Privacy Policy

At Haru, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy, together with the Terms of Service for our app and websites (together, our “Terms of Use”) apply to your use of:

  • The Haru App (the “App”)

  • The clear out services accessible through the App (the Services) that are also available on other sites of ours (our “Sites”).

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

1. Who Are We

Reform Clothing Ltd is the controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this policy.) Our contact details are as follows:

Reform Clothing Limited t/a Haru Company Registration Number: NI674281 14a Falcon Rd, Belfast, BT12 6RD, Email: support@haru.co.uk Phone: +44 28 9568 3595

2. Information We Collect

a. We may collect, use, store and transfer the following types of data about you:

  • Identity Data: first name, last name, date of birth, gender

  • Contact Data: billing address, delivery address, email address and telephone numbers

  • Financial Data: bank account details

  • Transaction Data: details about payments to and from you

  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), the type of mobile browser you use, and time zone settings

  • Profile Data: includes your email and password, in-App transaction history, your interests, preferences, feedback and survey responses

  • Usage Data: includes details of your use of any of our Apps or your visits to any of our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise.

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

b. 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, criminal records, information about your health, and genetic and biometric data).

c. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3. How We Collect This Information

a. Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms in our App or on our Sites, or by corresponding with us (for example, by email or chat). It includes information you provide when you download or register an App, subscribe to any of our Services, search for an App or Service, complete an in-App transaction, enter a competition, promotion or survey, and when you report a problem with an App, our Service, or any of our Sites. If you contact us, we will keep a record of that correspondence.

b. Information we collect about you and your device. Each time you visit one of our Sites or use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.

4. How We Use Your Personal Data

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

  • Where you have consented before the processing.

  • Where we need to perform a contract, we are about to enter or have entered with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

b. We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

c. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

d. If you would like more information about our legal basis for processing your data, feel free to contact us.

5. Purposes For Which We Use Your Personal Data

Purpose/Activity: To install the App and register you as a new App user Type of Data: Identity, Contact, Financial, Device Basis for Processing: Consent

Purpose/Activity: To deliver Services including managing payments and collecting money owed to us Type of Data: Identity, Contact, Financial, Transaction, Device, Marketing and Communications Basis for Processing: Your consent, Performance of a contract with you, Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity: To manage our relationship with you including notifying you of changes to the App or any Services Type of Data: Identity, Contact, Financial, Profile, Marketing and Communications Basis for Processing: Your consent, Performance of a contract with you, Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

Purpose/Activity: To enable you to participate in a prize draw, competition or complete a survey Type of Data: Identity, Contact, Device, Profile, Marketing and Communications Basis for Processing: Your consent, Performance of a contract with you, Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

Purpose/Activity: To administer and protect our business and this App including troubleshooting, data analysis and system testing Type of Data: Identity, Contact, Device Basis for Processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

Purpose/Activity:

  • To deliver content and advertisements to you

  • To make recommendations to you about goods or services which may interest you

  • To measure and analyse the effectiveness of the advertising we serve you

  • To monitor trends so we can improve the App

Type of Data: Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications Basis for Processing: Consent, Necessary for our legitimate interests (to develop our products/Services and grow our business)

6. Disclosure of Information

a. When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out at paragraph 6 above.

b. The following third-party service providers assist us in operating the App and providing the Services.

Third Party Name: Stripe Services Provided: Payment Processing Acting As: Processor

Third Party Name: Google Analytics Services Provided: Analytics Acting As: Processor

Third Party Name: Amazon Web Services Services Provided: Cloud Data Storage Acting As: Processor

Third Party Name: Klaviyo Services Provided: Email Automation Acting As: Processor

Third Party Name: eDesk Services Provided: Customer Service Acting As: Processor

Third Party Name: Veeqo Services Provided: Inventory Tracking Acting As: Processor

Third Party Name: Google Gemini Services Provided: Image Recognition Acting As: Processor

Third Party Name: Professional Advisors (e.g., lawyers, bankers, auditors & insurers) Services Provided: Advice in relation to the operation of our business and the provision of the Services Acting As: Processor Based in: UK

Third Party Name: HM Revenue & Customers, Regulators, and other authorities Services Provided: Reporting of processing activities in accordance with applicable laws Acting As: Processor Based in: UK

c. Where third party service providers are based outside the UK or EEA, their processing of your personal data will involve a transfer of data outside the UK and EEA.

d. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government and European Commission.

  • Where we use certain service providers, we may use specific contracts approved by the UK Government and/or the European Commission (as applicable) which give personal data the same protection it has in the UK.

e. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data Security

a. All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party payment processor will be securely encrypted. b. You are responsible for keeping any password required to access your account or any of our Sites confidential. You should not share this password with anyone. c. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way. d. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

8. Data Retention

a. We will retain your personal data in accordance with our data retention policy (a copy of which is available from us on request). A summary is provided below for your convenience:

  • Contractual Obligations: If customer data was collected as part of a contract (e.g., purchase records, service agreements), we retain the data for as long as the contract is in force and for a reasonable period afterward, up to 6 years.

  • Legal and Regulatory Requirements: Certain types of data must be retained for specific periods due to legal or regulatory requirements. For example:

    • Tax records: Must be kept for at least 6 years after the end of the tax year they relate to, according to HMRC requirements.

    • Financial records: 6 years, for financial records to comply with UK tax and accounting laws.

  • Consent-Based Data: If customer data is processed based on consent (e.g., marketing preferences), we retain it only as long as the consent is valid or until the customer withdraws their consent.

b. In some circumstances we will anonymise your personal data for research or statistical purposes. We may use this anonymised information indefinitely without further notice to you.

9. Your Legal Rights

a. You can control and manage the information you provide to us through the settings in the App.

b. You also have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, deleted, or transferred to you or a third party. If you would like to exercise these rights, please contact us as set out below.

c. You may also choose to delete your account at any time, although please note that we may retain certain data as required by law or as otherwise permitted by law.

10. Children's Privacy

Our App, Services and Sites are not intended for use by children (those under the age of 18), and we do not knowingly collect personal information from children. If you believe that we have inadvertently collected information from a child, please contact us immediately.

11. Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the distribution platform (app store) or our Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of our Sites and allows us to improve the App and our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, please contact us or see our cookie policy.

12. Changes To This Privacy Policy

a. We keep our privacy policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto one of the Sites. You may be required to read and accept the changes to continue your use of the App or the Services.

b. 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 our relationship with you.

13. Unsubscribe

If you’ve subscribed to our newsletters or asked to receive marketing material from us, you can always unsubscribe. In all these emails we include an unsubscribe link and you can always click the link and easily unsubscribe. You can also unsubscribe by sending us an email to the contact address below.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our practices, please contact us at support@haru.co.uk.

15. Complaints

Please contact us if you have any queries or concerns about our use of your personal data (see above ‘Contact Us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

  • the Information Commissioner in the UK

  • a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see here.

This Privacy Policy was last updated on 29 Aug 2024 (v1.3).