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Privacy Notice



How do we share the information we collect?

We are aware that it is ASOS that you are trusting with your information, not some other company. But, to be able to carry out our business, we do need to work with a number of third parties who are experts in their particular fields – after all, we’re good at what we do, but we’re not good at everything! We are very careful who we share your information with, but it is important that you understand when that sharing takes place and why, and that’s what this section explains. The limited instances where we may share your information include:

• We share your information internally within the ASOS Group when required for our business to function: Like any big global business, ASOS is not just a single company, but instead is a group, made up of a number of different company and entities in different parts of the world. We may therefore need to disclose your information (including your personally identifiable information) to any of our group of companies as necessary, in order to operate ASOS and to provide the Services. As they are all part of the ASOS Group, the requirements set out in this notice apply to all of these companies, as equally as they do to ASOS.com Limited

• We share your information externally with our core service providers when required for our business to function: Also like any big global business, ASOS relies on a number of external companies to provide it with key services, products and applications in order to be able to provide the Services. These include for example companies who help us pick and pack orders, make deliveries, support our customers, carry out fraud protection and credit risk reduction checks, support our IT systems, help keep us secure, enable our marketing, audit whether we’re doing what we’re supposed to be doing, or make sure we’re keeping the books right. We just can’t do everything ourselves, after all, and working with experts in various fields enables us to improve our Services for you in the quickest, most efficient way. Each of the external companies we work with has been selected by us for their ability to provide what we need to our required specification, including their ability to handle sensitive data (like your personal information) securely and appropriately. Each of these external companies has a contract with us, which clearly sets out our expectations and requirements in handling any of your information, and holds them fully responsible for meeting those expectations and requirements. On that basis and only on that basis, we may therefore disclose your personal information (including your personally identifiable information) to such third parties who need to be given specific tailored access to your information to facilitate our Services by performing key tasks on our behalf, and who are obligated to only use it in line with our instructions, and not to disclose or use it for other purposes. We are confident that we can trust those third party service providers with your information.

• We share your information when we’re required to comply with a legal request: to do business in all the countries that we do, ASOS is required to liaise with a number of regulators and other law enforcement agencies in each of those countries. Whilst it doesn’t happen often (touch wood!), some of those regulators or agencies may legally require us to share your information with them, under law, under a court order or subpoena, or as a result of some other legal process. If we do come under a legal or regulatory duty to disclose or share your personal data in order to comply with any legal obligation, we will have to share your information (including your personally identifiable information) if we believe that disclosure is reasonably necessary to comply. Having said that, we may dispute such demands when we believe, in our discretion, that the requests are overboard, vague or lack proper authority. We will also attempt to notify you about legal demands for your personally identifiable information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency.

• We share your information where we believe it’s reasonably necessary to protect ASOS or our customers: Sadly, ASOS (like many other companies) can be the subject of attempted fraudulent or criminal activities, which does sometimes require us to take certain steps to protect both our business and our customers. We may therefore disclose your information (including your personally identifiable information) if we have a good faith belief that disclosure is reasonably necessary to (1) detect, investigate, prevent, take action regarding or otherwise address suspected or actual illegal activities, fraud, security or technical issues or to assist government enforcement agencies; (2) enforce or apply our terms and conditions of usage; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Service; or (5) to exercise or protect the rights, property, or safety of ASOS, our customers, or others.

• We share your information externally with other partners when we have your consent to do so: ASOS works with a number of other partners who, whilst not essential for our business to operate, do enhance your experience with ASOS and your usage of the Services, in our opinion. This includes our marketing partners and social media partners (like Facebook or Twitter, if you’ve chosen to link your ASOS account to those services or publish your activity on ASOS to them) as well as third parties to deliver incentives to you to participate in competitions, offers, polls, surveys, analysis or research. We only believe in partnering with companies that we believe are right for ASOS and its customers, and that enhance our Services. On that basis and only on that basis, we may therefore disclose your personal information (including your personally identifiable information) to such third parties who are obligated to ASOS only use it in line with our instructions, and not to disclose or use it for other purposes. We are confident that we can trust those third party service providers with your information. But, as we know that people can feel strongly about their information being shared with companies when it is not essential to do, we will only do so where you have given us your consent to do that. And if you change your mind at any time, we’ll stop that sharing as soon as we can. More details on how to do that are set out below.

• We may share your information externally if we are considering a corporate transaction: We are always looking at ways to make our corporate group stronger and more effective. As a result, we may sometime consider certain corporate transactions, such as a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding. If we were to consider such a transaction, that may involve the transfer of your information (including your personally identifiable information) solely for the purposes of enabling that transaction or proceeding to be assessed. In the event that ASOS sells or buys any business or assets, or if ASOS or substantially all of its assets are acquired by a third party, your personal data which we hold about our customers may be one of the transferred assets.

• We may share aggregated non-personally identifiable information externally: We do also share certain information which, whilst not personally identifiable information relating to you, does include information that relates to your usage of our products, sites and Services, aggregated together with the same information from other users for example. Even though this would not include your personally identifiable information, we nonetheless want you to be able to understand that level of sharing as well. This sharing therefore happens for reasons such as these:

o We may provide reports containing aggregated information about your activities on various pages on our websites, or what are called ‘impressions’, to companies hosting ASOS plugins and similar technologies to help them measure ASOS-generated traffic to their websites.

o We may share aggregated or non-personally identifiable information with our brands and other product providers. For example, we may tell brands stocked on ASOS how many people viewed or purchased one of their product lines.

o We may disclose aggregate, anonymised statistics about the number of visitors to this site or the number of purchases made as required by our investors.

How long do we keep your information for?

In the explanations above, we have tried to be as specific as we can about how long we keep your information for. But in general we retain the information you provide either while your account is in existence, or as needed to be able to provide the Services to you, or (in the case of any contact you may have with our Customer Care team) for as long as is necessary to provide support-related reporting and trend analysis only.
If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also retain some of your information for a limited period of time as required, even after you have closed your account or it is no longer needed to provide the Services to you.

Protecting your security
We are always striving to make sure your information is protected. As soon as we receive your information, we use various security features and procedures, taking into account industry standards, to try to protect the personal information that you provide and to prevent unauthorised access to that information. For example:
• We also offer secure “https” access to the transactional parts of ASOS.com website (that is to the bits where you are required to provide Directly Provided Data). [This includes to existing SSL access over mobile devices]. [We’re working on making secure “https” access a default across ASOS.]

• Access to your data on ASOS is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the ASOS Services. To further secure your credit card, we also don’t keep details of the security code (or CCV number) that you need to input in order to complete an order using your credit card.

• To protect any data you store on our servers, we regularly monitor our system for possible vulnerabilities and attacks, as well as carrying out penetration testing of our own on those systems to try to identify possible improvements. We also use a tier-one secured-access data center.

We will do our best to protect your personal data. Unfortunately, security cannot be guaranteed though. There are therefore a number of general things we would also recommend that you do. Please help keep your account safe by using a strong password that includes characters other than just letters. We will also encourage you not to use the same password across all or many of your online accounts. As emails, instant messaging, and similar means of communication are not encrypted, we also would recommend not communicating any confidential information through these means.

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