suppliers to enable them to identify new
   prospective customers on our behalf and to prevent us repeatedly advertising
   products or services you have already bought.



Lawful basis: Legitimate Interest in assessing how and where to place
advertising



 * We receive data on how you interact with our adverts and content on third
   party websites and social media platforms (such as Google or Facebook) which
   it is necessary to use to tailor and personalise the products and services
   that are displayed to you.



To personalise and engage with you on social media Lawful basis:
Consent/Legitimate Interest to personalise the marketing and services we provide
to you

 * We use your personal data to engage with you on social media.
 * We place targeted advertising in social media. You may receive advertising
   based on data about you that we have provided to a social media platform, or
   allowed it to collect using cookies on our website or code in our
   applications (or a combination of the two). For some of our marketing
   campaigns, we may use this data to exclude you from receiving advertising, if
   we believe it will not be relevant to you.
 * You may also receive advertising because, at our request, the platform has
   identified you as falling within a group whose attributes we have selected or
   a group that has similar attributes to the individuals whose details it has
   received from us (or a combination of the two).
 * We view statistical data and reports regarding your interactions with the
   pages and accounts we administer on social media platforms.
 * To find out more, please refer to the information provided in the help pages
   of the platforms on which you receive advertising from us. Please also see
   the section below for further information regarding our use of social media,
   including specific platforms and the arrangements we have in place with them

To keep in touch with you Lawful basis: Consent/Contract

 * When you agree to receive marketing we will keep you up to date with news of
   products and services including store events, offers, promotions and sale
   data. We may send you marketing via email, SMS or post, depending on your
   preferences. You can unsubscribe from marketing at any time through the “my
   account” or using the link in every email that we send to you.
 * If you enter or apply for a prize draw or competition we will collect your
   contact details so that we can inform you if you are a winner.

Lawful basis: Legitimate interest in marketing to you and keeping customers
updated

 * Where we are permitted to market to you without consent, we will update you
   on the latest similar products and services sold on our websites or in our
   stores that we think you will be interested in.
 * When we send you communications we use records of how you interact with our
   website and any other marketing we have sent to you, along with purchase
   history, to personalise the marketing we send you so it is relevant and
   interesting.
 * When we respond to any communications and queries from you if you contact us
   via any of our customer contact channels, including when we interact with you
   through the chat function on our websites or apps.
 * We use your account data to notify you about important service messages, such
   as material changes to this policy, product recalls or information about your
   account.

To ensure the Website and the services we offer you operate properly Lawful
basis: Consent

 * We use cookies and other similar technologies to keep track of your
   preferences when using our site.
 * We use cookies and similar technologies to help us understand how you use the
   site, this allows us to optimise your shopping experience and continually
   improve our site

Lawful basis: Legitimate Interest in planning and delivering efficient
operations and to prevent and detect crime or fraudulent activity

 * We use data for logistics planning, demand forecasting, management
   information, dealing with errors on our site, and general research and
   development as it is necessary to keep the business running efficiently.
 * We gather data about the devices you use to access our sites (desktop and
   mobile) for example your IP address and device type, to ensure the site is
   secure and works across multiple platforms.

To develop and improve our products, range and services Lawful basis: Legitimate
Interest in understanding our customers’ needs and behaviours to provide a
better experience

 * We share insights about our customers (in an anonymised and aggregated
   format) with the companies whose products we sell. This is necessary to help
   them better understand the different profiles of our customers, focusing on
   those who buy their products or are interested in them.
 * We may contact you to take part in customer satisfaction surveys, if you
   respond we collect your feedback and contributions (customer feedback). We
   use this data to develop the services we offer.
 * We work with data providers that specialise in consumer profiling, such as
   Experian and Merkle. These organisations provide demographic or other data as
   it is necessary to help us better understand customers' demographics,
   lifestyles or shopping behaviours, usually linked to the areas where people
   live. This helps us to understand our customers better and provide products
   and services that people will want to purchase.

