Privacy Policy - Aspinal Inc

Welcome to Aspinal of London Group Privacy Notice. Aspinal of London Group, provides global retail services through Aspinal of London Limited and Aspinal of London USA Inc referred to as "we", "us" or "our" throughout this privacy notice and our registered Group office is Aspinal of London, Highfield, Midhurst Road, Fernhurst, West Sussex, GU27 3HA.

Aspinal of London USA Inc is a company registered in the State of Delaware, Company Registration number 1036747, registered office 850 New Burton Road, Suite 201, in the City of Dover, County of Kent Zip Code 19904

We take our Data Protection obligations very seriously and this notice gives you information about our approach to Data Protection legislation. The General Data Protection Regulation (UK & EU GDPR) is widely recognised as the benchmark for data protection. As a provider of retail services globally we are committed to upholding the highest standards of data privacy and protection.

Where applicable, we apply the principles and requirements of the GDPR to ensure that personal data is handled lawfully, transparently, and securely, regardless of jurisdiction. This approach reflects our dedication to safeguarding individual rights and maintaining trust across all markets in which we operate. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. We will endeavour to comply with applicable country or state specific data protection legislation. Specific privacy notices may apply to some of our products and services.

Aspinal of London Ltd is responsible as a data controller for personal data collected through this website and any processing activity in the UK & EU.

Aspinal of London Inc is responsible as a data controller for personal data processed through this website and any processing activity in the United States. Please see our US Addendum Privacy Notice for specific privacy information regarding the processing of the data of residents of the United States whose states have passed state-specific privacy laws.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

We are committed to protecting and respecting your privacy and your information. This Privacy Notice (together with our terms and conditions, US Addendum and any other documents referred to in it) explains what types of personal information we collect about you, what we do with that personal information, the legal basis for our processing of your personal information, what rights you have in relation to your personal information and how you can exercise those rights. It also explains how we keep your personal information safe and secure.

Aspinal of London’s digital services are not intended for children and young people under the age of 16 and we do not knowingly collect data relating to children. All individuals who register with us or who otherwise provide their personal data to us or must be aged 16 or over. If you are under the age of 16, please ask your parent or guardian to contact us on your behalf.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This notice supplements other privacy notices and is not intended to override them. We may update this notice at any time, details of which are found at the end of this document. 

CONTACT

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice or any other Data Protection query, please contact us using the details set out below.

•  
  • Aspinal of London Group
  • enquiries@aspinaloflondon.com

You have the right to lodge a complaint at any time with the relevant supervisory authority responsible for data protection matters in your jurisdiction. However, we would appreciate the opportunity to address your concerns directly before you escalate the issue and therefore encourage you to contact us in the first instance.

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 or if you would like to opt-out of any services we provide. You can update any information we hold about you by contacting our Customer Services Team https://www.aspinaloflondon.com/contact-us who will be delighted to help you.

1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

• Identity - Data includes first name, last name, username or similar identifier, postal address, telephone numbers, email address. We also collect age & special dates such as your birthday or anniversary, should you wish to provide this.
• Financial - Data includes payment information such as payment method and payment 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 your 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, and other technology on the devices you use to access this website.
• Profile - Data includes your username and password, your interests, preferences, feedback, competition, promotion, or survey responses (should you chose to engage).
• Marketing & Communications - Data such as your marketing and communication preferences, your interests and any feedback you give to us.
• User - Data such as your transactions on our website, phone calls, messages, recordings, chat logs when you communicate with us, access to our premises, CCTV footage from our stores or Head Office and similar data that we maintain on your account.

Please note the above list is not exhaustive but gives an indication of the data we collect.

You may give us information about other people, such as the name and address of a friend/family member to whom you want to send a gift. Please do not give us information about others unless you are authorised and have their permission to do so. We will use their information for the purposes described in this Privacy Notice, so please inform them of this notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data). Nor do we collect any information about criminal convictions and offences. Please do not provide us with any such data.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you to purchase our products, and you fail to provide that data when requested, we may not be able to provide you with goods or services. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

1. HOW IS YOUR PERSONAL DATA COLLECTED?

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

DIRECT INTERACTIONS

You may give us your Identity, Contact, User and Financial Data on our website, in our stores or by corresponding with us by post, online, phone, email or otherwise. This includes personal data you provide when you: purchase our products; create an account with us; subscribe to our marketing services; request a catalogue, enter a competition, promotion, sweepstake, survey or similar initiative; attend our stores, give us feedback or contact us.

