Privacy Policy

The website www.loake.com (the Website) is owned and operated by Loake Brothers Limited (“We”).

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we collect, process and look after your personal data when you shop with us online or communicate with us, and tell you about your privacy rights and how the law protects you.

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you create an account, join the Loake Members’ Club, purchase a product or service or take part in a competition.

This Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing 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 privacy notice supplements the other notices and is not intended to override them.

This policy should be read in conjunction with the following policies which also apply to your use of our Website:

• Our Terms and Conditions; and

• Our Cookie Policy

1.2 Controller

We are the controller and are responsible for your personal data.

1.3 Contact Details

Our full details are:

Company name: Loake Brothers Limited
Company number: 00043081
Contact name: Mark Povey – Data Protection Officer
Email address: mark@js-ig.com

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

1.4 Changes to the privacy notice and your duty to inform us of changes

This version was last updated in January 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

1.5 Third-Party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

2.1 Personal data, or personal information, means any information about an 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 and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username, Loake Members’ Club number or similar identifier.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. It will also include any Loake Members’ Club points or other benefits earned as part of the transaction.

• Technical Data includes traffic data, location data, weblogs and other communication data.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

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 and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 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 and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with 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.

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

• Direct interactions. You may provide us with your Identity, Contact, and Financial Data through forms or by communicating with us via post, phone, email, or other means. This includes when you apply for products or services, create an account on our website, join the Loake Members’ Club, subscribe to our services or publications, request marketing, participate in competitions, promotions, or surveys, or provide feedback.

• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

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:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details from section 1.3.

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:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details from section 1.3.

4.1 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

4.2 Marketing

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or are part of Loake Members’ Club, but only if you opted in for receiving such communications.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or are part of Loake Members’ Club, but only if you opted in for receiving such communications. and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

Personal information you provide to us will be made available to our Marketing team.
For the purpose of organising successful marketing campaigns, we might share your personal data with trusted third parties that are our contractors. You will be informed if that is the case, or asked for consent, depending on the case. We will always take into account the reason behind the necessity to share personal data with third parties, the jurisdiction where data will be sent to, what safeguards can be implemented etc.

We will also share your data for statistical analysis (it will be anonymised first).
We may also share data with a legal authority (police etc.) if we are required to do so by law – for example, by court order, or to prevent fraud or other crime.

Transferring information outside the UK

We will not transfer your personal data outside the UK. In exceptional cases, if that is necessary, we will rely on the lawful mechanisms allowed by the UK GDPR and the DPA 2018 and we will ask for your consent if other mechanisms cannot be applied.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or any other transactions between us for the purposes related to such activities.

4.3 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If 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 the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Professional advisers acting as processors or joint controllers including lawyers , auditors and insurers who provide consultancy, legal and insurance services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the European Economic Area (EEA).

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

How long will you use my personal data for?

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 contractual, legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a specific 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. All these details are detailed within our Data Retention Policy, applicable internally.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. However, there may be cases where we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details from section 1.3.

9.1 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3 Time Limit to respond

We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a larger number of requests. In this case, we will notify you and keep you updated.

We are committed to ensuring a balance between respecting your privacy rights and protecting our business interests.

We invest in innovation and in security at the same time. Therefore, we use Klaviyo as our business intelligence (BI) tool with the scope of improving our business, whilst maintaining a safe environment for your data protection. Klaviyo will act as a data processor, meaning it will process your personal data on our behalf and under our instructions. Klaviyo will process your personal data via cookies. For more details please check our Cookie Notice.

This is possible under the condition you consent to this process. Unless we have your consent, we cannot provide you with the best online experience and access to our services shall be limited.

At the same time, we use Google for ads personalisation, in line with the UK GDPR and DPA 2018. That means Google will have access to personal data collected via cookies. Please make sure you have read and understood how they will use your personal data as per https://policies.google.com/technologies/partner-sites

If you have any questions related to this, please contact our DPO and we will discuss your concerns with Google.

In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

We may change this privacy notice. When we make changes to this notice, the ‘last updated’ date at the top of this page will also change. Any changes to this privacy notice will apply to you and your data immediately. If these changes affect how your personal data is processed, we will take reasonable steps to let you know.