Lovehoney Privacy Policy
Our mission statement
We at Lovehoney Group understand that your Personal Information is exceptionally important to you, especially given the nature of our website and the products we sell, and when you trust us with it, we have a duty to keep it safe and secure. To that end you can be assured that our data handling policies and standards are fully in line with the current data protection legislation.
Overview
This Privacy Policy informs you about the types of Personal Information we collect, how we process it, the purposes for which we use it, and the rights you may have as a data subject.
Lovehoney Group is a global company with operations worldwide. Depending on your location and the website you use, specific conditions may apply to the processing of your data. Please refer to Section II. for more information.
You can always see which website and region the Privacy Policy applies to at the top of each website. To view the Privacy Policy for other websites or regions, simply change the selection there.
This Privacy Policy sets out our global principles for the collection, use, and disclosure of personal data. Please also refer to the country-specific information at the bottom of this page.
I. Who this Policy applies to
II. Who is collecting your Personal Information
III. How we process your Personal Information
1. Temporary Storage of Usage Data
2. Storage of the IP Address for Security Purposes
3. Obligation to Provide Personal Data
4. Storage Duration
5. Webshop / User Account
5.1. Registration and Login
5.2. Order Processing
5.3. Track Your Order
5.4. Availability Notification
5.5. Customer Reviews
6. When contacting us
7. Chatbots
8. Newsletters & Marketing Communications
8.1. Direct Advertising
8.2. Newsletter Tracking
9. Campaigns
10. Suppliers and Business Partners
11. Job Applications
12. Processors and Service Providers
13. Sharing Personal Data within the Group of Companies and other International Data Transfers
14. Data Security
15. Cookies
15.1. Required Cookies
15.2. Visitor Measurement (Cookies for Analysis Purposes)
15.3. Tracking Technologies from Third-Party Providers for Advertising Purposes 15.4. Integration of Other Technical Third-Party Content and Functions
15.5. Embedded Videos and Players
15.6. Map Services
15.7. Affiliate Marketing
15.8. Captcha
16. Social Media
17. Product Testing Campaigns
IV. Your Rights
V. Supplementary Country-Specific Information
1. US State Residents’ Additional Information
2. Canada Residents’ Additional Information
3. Australian Residents’ Additional Information
4. New Zealand Residents' Additional Information
5. Japan Residents' Additional Information
VI. Contact us and Data Protection Officer
VII. Updates to the Privacy Policy
I. Who this Policy applies to
· This Privacy Policy applies, inter alia, to: visitors to our websites;
· customers;
· users who create an account with us;
· campaign participants;
· job applicants, and
· suppliers and other business partners
Depending on your relationship with us, we may collect and use your personal information in different ways. Please refer to the sections below to learn more about what information we collect about you and how we use that information.
II. Who is collecting your Personal Information
As Lovehoney Group is a global company with operations worldwide, depending on which website you visit or which company within our group you interact with, the business responsible for processing your personal information may vary.
You can always see which website and region the Privacy Policy applies to at the top of each website. To view the Privacy Policy for other websites or regions, simply change the selection there.
Here is an overview of which company within the Lovehoney Group is data controller and business responsible for which website. All references in this Privacy Policy to “we”, “us” or “our” refer to this company.