AUTOMATED TECHNOLOGIES OR INTERACTION

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. You can set your browser to refuse all or some browser cookies, however if you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Further information can be found in our cookie policy.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES

We will receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks;
• Social Media Platforms and similar services (including but not limited to Facebook, Instagram, Twitter, TikTok and YouTube). When you engage with our content or ads on Social Media Platforms, we might obtain information from Social Media Platforms, including your username, user ID, and demographic information, subject to the settings and privacy practices of the relevant Social Media Platform. We obtain this information directly from the Social Media Platform or through plug-ins, integrations or applications. Please keep in mind that the operators of the Social Media Platforms also gather information about your use of the Digital Services and their features and tools. We are not responsible for their practices. In relation to Social Media Platforms, we only process information which you have already shared with the world. Where we receive personal data via Social Media Platforms we ensure this is processing lawfully in accordance with our legitimate interests which we do not consider affects your rights and freedoms.

Contact, Financial and Transaction Data from providers of technical, payment services, fulfilment and delivery services, including Klarna.

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain information, such as your name, billing and shipping address, email address, phone number, and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites 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 personal data to these websites.

1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To create your account and register you as a customer (if you have chosen to create an account with us) and to send you information relating to your account.
• To fulfil any order, you place with us or subsequent orders, to provide any services you request, to process payments and deal with after sales enquiries.
• To keep you informed about the status of your order, to deal with any queries or issues that might arise and to send you the products you have ordered.
• Make your shopping experience with us as quick and as simple as possible.
• Inform you of Aspinal of London offers or new products that may be of interest to you or events that may be happening in a store close to you, where you have consented to be contacted for such purposes.
• Send you product catalogues.
• Ensure that content from our site is presented in the most effective manner for you and for your device.
• Carry out our obligations arising from any contracts between us.
• Allow you to participate in interactive features of our service when you choose to do so.
• Notify you about changes to our service.
• Help to protect you from fraud (for instance we may carry out identity verification, credit or anti-fraud checks against your name using third party databases, which may involve disclosure to registered credit reference or fraud prevention agencies who may retain and use your personal information), carry out analysis and to help us manage our business, statutory returns and legal and regulatory compliance.
• Use your personal information for our internal marketing and demographic studies, together with non-personal data to consistently improve our site design and customer communication to better meet our visitors' needs and to enhance the overall service we provide to our customers.
• To comply with a legal obligation.
  • To protect your vital interests such as emergency situations on our premises and in our stores.

Please note this is not an exhaustive list but gives an indication of how we use your personal data.

We will request your consent in respect of marketing communications sent to you via email or text message. You may unsubscribe from our marketing communications by clicking the "unsubscribe" link in any communication that we send to you by email. Please also note that while your unsubscribe request is being processed, for a brief period you may continue to receive communications which are already on their way to you.

1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we use your personal data, and which of the legal bases for processing we generally rely on to do so. Please note this is not an exhaustive list but gives an indication of the purposes for our processing.

PURPOSES/ACTIVITY

• To register you as a new customer – Identity, Contact.

GDPR Article 6(1)(b) - Performance of a contract with you.

• To process and deliver purchases including managing payments, fees and charges & collecting and recovering money owed to us – Identity, Contact, Financial, Transaction, Marketing and Communications.

GDPR Article 6(1)(b) Performance of a contract with you,

GDPR Article 6(1)(f) Necessary for our legitimate interests (to recover debts due to us as required).

• To manage our relationship with you – Identity, Contact, Profile, Marketing & Communications.

GDPR Article 6(1)(b) Performance of a contract with you,

GDPR Article 6(1)(a) Consent (for marketing purposes).

• To enable you to partake in a prize draw, competition or complete a survey – Identity, Contact, Profile, Usage, Marketing and Communications.

GDPR Article 6(1)(a) Consent (for marketing purposes for our existing customers),

GDPR Article 6(1)(f) Necessary for our legitimate interests (to improve our business and receive feedback on how we can do this and to inform our marketing strategy).

• To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) - Identity, Contact, Technical.

GDPR Article 6(1)(f) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise),

• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you – Identity, Contact, Profile, Usage, Marketing and Communications, Technical.

GDPR Article 6(1)(f) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

• To use data analytics to improve our digital services, products/services, marketing, customer relationships and experiences,– Technical, Usage.

GDPR Article 6(1)(f) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our digital services updated and relevant, to develop our business and to inform our marketing strategy).

• To make suggestions and recommendations to you about goods or services that may be of interest to you – Identity, Contact, Technical, Usage, Profile, Marketing & Communications.

