Privacy Policy

Last updated: May 20th 2024

La Senza Canada, Inc. and its affiliates (collectively, “La Senza”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. This privacy policy (this “Privacy Policy”) together with our terms and conditions explain how La Senza collects, stores, uses, transfers, and discloses your personal information (as defined below).

This Privacy Policy applies to our websites and mobile applications (if any) and the services we provide (collectively, the “Site”), the stores we own or operate in the United States and Canada (the “Stores”), and when you otherwise engage our products or services, including, for example, if you contact our customer service offline (collectively, the “Services”).

We have franchise agreements with franchisees in a number of countries around the world. Under these agreements, third parties operate (or will operate) stores, shop-in-shops, and websites that sell apparel and related products under our brand names. Personal information collected by a franchisee is subject to the franchisee's own privacy policies. Please be sure to review other privacy policies that may apply.

This Site may also link to or incorporate websites or content hosted and served by others over which we have no control, such as third-party websites, online properties, platforms, social media, or systems, which are each governed by the privacy policy and business practices of the third party. You understand and agree that La Senza is not responsible for the security, privacy, or business practices of any third party and such practices are not covered by this Privacy Policy.

Table of Contents

Information We Collect

This section explains, for different situations, what information we may collect directly from you (either on a voluntary basis or through automated means) and what information may be collected (or we may receive) from other sources. Some of this information may be considered "personal information" under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as your name, telephone number, and e-mail address), as well as additional information, including IP addresses and cookie identifiers, where required by applicable law. And, if we combine information that we consider to be non-personal with personal information, we will treat the combined information as personal information under this Privacy Policy. In the limited circumstances in which we may process sensitive personal information as defined by applicable law, we process such information as permitted by and in compliance with applicable law. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or transforming it into information that does not identify you. We will treat de-identified information as non-personal to the fullest extent permitted by applicable law. Where collection is mandatory, we may not be able to provide you with the product or service you requested if you choose not to provide that information to us (e.g., name and delivery address for the delivery of a product). Please see the supplemental notices further below for additional information that may apply to you based on your location.

Information You Provide. We, or service providers that assist us in providing, maintaining, and operating the Services, may collect the following types of personal information from you:

• Identifiers: such as your name, postal address, email address, social media handle, telephone number, or identification materials used to verify eligibility for discounts and other offers and/or when you register for an account or otherwise interact with our Services;
• Demographic information: such as your age, date of birth, or gender;
• Transaction information: such as information regarding purchases, returns or exchanges; product reviews you provide; clothing size/fit information;
• Payment information: including gift card information;
• Communications: such as your contact information and identifiers and also the records of communications and our responses, whether related to transactions or otherwise, as well as records of information that you post on our social media channels, and information you provide to us related to any customer support requests;
• Information related to Sweepstakes, Contests and Promotions: such as your identifiers and other personal information and other registration information related to contests, sweepstakes, and promotions in which you elect to participate; and
• Customer content: such as photos, videos, blog posts, social media posts, product reviews or direct or personal messages sent to us on social media platforms.

Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with our Services. We may collect the following types of information automatically from you:

• Identifiers: such as device ID, IP address, and online identifiers, such as cookie data;
• Online activity and browsing information: such as device type; browser types and version; browsing history; search history; interactions with our websites, applications, communications, and advertisements; referring sites; network activities when using our Wi-Fi; and content and pages viewed;
• Location information: such as geo-location of your devices and in-store location;
• Audiovisual information: such as call recordings and closed-circuit television (CCTV) footage if you visit our Stores;
• Browsing behavior on our websites: such as when and how you visit our website, the amount of time spent viewing our website, the buttons and links you click, videos you watch, and where you scroll on our website, the search terms that you enter in our website, and the form submissions, purchases, and transactions you make through the website;
• Behavior related to emails: such as the buttons and links you click, the date and time an email was opened, whether an email was forwarded, and whether an email led to a sale;
• Text or other messages sent or shared through chat or chatbot services; and
• Inferences: To personalize your experience with the Services, we may draw inferences using your personal information, to create a profile reflecting your interests, preferences, and characteristics.

Information We Collect from Third Parties.