Lovehoney
lovehoney.co.uk, lovehoney.eu, lovehoney.net, lhboutique.co.uk, lovehoneyforum.com: Lovehoney Limited, 100 Locksbrook Road, Bath BA1 3EN, UK
lovehoney.com: Lovehoney LLC, 5156 Southridge Parkway, Suite 110, College Park, Georgia, 30349, USA
lovehoney.com.au, lovehoney.co.nz: Lovehoney Australia Pty Limited, Grant Thornton, King George Central, Level 18 145 Ann Street, Brisbane QLD 4000, Australia
lovehoney.ca: Lovehoney Canada Inc., 1741 Lower Water Street, Suite 600, Halifax, Nova Scotia, B3J 0J2, Canada
Womanizer
womanizer.com/uk, womanizer.com/eu, womanizer.com/de, womanizer.com/fr, womanizer.com/ch, womanizer.com/au: WOW Tech Europe GmbH, Hermann-Blankenstein-Str. 5, 10249 Berlin, Germany
womanizer.com/us: WOW Tech USA Ltd., 103 Foulk Road, Suite 202, Wilmington Delaware, 19803-3741, USA
womanizer.com/ca-en: WOW Tech Canada Ltd., 1545 Carling Avenue, Suite 401, Ottawa, Ontario, K1Z 8P9, Canada
womanizer.com/jp: WOW Tech APAC Ltd., Unit A, 23/F, Gee Chang Hong Centre, 65 Wong Chuk Hang Road, Wong Chuk Hang, Hong Kong
We-Vibe
we-vibe.com/uk, we-vibe.com/eu, we-vibe.com/de, we-vibe.com/fr, we-vibe.com/ch: WOW Tech Europe GmbH, Hermann-Blankenstein-Str. 5, 10249 Berlin, Germany
we-vibe.com/us, we-vibe.com/au: WOW Tech USA Ltd., 103 Foulk Road, Suite 202, Wilmington Delaware, 19803-3741, USA
we-vibe.com/ca-en: WOW Tech Canada Ltd., 1545 Carling Avenue, Suite 401, Ottawa, Ontario, K1Z 8P9, Canada
Romp
romp.toys/uk, romp.toys/eu: WOW Tech Europe GmbH, Hermann-Blankenstein-Str. 5, 10249 Berlin, Germany
romp.toys/us: WOW Tech USA Ltd., 103 Foulk Road, Suite 202, Wilmington Delaware, 19803-3741, USA
romp.toys/ca-en: WOW Tech Canada Ltd., 1545 Carling Avenue, Suite 401, Ottawa, Ontario, K1Z 8P9, Canada
Arcwave
arcwave.com/uk, arcwave.com/eu, arcwave.com/de, arcwave.com/fr, arcwave.com/ch, arcwave.com/au, arcwave.com/jp: WOW Tech Europe GmbH, Hermann-Blankenstein-Str. 5, 10249 Berlin, Germany
arcwave.com/us: WOW Tech USA Ltd., 103 Foulk Road, Suite 202, Wilmington Delaware, 19803-3741, USA
arcwave.com/ca-en: WOW Tech Canada Ltd., 1545 Carling Avenue, Suite 401, Ottawa, Ontario, K1Z 8P9, Canada
III. How we process your Personal Information
1. Temporary Storage of Usage Data
When you visit our websites, so-called usage data is temporarily analyzed on our web server for statistical purposes as log data in order to improve the quality of our websites. This data record consists of
• the name and address of the requested content,
• the date and time of the request,
• the amount of data transferred,
• the access status (content transferred, content not found),
• the description of the web browser and operating system used,
• the referral link, which indicates the page used to connect to our site,
• the IP address of the requesting computer, shortened in such a way that a personal reference can no longer be established.
The aforementioned log data is only analyzed in anonymized form. The legal basis for the processing of usage data is our legitimate interest in providing the content of the website and ensuring a device- and browser-optimized display.
2. Storage of the IP Address for Security Purposes
In addition, we store the full IP address transmitted by your web browser for seven days in the legitimate interest of recognizing, limiting and eliminating attacks on our websites. After this period has expired, we delete or anonymize the IP address.
3. Obligation to Provide Personal Data
Providing your personal data to us is not required by law and is voluntary. However, the provision of your data is necessary for the use of certain services. This applies, for example, to your usage data, without which we cannot technically offer our website content. Failure to provide required data will result in us being unable to provide the service or function in question. In the case of optional data, failure to provide it may mean that our services are unable to provide in the same form and extent as usual.
4. Storage Duration
Unless we specifically provide detailed information about the storage period elsewhere, we delete personal data when it is no longer required for the processing purposes and there are no legitimate interests or other (legal) reasons for storage that prevent deletion.
5. Webshop / User Account
5.1. Registration and Login
You have the option of registering in our webshop. Registration is not necessary to place an order. We only collect the data required for registration and provision of the service (e.g., name, e-mail address, date of birth, password). For the purpose of registration, we collect your e-mail address and your chosen password. You can also log in with your Google or Apple account. In this case, we receive the email address and your name from Google LLC or Apple, Inc. The processing is necessary for the performance of a contract or for pre-contractual activities.