GDPR Article 6(1)(f) Necessary for our legitimate interests (to develop our products/services and grow our business).

• To protect our stores and Head Office by the use of CCTV and security services – Usage.

GDPR Article 6(1)(f) Necessary for our legitimate interests (to protect our stores and assist law enforcement agencies).

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

In the unlikely event that we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with Data Protection legislation, where this is required or permitted by law.

1. DISCLOSURES OF YOUR PERSONAL DATA

We transfer personal data between our businesses to enable us to provide services to our clients and operate our business. We minimise the amount of personal information we disclose to what is directly relevant and necessary.

Additionally we may disclose your personal information to authorised third parties who help us to provide our services such as:

• Companies involved with the payment and logistics of your purchase, such as payment service providers, address verification providers, fulfilment providers to facilitate order management, and delivery companies or couriers (such as Royal Mail, DHL & DPD). (Identity, Contact, Financial, Transaction, User)

• Professional service providers who help us run our business, such as CRM solutions, website hosts, IT providers, CCTV & Alarm services, analytics and research, data enrichment, survey providers, customer support and marketing agencies. (Identity, Contact, Financial, Transaction, Technical, Profile, User, Marketing and Communications)

• To any competent law enforcement body, regulatory, government agency/department, court, credit reference agencies or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation (such as prevention of fraud), (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. (Identity, Contact, Financial, Transaction, Technical, Profile, User)

• Third party sites approved by you, such as social media sites (if you choose to link your accounts to us). We encourage you to review the privacy policies of the Social Media Platforms that you engage with to understand their privacy practices, which we do not control. (Identity, Profile)

• To enforce or apply our Terms of Service or other agreements or to protect Aspinal of London and our customers including sharing with other companies and organisations for the purposes of fraud protection and credit risk reduction. (Identity, Contact, Financial, Transaction, Technical, User)

• To any other person with your consent to the disclosure. (Identity, Contact, Financial, Transaction, Technical, Profile, User, Marketing and Communications)

If we were to be acquired by another company or decided to sell any parts of our business, we may also need to share your personal data with the buyer of those parts of the business. In those circumstances, we will make sure that any new buyer agrees to follow this Privacy Notice with respect to your personal information and will promptly give you details of how they will use your personal data, and your options for changing that.

A list of third parties who we may share your data with can be obtained from our Data Protection Officer. Please note this list is not exhaustive but gives an indication of the data we share with third parties.

INTERNATIONAL TRANSFERS

Aspinal of London is a global business. We may transfer your Personal Information to the United States and other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will protect your Personal Information in accordance with this Global Privacy Notice, or as otherwise disclosed to you.

We comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located. If you are located in the EEA, the UK or Switzerland, any such transfers are done using either a transfer to a country with an adequacy ruling, or if a third country, using the UK International Data Transfer Agreement (IDTA), or the European Commission Standard Contractual Terms (SCC’s) with the UK ICO Standard Contractual Clauses Addendum and the relevant transfer impact assessments.

Should the international data transfer requirements change, we will review the obligations and amend this notice as appropriate. More information can be obtained by contacting our Data Protection Officer.

1. DATA SECURITY

We take the security of your information very seriously. We have in place the 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 to those 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1. 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. Please contact our DPO for further information about retention and our schedule.

1. YOUR LEGAL RIGHTS

Your rights in connection with personal information 

Under certain circumstances, by law you have the right to: 

Right to be informed by the provision of a privacy notice when your personal information is processed.

Request access to your personal information (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

Request rectification of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected. 

Request erasure of your personal information.  This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing. 

Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal information for direct marketing purposes. 

Request the restriction of processing of your personal information.  This enables you to ask us to suspend the processing of personal information about you. 

Request the transfer of your personal information to another party. 

Automated decision making, including profiling We do not envisage that we will conduct any automated processing including profiling, however we will inform you if this changes.

In the limited circumstances where you may have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.   

Generally, you will not have to pay a fee to exercise any of your legal rights. However, we are entitled to charge a reasonable fee if any request is clearly unfounded, repetitive or excessive. We can also refuse to comply with an unfounded or excessive request. We may need to request information from you to confirm your identity, in order to make sure that personal data is not disclosed to someone who is not entitled to have it. We may also need to ask you for additional information to help us respond to your request. We will try to respond to your request within one month but, if the request is very complex or if you have made a number of requests, we are legally able to extend the request by an additional two months. In such circumstances, we will explain to you why it will take longer to respond and we will keep you updated.