You can view the privacy policy for Experian and Merkle, including the ways in
which they use and share personal data here:

 * experian.co.uk/privacy/privacy-policies
 * merkle.com/privacy
 * We use data about how you browse and engage with our website to improve our
   websites.
 * We use all data, including third party data in the development of new
   products, services and systems to ensure they work as expected and will be
   useful to our customers.

To prevent and detect crime and other incidents Lawful basis: Legitimate
Interest in keeping our customers and staff safe, reducing theft and fraud

 * When you shop in our stores we use CCTV for the prevention and detection of
   crime, for operational efficiency and analytics purposes or for the
   protection of our staff, customers and products. This includes for the
   investigation of accidents, incidents, criminal activities and breaches of
   our policies.
 * Our employees may wear body-worn devices to protect themselves in limited
   circumstances. These devices record both audio and video and are only
   activated in high risk situations where it is necessary such as aggressive
   behaviour and/or when there is a threat of violence.
 * When you register an account, apply for credit or contact our customer
   contact centres we use your account, application and purchase history data as
   they are necessary to confirm your identity.
 * We use device identifiers, IP addresses and account numbers in fraud
   prevention and investigation, as they are necessary to maintain network and
   data security.

To fulfil our legal obligations Lawful basis: Legal obligation

 * We use your data to ensure we comply with any requirements imposed on us by
   law or court order, including disclosure to law or tax enforcement agencies
   and authorities or pursuant to legal proceedings.
 * We use your account data, order history and payment history to assist in
   monitoring for fraudulent transactions or suspected money laundering.
 * We maintain a record of any health and safety incidents that occur in our
   stores or in our premises. We will share data with regulatory and other
   official bodies if they make formal requests.
 * We will maintain records to meet regulatory and tax requirements.
 * We will use your account data to contact you in connection with product
   recalls or other similar product quality issues and to comply with our legal
   obligations in connection with the sale of age restricted products.

Our use of social media

We use a number of different social media platforms to communicate with you and
to promote products and services. We process your personal data using these
platforms in a variety of ways, as follows:

Pages/accounts. We use your personal data when you post content or otherwise
interact with us on our official pages and accounts on Facebook, Instagram,
Pinterest, Snapchat, TikTok, LinkedIn, X (formally Twitter) and other social
media platforms. We also use the Page Insights service for Facebook, Instagram,
Pinterest, TikTok, Snapchat and X to view statistical data and reports regarding
your interactions with the pages and accounts we administer on those platforms
and their content. Where those interactions are recorded and form part of the
data we access through these page insights services, we and the relevant
platform are joint data controllers of the processing necessary to provide that
service to us.

Cookies. We use cookies and similar technologies in our website to collect and
send data to social media platforms about actions you take on our website and
applications. In particular:



 * Meta (who operates the Facebook and Instagram platforms) uses this data to
   provide services to us and also for further processing for its own business
   purposes. We and Meta are joint data controllers of the processing involved
   in collecting and sending your personal data to Meta using cookies and
   similar technologies as each of us has a business interest in Meta receiving
   this data. The services we receive from Meta that use this data are delivered
   to us through Meta Business Tools, which include Meta pixel, social plugins,
   code in our applications and website custom audiences. These tools allow us
   to target advertising to you within Meta’s social media platforms by creating
   audiences based on your actions on our website and applications and allow
   Meta to improve and optimise the targeting and delivery of our advertising
   campaigns for us.



Our relationship with Meta and LinkedIn. As we are joint data controllers with
these platforms for certain processing, we and each platform have:

 * entered into agreements in which we have agreed each of our data protection
   responsibilities for the processing of your personal data described above;
 * agreed that we are responsible for providing to you the information in this
   privacy policy about our relationship with each platform; and
 * agreed that each platform is responsible for responding to you when you
   exercise your rights under data protection law in relation to that platform’s
   processing of your personal data as a joint data controller.

Meta also processes, as our processor, contact information that we submit for
the purposes of matching, online targeting, measurement, reporting and analytics
purposes. These services include the processing Meta carries out when they
display our advertisements to you in your news feed at our request after
matching contact details for you that we have uploaded to the social media
platforms they operate.