In addition we may collect and use the following information about you:
• name
• postal address
• email address
• telephone number
• IP address
• age and/or date of birth
• your gender
• your anniversary
• your relationship status
• your credit/debit card details
• information provided when you correspond with us (such as where you report a problem with your order or account)
• any updates to information provided to us
• information you provide when you enter a competition, promotion or survey
• information about your account and associated services we provide to you
• information needed to provide our services to you (including information on account opening forms, order details, order history and payment details)
• customer services information
• customer relationship management and marketing information
We will collect, use and store the personal information listed above to provide you with our services, to facilitate deliveries of our products to you, for administrative purposes, for marketing and other purposes as described further below or to deal with any enquiries or issues you have about our website, products, services and your orders. The processing of data for these purposes is either necessary for the performance of existing contracts or pre-contractual activities, or based on our legitimate interest, e.g. in responding to your enquiry and optimizing our customer service or verifying your identity in order to protect your data and prevent misuse, or based on your express consent. You can revoke your consent at any time with effect for the future by contacting us.
5.2. Order Processing
When you place an order with us, we process your contact details (name, email address) as well as other data that we need to process your order and fulfil the contract. This includes a delivery address, billing address, if applicable, and payment information.
If you use a third-party provider for payment processing such as:
• Amazon Pay: https://pay.amazon.com
• PayPal: https://www.paypal.com
• Visa: https://www.visa.com
• Mastercard: https://www.mastercard.com
• Payone: https://www.payone.com
you will be redirected to the corresponding pages of the chosen provider. Each third-party provider is responsible for its own data protection. For more information on the processing of your data during the payment process, please contact your chosen payment service provider directly.
For the purpose of delivering your goods, your contact details are provided to shipping service providers.
This data processing is based on contract fulfilment. In addition, we may process your data for the assertion, enforcement or defence of legal claims based on our legitimate interest, in particular if there are problems with payment processing. Our legitimate interest lies in the effective enforcement or defense of legal claims.
5.3. Track Your Order
To check the status of your order, you can track your order. To do this, we process your order number, your email address and your order details so that we can show you the shipping status. The data processing is carried out based on our legitimate interest in informing our customers about the status of their order. The recipient of your data is the shipping service provider from whom we request the order status.
5.4. Availability Notification
To receive a notification when a product becomes available again, you can provide your email address for this purpose. We will process your email address solely for this purpose and delete it after the notification has been sent. The processing is necessary for pre-contractual activities at your request.
5.5. Customer Reviews
As part of the customer review process, you have the opportunity to voluntarily share information about your experiences with our products. When you submit a product review on our website, we process the data you provide in order to display your review and, where applicable, associate it with our product offerings. If the product you reviewed is also available in other webshops, your review may also appear on multiple websites of the Lovehoney Group.
The data we process includes information about the reviewed product (in particular its design and quality), your experience using the product, your chosen reviewer username, and your email address (which is not published and is used solely for authentication purposes and, if necessary, to contact you with questions about your review). We use service providers (such as “Yotpo”) to manage and display customer reviews. This helps ensure, in particular, that reviews are submitted by actual buyers.
The processing of your data is based on our legitimate interest, that lies in the transparent presentation of user experiences and the continuous improvement of our product offerings. Data processing agreements have been concluded with the service providers.
Your review can be published for as long as the reviewed product is listed on our websites.
6. When you contact us
You have the option of contacting us by telephone, post, chatbot or via our contact form. To use our contact form, we first need the data marked in it as mandatory. In the case of a contact enquiry, we may need to verify your data by entering your email address or other data into our customer database. If you have not objected to receiving a survey, we may also send you a satisfaction survey about our customer service by email afterwards. We use this data based on our legitimate interest to answer your enquiry or to optimise our customer service. In the case of warranty processing, the legal basis may also be contract fulfilment. When you contact us in connection with a potential product defect or damage incident, we may process your data by communicating with you, assessing and handling your request and, where necessary, sharing relevant information with our insurance provider, legal advisors, authorities, or other parties involved in the resolution of the matter. In this case, we process your data to comply with our legal obligations relating to product safety and product liability and based on our legitimate interests in managing and resolving related claims.