If you want to exercise any of your rights, please contact our Data Protection Officer in writing at enquiries@aspinaloflondon.com. 

If you reside in the United States, you may have additional rights as described in our U.S. Addendum Privacy Notice.

We have a GDPR Rights Requests Policy and procedures which includes how we respond to Data Protection complaints, a copy of which can be provided upon request.  If you would like to make a

complaint about our processing of your personal data, please contact our Data Protection Officer in writing at enquiries@aspinaloflondon.com or we can provide a complaints form upon request.

If you remain dissatisfied with our response, you may contact your relevant supervisory authority.

1. CHANGES TO THIS PRIVACY NOTICE

From time to time, we may revise this Privacy Notice. Any such changes will be reflected on this page. Aspinal of London recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located below.

U.S. Addendum Privacy Notice

If you reside in the United States, this U.S. Addendum Privacy Notice supplements the Aspinal of London Group privacy notice for certain states, as indicated in this Addendum.

Application

This U.S. Privacy Addendum supplements the information contained in the Aspinal of London Group Global Privacy Notice. This U.S. Privacy Addendum applies to residents in the United States whose states have passed state-specific privacy laws.

Additional disclosures for U.S. residents, other than California residents

At Aspinal of London, we honour your privacy rights in accordance with applicable U.S. state laws, no matter where you reside. If you are a U.S. resident from whom we collect Personal Data as a controller, you may have certain rights under an applicable U.S. state privacy law, including those in effect in Connecticut, Colorado, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, or under a state privacy law that becomes effective in the future. You may rely on the disclosures in our Global Privacy Notice regarding how we collect, use, and disclose your personal information as well as the choices you can make related to your personal information.

Collection and Sale of your Personal Information to Other Parties

We will not sell your Personal Information. We do not “share” Personal Information with third parties for targeted advertising.

Your Rights and Choices

In addition to the rights identified in the privacy notice, you may have the right to opt out of the processing of the personal information for purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; where applicable, the right to question the result of the profiling, to be informed of the reason the profiling resulted in the decision and, if feasible, to be informed of what actions might have been taken to secure a different decision and the actions that might be taken to secure a different decision in the future; the right to review the data used in the profiling, and if the decision is determined to have been based on inaccurate personal data, taking into account the nature of the personal data and the purpose of the processing, the right to have the data corrected and the profiling decision reevaluated based upon the corrected data; and the right to appeal a decision we make with respect to your privacy rights.

You (or, where permitted by law, your authorized agent) can exercise your rights by contacting us at enquiries@aspinaloflondon.com.

Additional disclosures for California residents

If you are a California resident from whom we collect Personal Information as a business under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), you may rely on the Global Privacy Notice and the additional information below.

For the purpose of this section for California residents, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA. Personal Information does not include information that is publicly available, deidentified, or aggregated (as those terms are defined in the CCPA) or otherwise excluded from the scope of the CCPA.

1. Categories of Personal Information about you that we Collect and Disclose

The following is a list of categories of Personal Information (as defined by the CCPA) we have collected and disclosed for a business purpose.

A. Identifiers. Examples: Personal and business contact information (e.g., name, postal address, telephone number, job title), unique personal identifiers or numbers, online identifier, device identifier(s), internet protocol address, email address, account name, authentication information, and similar identifiers. We may collect this information about other people if you give us their information. We may also associate information that you submit to us, such as articles, comments, or content on our social media pages, with your identifiers.

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e). Examples: Name, address, telephone number, email address, and IP address.

C. Characteristics of Protected Classifications under California or Federal Law. Examples: Gender, family status, age range, and military and veteran status. It is not expected that we will routinely collect such data.

D. Commercial Information. Examples: Information we create or retain that are fundamental to our business, e.g. transaction information, personal account number, product information, marketing.

F. Internet or Other Electronic Network Activity Information. Examples: Cookie and web beacon data, IP address, browser type, operating system, mobile device identifier, referring URLs, pages viewed and actions you take on our online properties and apps, and behavioural-based data or biometric information, such as keystroke timing, device accelerometer, scroll position, and mouse location.

G. Geolocation Data. Example: Your city, state or country or your IP address.

H. Sensory Information. Examples: Audio recordings (including call recordings for customer service purposes).

I. Professional Information. Examples: Professional information such as job title, department, and name of organization.

K. Inferences Drawn from Personal Information. Examples: Personal characteristics, life habits, consumption habits, and interests.