Further information. The Meta company that is a joint data controller of your
personal data is Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025,
USA (if you are a UK-registered user) or Meta Platforms Ireland Limited, Block
J, Serpentine Avenue, Dublin 4, Ireland (if you are an EEA-registered user). The
LinkedIn company that is a joint data controller of your personal data is
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland For further
information regarding these platforms and their use of your personal data,
please see:

 * Meta’s Controller Addendum for Page Insights and UK UK Controller Addendum
   for Business Tools (for users located in the UK) and Controller Addendum (for
   users located in the EEA), and LinkedIn’s Page Insights Joint Controller
   Addendum, which include information regarding how our and these platforms’
   responsibilities to you are allocated as controllers of your personal data;
 * Meta’s Privacy Center including its privacy policy at
   www.facebook.com/privacy and LinkedIn’s privacy policy at
   www.linkedin.com/legal/privacy-policy which include details of the legal
   reasons (known as ‘lawful bases’) on which each platform relies to process
   your personal data, together with details regarding your data protection
   rights.

Cookie Policy

What are cookies?



 * Cookies are small text files that are stored on your computer, mobile device
   or other web enabled device when you visit one of our websites or apps.
   Cookies allow us to “remember” your actions or preferences over a period of
   time, or they may contain data related to the function or delivery of our
   websites. We also use the term “cookie” to describe similar technologies such
   as pixels or tags.



What do we use cookies for?

Some cookies are required by our site to enable you to transact whilst other
cookies enable us to give you an enhanced, personalised web experience. We use
cookies for the following purposes:

 * To allow you to securely sign in to your account, so that you can use "My
   Account" features such as order information, making payments and viewing
   statements.
 * To store the content of your online shopping bag whilst you browse the site
   and to complete an order.
 * To record the areas of the website that you have visited, products you have
   viewed and time spent browsing, as well as the products you purchased. We use
   this data to help make the websites more user friendly, develop our website
   design and to continuously improve the quality of the service we provide.
 * To distribute visitors to our websites evenly across platforms to ensure the
   content is served at the fastest possible speed.
 * Provide relevant products and services to you when you come to the websites
   and ensure that relevant marketing material is provided to you.
 * Detect and prevent fraud and other crimes.



We also offer you the facility to share your experience on our website through
social sites. More information about how these sites use cookies can be found on
their websites.

What cookies do we use?

We use the following cookies on our websites and apps:

 * Strictly necessary Cookies.These cookies are necessary for the website to
   function and cannot be switched off. They are used, for example, to make sure
   your transaction is secure, to enable you to log in to the secure areas of
   your account, such as your order history and to add items to your basket.
   Blocking these cookies through your browser will mean that some parts of our
   website won’t work.
 * Performance Cookies or analytical Cookies. These cookies allow us to monitor
   visitors to our websites and ensure it is performing correctly. We use this
   data to measure overall performance, improve your website experience and
   improve the design of our website.
 * Functionality Cookies. These cookies enable enhanced functionality on our
   website, such as allowing you to add to favourites or remember your language
   preferences.
 * Onsite Targeting: Marketing and Personalisation Cookies. These cookies are
   placed by us and are used to help us to build an understanding of your
   interests (for example by understanding what products you have browsed on our
   website) and show you products, services and advertisements relevant to you
   whilst you are on the website. These cookies make it possible for us to
   personalise your experience on the websites and (if you are subscribed) in
   our email marketing.
 * Off Site Targeting: Marketing and Personalisation Cookies. These cookies are
   placed by our advertising and marketing partners (including social networks).
   These help us to build an understanding of your interests (for example by
   understanding what products you have browsed on our website) and show you
   products, services and advertisements relevant to you. These cookies make it
   possible for us to ensure that you don’t see irrelevant, duplicate or
   multiple ads from us in a short period of time. We do want to prevent ads
   continuously re-appearing and annoying you.

Can I turn off or block cookies?

