Last Updated: 20 December 2022
Space NK values its customers and respects their privacy. Your visit to the Site and your use of any of the services or features we provide is subject to our Terms and Conditions.
Our website is not intended for, and should not be used by, children under the age of 13. We do not knowingly or intentionally collect any information from children under the age of 13.
1. How/when we collect personal information from you
Information you give us: You may give us personal information about you when you:
• visit our website;
• fill in forms on our Site or instore or when you otherwise correspond with us by phone, e-mail or otherwise;
• register to use our Site (which you must do if you would like to use some of the services and features we offer on our Site), subscribe to our marketing communications and services including the Ndulge loyalty programme, or place an order on our Site;
• submit enquiries, feedback, suggestions, ideas or other information;
• participate in our customer satisfaction surveys or other market research;
• fill in any of our product suitability questionnaires (such as skincare or make-up suitability) and/or
• communicate with us via social networking websites, third party apps or similar technologies.
Information we receive from other sources: we may receive information about you if you use any of the other websites we (or any member or brand within our group) operate or other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example sub-contractors in technical, payment and delivery services, advertising networks, marketing services, analytics providers, search information providers, credit reference agencies, etc.) and may receive information about you from them.
2. Personal information we collect about you:
We may collect and process the following personal information about you, that you submit to us, such as:
• contact details (such as your name, address, email address and telephone number);
• demographic information (such as age and/or other information that may identify you as an individual);
• passwords and other authentication information;
• responses to any customer satisfaction surveys or market research (unless these are provided anonymously);
• social media handles;
• financial and credit card information;
• your marketing preferences;
• CCTV footage in our stores; and/or
• additional information you choose to provide us including your date of birth, hair colour, eye colour, make up tone, skin tone, skin type and beauty preferences.
We may also collect information from you automatically. For example, if you contact us with a complaint or query, we may keep a record of any phone number used to call our customer service number as well as the correspondence and the period of time it took for us to deal with a query or any request you had. We may also record your levels of satisfaction with the services we have provided. We will also collect and store your purchase history.
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet;
• your login information
• browser type and version, time zone setting, browser plug-in types and versions;
• operating system and platform; and
• information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information such as scrolling, clicks, and mouse-overs; methods used to browse away from the page.
3. Use made of your personal information
We may use personal information held about you in the following ways:
• to fulfil your order (including acknowledging your order and communicating with you if there is any issue regarding the fulfilment of your order);
• to make sure your order is delivered correctly;
• to provide you with a birthday gift as part of the Ndulge loyalty programme;
• to operate and administer the Ndulge loyalty programme (including the provision of rewards), which may include the sharing of information with carefully selected third party partners;
• to maintain your account;
• to allow you to book an appointment with us or to attend an event;
• to allow you to complete any surveys we send you (if you wish to) or to comment on or review our products or services, to help us improve them;
• to provide you with a more personalised beauty experience (which may include using the information you provide on our suitability questionnaires to automatically recommends suitable products to you);
• for accounting, billing, reporting and audit purposes;
• for credit checking or screening;
• for authentication and identity checks and to distinguish you from other users;
• for credit, debit or other payment card verification and screening;
• to record images for security purposes;
• for debt collection;
• safety, security, training, legal and administrative purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• for customer care support and services such as identifying your shopping preferences and requirements;
• to monitor your use of our website to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
• to improve your shopping experience with us and tailor any marketing or advertising so that it is more relevant to you, for example to keep you up-to-date on our latest fragrance, perfumes, candles, cosmetics, makeup, and body care products, promotional offers and events;
• to notify you of any changes to our services including our Ndulge loyalty programme; and/or
• to conduct marketing analysis to allow us to assess trends and the effectiveness of our advertising and marketing campaigns (including using your personal information to evaluate, analyse or predict certain personal aspects relating to you, such as your preferences, economic situation, interests, and/or location) for example, to build a picture of your interests so that we may tailor our communications to you to ensure they are relevant and of interest to you and so that when you visit our site we can tailor your experience so that it is easier to shop with us.