We may collect information about you from activities related to other affiliated businesses or third parties who provide services to us or to you, like analytics, advertising, and technology companies. These third parties share information they have collected with us. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices. Your information may also be shared with us by others, such as your friends and family, when they use the Services, for example, by sending you a gift card or shipping an order to your address. We may also obtain information from social media companies, for example, when you interact with content or features provided by social media platforms on our Services or our content or ads on social media platforms. The information that we obtain from social media platforms depends on your account and privacy settings within the platforms and the platforms privacy policies.

We and our third-party business partners may collect information about your visits to and activity on the Site and with the Services. We may combine that information with other personal information we have collected from or about you. We may share certain of this information with third party business partners for similar purposes as described in this Privacy Policy.

Cookies and Other Technologies

In common with many other website and app operators, we use standard technology called “cookies” and similar technologies on our website, including to automatically collect the information described above. Cookies are small pieces of information that are stored by your browser; they are used to record how you navigate the Site on each visit. When we refer to cookies, this term includes all means by which we may store information on an end-user’s device and/or retrieve information that is stored on such end-user’s device beforehand., including through equivalent server-side tracking. The information collected by these cookies and similar technologies may include your: IP address; unique cookie identifier and information obtained through cookies; unique device identifier and device type; domain, browser type and language, operating system, and system settings; country and time zone; previously visited websites; information about your interaction with our Platform such as click behavior, purchases and indicated preferences; and access times and referring URLs. For more detailed information on how we use cookies and also to manage your cookie preferences at any time, you may click on the “Cookie Settings” button in the footer.

The Site also uses Google Analytics. Google Analytics uses cookies and similar technologies to collect and analyze information about the use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. For information from Google about opting out, click here, and to download the Google Analytics opt-out browser add-on from Google, click here.

How We Use Your Personal Information

We use your personal information as described in this Privacy Policy for business and commercial purposes, including to:

• provide content, products, and services, including the operational, management, and billing support necessary to accomplish those business purposes;
• provide you and others with customer service, to assist in resolving issues, and to evaluate and improve our customer service and processes;
• post content you provide to us (e.g. your product reviews), including using such content on our social media accounts and other marketing platforms where permitted;
• communicate with you, including providing you with:
  • information about your account, transactions, new features of the Services, and changes to our policies,
  • inform you if products or services you have requested are back in stock or unavailable;
  • to communicate with you in the event that you have abandoned your online basket;
  • to carry out market research so that we can improve the products and services we offer; and
  • where you have provided specific consent, offers or promotions for products, services, or special events;
• personalize content and experiences, including providing recommendations based on your preferences;
• provide advertising including advertising based on your activity with the Services or activity on third-party websites;
• administer contests, sweepstakes, promotions, or surveys;
• maintain, protect, optimize or improve our Services and operations, including to personalize and improve your experiences and/or tailor any communications that we may send you;
• detect, investigate, and prevent activities that may violate our policies or be illegal;
• perform statistical, demographic, and marketing analyses of users of the Services and their purchasing patterns;
• compile aggregate data about Site and Store traffic and interaction;
• create advertising models through lookalike modelling or other research methodologies;
• identify and prevent fraud and other criminal activities, such as monitoring and reviewing CCTV footage;
• process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions;
• for internal business purposes, such as improving our Services and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies; and
• for other reasons that (i) we disclose at the point of collection, (ii) with your consent, or (iii) as described in this Privacy Policy.

Sharing Your Personal Information

We share non-personal information, such as aggregated statistics and de-identified information, with third parties to the extent permitted by applicable law. La Senza also shares personal information as provided below in more detail. We do not share personal information with any unaffiliated third party to use for its own marketing or promotional purposes without your consent.