We use cookies to ensure that we provide the best possible standard of service
to our online customers. You can change your cookie preferences at any time by
clicking on “Manually Manage Cookies” at the bottom of the page. You can then
adjust the available sliders to on or off, then click “Confirm my choices”. If
you choose not to consent to the use of cookies your experience of our website
may be impaired and many integral aspects of the website, including (but not
limited to) adding items to your shopping bag and accessing your account, will
not work.

Alternatively, most web browsers allow some control of most cookies through the
browser settings. To find out more about how to manage cookies, including how to
delete cookies, visit www.allaboutcookies.org

How long we keep your data for

We keep your personal data as long as you are a customer of ours and generally
for up to 7 years afterwards to comply with legal requirements. During that time
we take steps to remove any personal data as soon as we no longer need it.

We consider you a customer:

 * as long as you hold an open credit account,
 * for 2 years from the point you last made a purchase from our website using a
   non-credit account, or
 * during any time we are managing a customer service request from you.

We keep CCTV footage on our systems for up to 30 days, it is then deleted. Where
accidents, incidents, criminal activities or breaches of our policies are
recorded CCTV footage will be kept for longer, however only as long as
necessary.

Third Parties we share data with and receive data from

We work with a number of trusted third parties to provide you high quality goods
and services. Anybody we work with is subject to stringent security and data
protection assessments before we begin to do business with them and on an
ongoing basis.

We always make efforts to anonymise data and only pass over personal data that
is absolutely necessary for the purposes it is being processed. We always do so
securely.

We have contracts in place with all suppliers that help us to ensure security
and privacy of your personal data, these are reviewed and updated regularly and
always in line with data protection laws.

 * NEXT Group companies – We will share your personal data, in certain
   circumstances with the other companies within the NEXT Group. This is so that
   we can provide personalised services across our group companies.
 * Delivery Partners – Helping us to deliver the goods you order to you
   including our brand partners that dispatch and deliver goods to you directly.
 * IT Companies – Supporting us in maintaining our website and other business
   systems including; providing phone lines, data storage facilities, and
   providing and supporting Cloud based infrastructure used in providing our
   products and services.
 * Marketing Companies and Online Advertising – Helping us to manage our
   electronic communications to you and to help us show you the advertising you
   are most likely to be interested in, companies that provide marketing and
   advertising assistance (including management of email marketing operations,
   mobile messaging services such as SMS, and services that deploy advertising
   on the internet or social media platforms, such as Facebook and Google) as
   well as analysis of the effectiveness of our advertising and communications
   campaigns.
 * We use technologies such as cookies, pixels, and device IDs within digital
   marketing networks, ad exchanges and social media networks such as Facebook’s
   Custom Audience to get relevant marketing messages across to you.
 * Consumer profiling organisations – These organisations provide demographic or
   other data to help better understand customers' demographics, lifestyles or
   shopping.
 * Payment processors – Payment card processors to process credit and debit card
   payments and store payment data.
 * Credit Reference Agencies (CRAs) – We share your personal data with CRAs on
   an ongoing basis, including details of settled accounts and any debts not
   fully repaid on time. CRAs will share your data with other organisations.

The identities of the CRAs, and the ways in which they use and share personal
data, are explained in more detail at:

- Experian Credit Reference Agency Information Notice

- TransUnion Credit Reference Agency Information Notice

- Equifax Credit Reference Agency Information Notice

We also take data from CRAs to allow us to make decisions about your credit
account and credit facility.

 * Fraud prevention services – Before we provide goods and services to you, we
   use third parties to undertake fraud and money laundering checks and verify
   your identity. These organisations will report to us on industry fraud
   indicators and if they have reason to believe an identity is fraudulent. If
   we have reason to suspect fraud or other criminal offences we will pass your
   personal data to fraud prevention agencies or law enforcement agencies for
   the detection, investigation and prevention of crime. If we think there is a
   risk of fraud, we may suspend activity on your account or refuse access to
   your account and/or cancel an order. If we do this we will inform you by
   email or SMS and ask you to contact us.
 * Claims management companies – where we have received appropriate instruction
   we will share your data with them if it is requested in order to manage your
   claim.
 * Debt collection agencies (DCAs) – If you default on repayments to your credit
   account we may share your data with DCAs to allow them to collect the
   outstanding debts from you.