Your data will only be processed to answer your enquiry. We delete the data as soon as the enquiry has been resolved, and the deletion does not conflict with any statutory retention periods or legitimate interests.
7. Chatbots
Our website offers AI-based chat assistants (“Chatbots”) that provide automated support and advice. These Chatbots are not operated by human advisors but use artificial intelligence (AI) and algorithms to assist you with enquiries and provide personalized recommendations. During a chat session, you may voluntarily provide personal information such as your name, email address, order number, or other details necessary to handle your enquiry. Chat transcripts may also include interaction data, time stamps, and technical metadata. We process your personal information to provide automated customer support and to respond to your enquiries. Where your request relates to an existing contract or is made in preparation for entering into one, the processing is based on performance of a contract or pre-contractual measures. We also process data to ensure efficient and user-friendly communication based on our legitimate interest to continuously improve our chatbot and customer service experience. If the chatbot offers personalized shopping recommendations, this may involve limited profiling based on your previous interactions or user behaviour. Such processing is carried out based on our legitimate interest. There is no fully automated decision-making with legal or similarly significant effects. We use Salesforce as a technical service provider to record and track conversations. Salesforce acts as a processor bound by instructions under a data processing agreement. We delete or anonymize your data once the enquiry has been completed and the data is no longer required for the stated purposes, unless legal retention obligations apply. Technically necessary cookies are used for the use and operation of the chat function. We use these cookies on the basis of our legitimate interest in recognizing your internet browser in order to be able to distinguish individual users of the chat function on our websites. We are supported in the provision and analysis of the chats by processors bound by instructions.
8. Newsletter & Marketing Communications
You can subscribe to a personalized newsletter and marketing communications with exclusive discounts and information about our products, self-love and pleasure on our website or through other channels, such as social media. To subscribe, we require your e-mail address, and optionally your telephone number or your postal address, depending on the preferred communication channel. Our newsletter and marketing communication may be sent by any of the companies of the Lovehoney Group. Therefore, your data may be shared within the company group.
You can revoke your given consent to receive the newsletter at any time with effect for the future. To unsubscribe please use the link provided at the bottom of every newsletter or follow the instructions relevant to the channel.
As part of the newsletter registration process, we store further data necessary to verify your subscription to our newsletter. This may include the storage of the full IP address at the time of the request or confirmation of the newsletter, as well as a copy of the confirmation email sent by us. The corresponding data processing is carried out in the legitimate interest of being able to fulfill the requirement to prove consent was obtained for the sending of the newsletter.
8.1 Direct Advertising
If we receive your postal or e-mail address in connection with the sale of a product or service or by other means, we may use it for direct advertising, e.g. for similar goods or services, provided you have not objected to the processing. We may also use your name to address you personally. Additionally, we may use your email address to send out our customer satisfaction surveys after you have purchased a product from us, asking you to rate us, for example on TrustPilot.
If you do not complete your purchase, we may send you a reminder e-mail to help you finalize your order. This message will be based on your previous activity and the e-mail address you provided. You can unsubscribe from receiving such emails at any time by using the unsubscribe link included in the e-mail.
This use is based on our legitimate interest of promoting the sale of our goods or services. If you object to such processing you may unsubscribe by using the link provided at the bottom of every newsletter or follow the instructions relevant to the channel.
If we have received your e-mail address from a third party with your consent, we may share certain information about your interactions with us, such as confirmation of a purchase, with that third party based on your consent. You can withdraw your consent at any time with future effect by contacting us or adjusting your preferences in the cookie settings.
8.2 Newsletter Tracking
We include individual tracking pixels in all our newsletters, which allow us to recognise when your newsletter has been accessed or opened and individualise the links in the newsletter in order to evaluate when you clicked on which link. The legal basis is our legitimate interest in analysing the newsletter click and opening behaviour of our subscribers in order to optimise our newsletter.
9. Campaigns
We may run contests, giveaways or other campaigns from time to time. Participation is voluntary. If you choose to participate, we will process your email address and, in some cases, your name, address or other personal data in order to verify your eligibility to participate, notify you of the result and, if you win, send you the price. If you have given your consent, you will also receive our newsletter, which you can unsubscribe from at any time. We will delete your data as soon as we no longer need it to determine and notify the winner unless legal retention obligations do not conflict with deletion.