L. Sensitive Personal Information. Examples: Biometric information, fraud and security prevention. (We note, however, that we do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit our collection and processing of this data under the CCPA).

1. Sources of Collection of Personal Information We have collected Personal Information from the following categories of sources:
   • You/Your Devices: You or your devices directly.
   • Affiliates.
   • Analytics Providers.
   • Users: Other users of our services.
   • ISPs: Internet service providers.
   • Government: Government entities.
   • Advertising Networks.
   • Social Networks.
   • Partners: Business partners.
   • Public: Publicly accessible sources.

1. Use of your Personal Information We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
   • Providing Services: Providing our services.
   • Communicating: Communicating with you, providing you with updates and other information relating to our services and products, providing information that you request, responding to comments and questions, and otherwise providing customer support.
   • Connecting Third Party Services: Facilitating the connection of third-party services or applications.
   • Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
   • Personalization: Personalizing your experience on our services, such as presenting tailored content.
   • Sending Messages: Sending you personalized text messages.
   • Facilitating Payments: Facilitating transactions and payments.
   • Safety Issues: Responding to trust and safety issues that may arise.
   • Compliance: For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
   • Auditing Interactions: Auditing related to your interaction with our services and

transactions and auditing compliance with other standards.

• Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging: Debugging to identify and repair errors that impair existing intended functionality.
• Transient Use: Short-term, transient use.
• Contracting Vendors: Contracting with vendors and service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services.
• Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
• Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
• Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

1. Disclosure of your Personal Information to Third Parties With respect to the categories of Personal Information identified above in Section 1, we disclose your Personal Information to the following categories of third parties:
   • Advertising Providers: Advertising technology companies, such as advertising networks. We disclose your Personal Information to Advertising Providers only with your consent. Personal Information we disclose: Identifiers; Internet or Other Electronic Network Activity; Geolocation Data.
   • Analytics Providers: Companies that help us analyze and improve our online properties. We disclose your Personal Information to Analytics Providers only at your direction and only with your consent. Personal Information we disclose: Identifiers; Internet or Other Electronic Network Activity; Geolocation Data.
   • OS/Platform Providers: Operating systems and platforms. Personal Information we share: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data.
   • Resellers: Consumer data brokers. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Geolocation Data; Inferences Drawn from Personal Information.
   • Affiliates. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
   • Vendors: Vendors and service providers. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
   • Integrated Third Parties: Third parties integrated into our services. Personal Information we disclose: Identifiers; Internet or Other Electronic Network Activity; Geolocation Data.
   • Third Parties as Legally Required: Third parties as required by law and similar disclosures. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
   • Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
   • Third Parties with Consent or Direction: Other third parties for whom we have obtained your direction or permission to disclose your Personal Information. Personal Information we may disclose: Identifiers; Commercial Information

We do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit under the CCPA.

1. Collection and Sale of your Personal Information to Other Parties

We do not sell your Personal Information. We do not “share” Personal Information with third parties for “cross-context behavioural advertising” (“CCBA”).

1. Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

1. Your Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, shared with third parties for CCPA, or disclosed by us; (2) purposes for which categories of Personal Information are collected, sold, or shared with third parties for CCBA by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed Personal Information; and (5) specific pieces of Personal Information we have collected about you.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. We maintain a record of such request as required by the CCPA.

Right to Correct. You have the right to correct inaccurate Personal Information that we maintain about you.

Verification. Requests for access, deletion, or correction of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested pursuant to relevant CCPA requirements, limitations, and regulations.

Right to Opt Out. In some circumstances, you may opt out of the sale of Personal Information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your rights, except where the different price or level of quality of good or service is reasonably related to the value of the data that we receive from you.

Submit Requests.

To exercise your rights under the CCPA, please submit your request to enquiries@aspinaloflondon.com.

1. CCPA Metrics

Each calendar year, we compile various metrics describing how we have complied with requests to delete, access, correct, and opt-out of sale or sharing. To view these metrics please contact us at the above address.

The following information is relating to certain specific state data protection laws. This is not a comprehensive list of all US states who have relevant data protection laws but gives an indication of how Aspinal of London will process data in compliance with state laws.

Delaware Residents

Under the Delaware Personal Data Privacy Act (DPDPA) and subject to certain limitations and exceptions, if you are a Delaware resident, you may have the following additional rights with respect to information we have collected about you that constitutes personal information under the DPDPA;

• To opt-out of any sales of your personal information – you may opt-out of disclosure of your personal information to third parties under certain circumstances.

• To opt-out of targeted advertising – you may opt-out of targeted advertising under certain circumstances.