The identities of the DCAs, and the ways in which they use and share personal
data, are explained in more detail at:

- tdxgroup.com/privacy

 * Debt purchase companies – Where appropriate will share certain data on
   defaulted accounts with prospective debt purchasers as part of the
   negotiations for sale of the debt.
 * Debt management companies – where we have received appropriate instruction we
   will share data about your credit account with debt management companies to
   allow them to assist you with managing your debts.
 * Research and analytics companies – We may share personal details to allow
   research companies and feedback providers to contact you directly on our
   behalf in order to capture your opinions on our products, services, websites
   and apps. We may ask these research companies to analyse the results so that
   we can better understand your online experience, which will help us to
   improve our services. We only provide them with the data they need to perform
   their function. This may take the form of a survey, where you may be asked to
   review a product or service you’ve bought or provide general feedback on our
   products and services. You will always have the choice about whether to take
   part in our market research or surveys. We may share data with specialist
   companies to analyse customer data to help us better understand how you use
   our services and to tailor products, services and offers that may be relevant
   for you. We utilise companies that help us track and record the way you
   navigate our website, so that we can understand your online experience and
   use it to improve our services and offer a more personalised experience.
 * Product technicians – We use professional third party companies to assist us
   in independently reviewing issues and complaints with our products. We will
   share data with these technicians to allow them to review the product and
   return it to you or to review the product in your home.
 * General service companies – Such as insurance companies, printers and mailing
   houses that assist us in providing our products and services.
 * Regulators and law enforcement – We will share data with regulators and other
   official bodies (including law enforcement) if they make formal requests or
   pursuant to legal proceedings.

International Transfers

Our main operations are based in the UK and your personal data is generally
processed, stored and used within the UK. In some instances your personal data
may be processed outside the UK. For example, we operate a customer contact
centre in Pune, India. Operatives in this location will have access to your
account data in order to assist you with your query. We also work with suppliers
and partners who may make use of Cloud and /or hosted technologies across
multiple geographies.

If you place an order with us and you are outside of the UK we will transfer the
personal data that we hold on you to the UK to facilitate your order and may
also transfer your personal data to third parties located in your country of
residence to enable us to supply products you order from us. If and when this is
the case we take steps to ensure there is an appropriate level of security so
your personal data is protected in the same way as if it was being used within
the UK.

Where we need to transfer your personal data outside the UK, and if the
recipient country has not been determined as providing an equivalent adequate
level of protection as the UK, we will use one of the following safeguards:

 * The use of European Commission approved standard contractual clauses in
   contracts for the transfer of personal data to third countries; and/or
 * The International Data Transfer Agreement or Addendum for the transfer of
   personal data to third countries.

Keeping your personal data secure

We always ensure that personal data is secure by continuously developing our
security systems and training for our employees. We have implemented appropriate
technical and organisational security measures designed to protect your personal
data against accidental or unlawful destruction, loss, alteration, unauthorised
disclosure, unauthorised access, and other unlawful or unauthorised forms of
processing, in accordance with applicable law.

Third party apps, websites and services

If you use any third party apps, websites or services to access our services,
your usage is subject to the relevant third party's terms and conditions,
cookies policy, and privacy policy. For example, if you interact with us on
social media, your use is subject to the terms and conditions and privacy
policies of the relevant social media platform (Facebook, X etc.). The same
applies if you use third party services, like Amazon's Alexa. In certain cases
we may be required to share your personal data, in relation to transactions and
usage of the services, with the relevant third party.

How you can get in touch

If you would like to exercise any of your rights mentioned within this privacy
policy you can submit these through our privacy portal.

Alternatively, should you need to contact our Data Protection Officer please
email: dataprotection@next.co.uk or you can write to:

UK registered address:

Data Protection Officer

NEXT Group

Desford Road

Enderby

Leicester

LE19 4AT

EU registered address:

Data Protection Officer

NEXT Retail (Ireland) Ltd

13–18 City Quay

Dublin 2

D02 ED70

Ireland





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