We may also match or combine the information we collect from you and the information you provide to us with information we receive from other sources (such as social media platforms). We may use the combined information for the purposes set out above (depending on the types of information we receive). This may include your contact details, demographic data, your social media interactions, preferences, shopping habits, interests, geographic location and age or age range. We may use this personal information to tailor and show advertisements more relevant to you either on our website or on third party websites (including social media platforms).
4. Legal basis for processing
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this
legal basis when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our brand.
• Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.
• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
5. Opt-Out of direct marketing
You can at any time tell us not to send you marketing communications (i) by email by clicking on the unsubscribe link within the marketing emails you receive from us; or (ii) by SMS by following the “STOP” instructions provided with the message or (iii) by postal mail by following the instructions that may be included in a particular promotion. If you have registered with us, you may also opt out of receiving postal mail from us by logging into your account and amending your preferences.
6. Disclosure of your information
We may share your personal information with any member or brand within our group, which means our parent undertaking, Manzanita US Investments LP (a US Limited Partnership) and all of its subsidiary undertakings in the fields of luxury beauty, fragrance, cosmetics, home and lifestyle products. Please visit www.manzanitacapital.com for more information about our group and brands.
They may use the information in accordance with their privacy policies for purposes such as: financial reporting and analysis; strategic planning; the development of customer segmentation and metrics to provide a consistent view of our customer base; the creation of inspiring content and editorial features, and the development of new products and collaborations to enhance your experience as a customer of Space NK or other brands within the group.
From time to time we retain the services of other carefully selected and monitored companies and individuals to perform functions on our behalf in connection with the successful operation and continuous improvement of this Site and our services. We may share your information with selected third parties including:
• Suppliers and sub-contractors for the performance of any contract we enter into with them or you (e.g. in order to process your order and maintain your account, including the authorisation and validation of credit or debit card transactions, the provision of delivery services, the analysis of data, etc.). These companies or individuals may be provided with access to your personal details in order to fulfil their function but may not use such information for any other purpose.
the mode that such personalized advertising and marketing are conducted, subject to your consent for the use of your personal information for direct marketing if/where applicable.
• Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
We do not provide your personal details to other companies or individuals for their marketing purposes unless you have indicated when you registered that you wish to receive information about other companies’ products, offers and services in areas including luxury beauty, fragrance and cosmetics.
We may also disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if Space NK (or its ultimate holding company and its subsidiaries) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We may share your personal data where we are under duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our other terms and conditions or other agreements, or to protect our rights, property, or safety (or the rights, property, safety of our customers or others). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside of the country in which it was originally collected including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK.
The reason for this transfer is that some of the operations we need managed in order to complete our contract with you are located outside of the EEA or the UK, for instance, it may be processed by staff working outside of the EEA or the UK who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
8. Security and passwords
We use the latest strong encryption technology to ensure that all transactional information is protected to the highest standard. Transactional information includes any credit or debit card details, your personal contact information together with any other names and addresses you provide when you place an order for delivery to another address, and your purchasing history. If you have given your consent prior to entering the details required for the ordering process, our Site will retain your Space NK account details
such as your name, address, email address and purchasing history. Each time you log into your Space NK account to create a new order you must re-enter your credit card details.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9. Third Party Websites
Our Site 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.
10. Data Retention and Destruction
We store data for as long as it is necessary to provide products and services to you and others as long as we are legally required to do so. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.
11. Rights of Data Subjects
You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information. To the extent the processing is based on your consent, you may withdraw your consent at any time.
If you wish to exercise any of your rights, please send your request via the link here or alternatively you may contact us via email at email@example.com or by post to:
Head of Customer Experience
Space NK Limited, 5th Floor, Shropshire House
11 – 30 Capper Street, London
WC1E 6JA, United Kingdom
We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights, please contact us using the contact details below.
You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.
14. UK data protection representative
Representative in the United Kingdom:
FAO: Chief Technology Officer Space NK Limited
5th Floor, Shropshire House 11-30 Capper Street London, WC1E 6JA United Kingdom
15. EU data protection representative
Representative of controllers or processors not established in the European Union (Article 27 GDPR):
ePrivacy GmbH Große Bleichen 21 20354 Hamburg Germany