• Affiliated Brands & Companies: We may share your information between various brands owned by La Senza or under common control, including Club Monaco, Intermix, Escada, DIM, and other related companies.
• Service Providers: We partner with third parties to assist with many aspects of our e-commerce business, including fulfilling orders, advertising, analyzing your interests and activity on our Services, and helping us communicate with customers. These third parties may provide services related to any of the purposes described in How We Use Your Personal Information, and we may share with them any types of information described in Information We Collect. We may also receive information collected by these third parties and combine it with the information we have collected. Some of these third parties may be located outside the United States, Canada or the nation in which you reside. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
• Marketing Providers: We partner with third parties to assist with the advertising and marketing of our business, including as necessary to conduct and administer a sweepstakes, contest or promotion. We may share with them the types of information described in Information We Collect. We may also receive information collected by these third parties and combine it with the information we have collected.
• Other Third Parties: We may disclose your personal information if we believe it is necessary to protect and defend our rights, property, or safety or when we believe the disclosure is necessary to protect the rights, property, or safety of another, including for the purpose of enforcing our terms and conditions, or where the law and / or government authorities require. This disclosure may include legal requests from a jurisdiction outside of the United States when we have a good faith belief that the response is required by law, regulation, court order, or other legal request or process in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally-recognized standards.
• Parties to a Business Transaction: We may disclose or transfer your information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, or any other transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.
• Other Disclosures: We may disclose your information to other third parties when we have your consent or direction to do so.

Security

We maintain appropriate administrative, technical and physical safeguards to protect the personal information you provide on this website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and you use the Services and transmit information to us at your own risk. If you have any questions about security on our Services, please contact us as provided below.

How Long We Retain Your Personal Information

We keep the personal information we collect for the duration of our relationship with you, plus a reasonable period in order to take into account the applicable legal retention requirement or statute of limitation period, or otherwise as required for our business purposes described in this Privacy Policy.

If you consent to receive marketing communications, we will keep the information necessary to send you these communications for as long as we have a legitimate business purpose to retain the data, as long as permitted by law, or until you request we delete the data if such a right exists in your jurisdiction.

At the end of the retention period, your personal information will be deleted completely or anonymized so that it can be used in a non-identifiable way for statistical and analytical purposes.

Data Transfers

Your information will be collected, processed, and stored directly on or transferred to servers in the U.S. In addition, it may be transferred to other countries where La Senza, its affiliates, or third-party business partners maintain facilities or business operations, which may include countries outside Canada, the United Kingdom (UK) or European Economic Area (EEA). No matter where the information is located, La Senza takes commercially reasonable measures to safeguard your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage and transfer of your information, please do not provide your information to us and stop using our Services. If you have questions, please contact us as provided below.

Your Choices and Rights

Communications Preferences

You are free to withdraw your consent and opt out of receiving marketing emails from La Senza by following the instructions in any marketing email you receive or by logging into your online account and adjusting your preferences. Please note that if you do opt out, it may take a few days to process your request and that you may continue to receive promotional or marketing materials during this time. Opting out will not preclude us from sending you other types of non-promotional messages, such as emails confirming transactions.

To stop receiving promotional text messages, please follow the instructions provided in those communications or contact us as provided below. You will receive a text confirming you have been unsubscribed. To manage your cookie preferences, use the settings in your web browser.

Your Rights

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

• request access to your personal data that we hold;
• request correction of the personal data we hold about you if it is incorrect, out of date or incomplete;
• request erasure of your personal data, for example where the information is no longer necessary for the purpose which it was collected for, or you withdraw your consent for us to hold such information;
• object to processing of your personal data;
• request the restriction of processing of your personal data, for example where you suspect the information held is inaccurate, or is being used in an unlawful manner but you do not want it to be erased (i.e. if required for establishment or defense of a legal claim);
• request that we transfer your personal data to another organization, where it is technically feasible; and/or
• withdraw your consent at any time and request we discontinue any consent-based processing of your personal data after you withdraw that consent.

Please note that where you subsequently object to our processing, or otherwise request that your data is erased, we will be required to retain some of your personal data until we have delivered your ordered goods or performed your requested services, unless you inform us you wish to cancel your order.

When exercising any of the rights listed above, we will ask you to verify your identity before proceeding to ensure that your personal data is adequately protected from unauthorized use. Likewise, if you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. Please see the supplemental notices below for more information relevant to your jurisdiction, if applicable.

Children's Privacy

Our Services are not directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 on our Services, we will delete the information from our records, unless we have a legitimate interest or are under a legal obligation to postpone deletion.