• To opt-out of profiling for automated decisions – you may opt-out profiling activities which result in an automated decision which has an adverse legal effect or significant affects you in certain circumstances.

Universal Opt-Out Mechanism

Beginning January 1, 2026, we will honor universal opt-out signals, such as those sent via Global Privacy Control (GPC), to respect your preferences regarding the sale of personal data and targeted advertising

Contact details for the Delaware Department of Justice:

Email: privacy@delaware.gov

Colorado Residents

Under the Colorado Privacy Act (“CPA”), and subject to certain limitations and exceptions, if you are a Colorado resident, you may have the following rights with respect to information we have collected about you that constitutes personal information under the CPA:

• To request more details about the personal information we collect about you – to request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months. This includes personal information disclosed for business purposes.

• To request deletion of your personal information – you may request that we delete certain pieces of personal information that we have collected about you.

• To opt-out of any sales of your personal information – you may opt-out of disclosure of your personal information to third parties under certain circumstances.

• To appeal – you may ask that we reconsider our response to decline to take action to any request that you submit in connection with your rights described in the above sections.

If you are a Colorado resident, you may exercise your rights by contacting us at the addresses provided within this privacy notice.

Connecticut Residents

Under the Connecticut Data Privacy Act (“CTDPA”), and subject to certain limitations and exceptions, if you are a Connecticut resident, you may have the following rights with respect to information we have collected about you that constitutes personal information under the CTDPA: Under Senate Bill 6:

• To request more details about the personal information we collect about you – to request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months. This includes personal information disclosed for business purposes.

• To request deletion of your personal information – you may request that we delete certain pieces of personal information that we have collected about you.

• To opt-out of any sales of your personal information – you may opt-out of disclosure of your personal information to third parties under certain circumstances.

• To not be discriminated against for exercising these rights.

Connecticut law requires that we describe certain disclosures of personal information where we receive valuable consideration. Connecticut law treats such disclosures as sales. We do not sell information to third parties as defined under Connecticut law, nor do we sell the personal information of minors.

Connecticut law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. To verify your request, we will check the information you provide us in your request (which may include your name, phone number and email address) against third party identity verification tools or verified information you have previously provided to us. As part of this process, we may call you after you submit your request to verify information. You may also designate an authorized agent to exercise certain of the rights listed above on your behalf by providing the authorized agent with power of attorney pursuant to the Connecticut Probate Code. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.

If you are a Connecticut resident, you may exercise your rights by contacting us at the addresses provided within this privacy notice.

Utah Residents

Under the Utah Consumer Privacy Act (“UCPA”), and subject to certain limitations and exceptions, if you are a Utah resident, you may have the following rights with respect to information we have collected about you that constitutes personal information under the UCPA:

• To request more details about the personal information we collect about you – to request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months. This includes personal information disclosed for business purposes.

• To request deletion of your personal information – you may request that we delete certain pieces of personal information that we have collected about you.

• To opt-out of any sales of your personal information – you may opt-out of disclosure of your personal information to third parties under certain circumstances.

If you are a Utah resident, you may exercise your rights by contacting us at the addresses provided within this privacy notice.

Virginia Residents

Under the Virginia Consumer Data Protection Act (“VCDPA”), and subject to certain limitations and exceptions, if you are a Virginia resident, you may have the following rights with respect to information we have collected about you that constitutes personal information under the VCDPA:

• To request more details about the personal information we collect about you – to request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months. This includes personal information disclosed for business purposes.

• To request deletion of your personal information – you may request that we delete certain pieces of personal information that we have collected about you.

• To request correction of your personal information – you may request that we amend certain pieces of personal information that we have collected about you.

• To opt-out of any sales of your personal information – you may opt-out of disclosure of your personal information to third parties under certain circumstances.

• To not be discriminated against for exercising these rights.

Virginia law requires that we describe certain disclosures of personal information where we receive valuable consideration. Virginia law treats such disclosures as sales. We do not sell information to third parties as defined under Virginia law, nor do we sell the personal information of minors.

Virginia law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. To verify your request, we will check the information you provide us in your request (which may include your name, phone number and email address) against third party identity verification tools or verified information you have previously provided to us. As part of this process, we may call you after you submit your request to verify information. You may also designate an authorized agent to exercise certain of the rights listed above on your behalf by providing the authorized agent with power of attorney pursuant to the Virginia  Probate Code. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf

If you are a Virginia resident, you may exercise your rights by contacting us at the addresses provided within this privacy notice.