Changes to Our Privacy Policy

This policy is effective as of the date set forth above. Changes made in the future will be posted on this page. Please check this page for any updates or changes.

How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us via email at at [email protected] or via mail at:

 La Senza Canada, Inc.
 4100 Regent Street, Suite T
 Columbus, OH, 43219

Supplemental Notices to Residents of California and Certain U.S. States

The following is a list of categories of personal information which may have been collected from consumers or users of the Services within the last twelve (12) months, along with the categories of third parties to whom each category of personal information was disclosed. The categories and examples provided in the chart below are those defined in the California Consumer Privacy Act of 2018 (as amended, the “CCPA”). This does not mean that all examples of that category of Personal Information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about consumers. We will update this disclosure from time to time as appropriate.

California and certain other U.S. states provide their state residents with rights to (as applicable):

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Data portability.
• Opt-out of personal data processing for targeted advertising, sales; or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state.

You may also have the right (for example, under California Civil Code § 1798.83) to periodically request and obtain from us the details of any personal information we shared with a third party for the third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.

To exercise any of these rights or appeal a decision regarding the same, you may contact us as indicated above. To change your consent settings for our use of cookies and other technologies, please click on “Cookie Settings” in the footer below.

From time to time, we may offer free shipping, order discounts, or other benefits to consumers who provide us their email address, phone number, and/or zip codes when they sign up to receive our marketing communications. Consumers may opt in by entering their information where prompted on the Site or in Stores. Consumers may opt out at any time by following the unsubscribe instructions in our marketing communications and/or through managing account preferences on the Site. The value of the consumer information that we collect is reasonably related to the expenses of providing the discounts and other benefits (which may vary depending upon the specific benefits offered or the value of the consumer relationship in terms of purchases).

We do not sell your covered information as defined under applicable Nevada law.

Supplemental Notices to Residents of the UK and EEA

In the event La Senza collects personally identifiable information from individuals in the EEA and UK through the Services, it is the controller for the purposes of the General Data Protection Regulation (EU) 2016/679 and the UK GDPR, and "personal information" as used in this Privacy Policy is "personal data," as defined in Article 4(1) of the GDPR and UK GDPR.

Basis for Processing

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, including, administering your account subject to our terms, facilitating your purchases, maintaining the Services, providing customer service and administering promotions you have entered.
• Consent: This is where we have asked you to provide permission to process your data for a particular purpose, for example, to send you marketing messages by e-mail or other advertising.
• 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, including, among other things, providing requested customer and technical support, monitoring and protecting the Site and payment transactions, or establishing, exercising, or defending legal claims or in connection with any court or jurisdiction .
• Legal Obligation: To process your information for compliance with any legal obligation to which La Senza is subject.

Your Rights

Subject to applicable law, you may be able to exercise any of the following rights in relation to your personal information:

• Right to know what information we have about you: This is known as the "right of access" and gives you the right to find out what, if any, personal information we have about you, how we process it, and to request a copy of the personal information.
• Right to correct your information: This is known as the "right of rectification" and gives you the right to ask that we correct or complete any personal information we have about you.
• Right to delete your information: This is known as the "right to erasure" or "right to be forgotten" and gives you the right to ask us to delete your personal information.
• Right to change how we use your information: This is known as the "right to restrict processing" and gives you the right to ask us to change how we use your personal information in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.
• Right to move your information: This is known as the "right to data portability" and gives you the right to ask to receive your personal information from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.
• Right to stop us from using your information: This is known as the "right to object" and gives you the right to ask us to stop using your personal information when applicable.
• Rights relating to how we use your information to categorize you or make decisions about you: This is known as the "right in relation to automated decision-making and profiling": You have the right to be free from decisions we may make that are based solely on automated processing of your personal information, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.
• Right to withdraw consent: If we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.
• Right to file a complaint with the supervisory authority: If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the supervisory authority that is authorized to hear those concerns in your jurisdiction, although we invite you to Contact Us with any concern as we would be happy to try and resolve it directly.

You may exercise your rights by contacting us as indicated under the Contact Us section above. To change your consent settings for our use of cookies and other technologies, please see the Your Rights section above and/or click on “Cookie Setting” in the footer.

The requests above will be considered and responded to in the time period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.