The legal basis for this data processing is your consent and our legitimate interest in conducting the campaign, determining the winner, notifying them, and sending our newsletter. Please note, that, should you revoke your consent during an ongoing campaign, your participation can then no longer be considered, and you will no longer have the chance to win a price.
10. Suppliers and Business Partners
The business relationships with our contractual partners requires the processing of data. Insofar as this data allows conclusions to be drawn about a natural person (e.g. contact person of a company, supplier, vendor), this is considered personal data. We only process personal data that we receive from you as part of our business relationship. This includes name, address, company affiliation and your contact details (telephone number, e-mail address).
The processing of your personal data may arise due to the implementation of pre-contractual measures that precede a contractually regulated business relationship or in the fulfilment of obligations arising from a contract concluded with you or the company you work for. This may include, for example, the processing of purchase orders, deliveries or payments or the preparation and response to requests for quotations from individuals to determine the establishment or terms of a contractual relationship.
We are also subject to legal obligations that may make it necessary to process your personal data. These legal obligations may arise, for example, from tax law, commercial and foreign trade law or sanction law regulations.
It may also be necessary to process your personal data to pursue our legitimate interests. These legitimate interests are, in particular, the conclusion or performance of contracts and other business relationships with our business partners, suppliers or interested parties for whom you may act as a representative or employee. Further legitimate interests are internal administrative purposes (e.g. accounting) or to ensure IT security and IT operations as well as to carry out compliance investigations, to ensure building and plant security or to assert, exercise or defend legal claims.
As part of our business relationship, you must provide the personal data that is necessary for the establishment, execution and termination of a business relationship and for the fulfilment of the associated obligations, which we are legally obliged to collect or which we are entitled to collect on the basis of legitimate interests. Without this data, we will generally not be able to contact you and/or enter into a business relationship with you. If you provide us with data voluntarily, we will indicate this accordingly when collecting the data.
11. Job Applications
If you send us a job application, you determine which data you wish to provide us with. However, to be able to consider your application, usually the following information is required: name, address, email address, cover letter or desired position, CV, references and qualifications.
We process this information exclusively for the purpose of applicant selection (pre-contractual steps), as this is necessary for the decision regarding the establishment of an employment relationship. Data processing for other purposes does not take place.
In addition, you can decide for yourself whether you would like to provide us with further information, e.g. your hobbies, date of birth, telephone number or a photo. The provision of this data is voluntary and is not mandatory for the application. If you include voluntary data in your application, we will process it on the basis of your consent. You can revoke your consent at any time with effect for the future. Please contact the Lovehoney Group company to which you have applied. We receive your application data mainly from you. In some cases, we may enter your name in a search engine and process information from the Internet. Your data will be treated confidentially. If necessary, we use service providers who are strictly bound by our instructions, e.g. in the areas of IT and with whom separate contracts for order processing have been concluded. Your data will not be passed on beyond this. If an employment contract is concluded after the application process, we will store the data from your application that is required for the fulfilment of your employment relationship (i.e. performance of the employment contract). If your application is unsuccessful, your documents will be deleted as soon as they are no longer required for us to defend ourselves against potential legal claims brought by you. Therefore, the processing until the deletion takes place in our legitimate interest to be able to defend ourselves against any complaints concerning the application. The specific retention period depends on the location of the company (and the legal requirements applicable there) to which you have submitted your application.
12. Processors and Service Providers
We occasionally pass on your data to service providers, who support us in the operation of our websites and the associated processes, as part of commissioned data processing in accordance with applicable data protection requirements. Our service providers are strictly bound by our instructions and contractually obliged accordingly.
Such service providers include without limitation:
• website services providers who help us host and administer our website;
• email services providers;
• delivery services providers for the purposes of delivering your orders and sending you tracking notifications about your delivery and returns services providers;
• service providers who we work with closely to help provide our independent reviews database;
• our other service providers and sub-contractors, including suppliers of technical and support services, insurers, logistic providers, and cloud service providers; and
• analytics and search engine providers that assist us in the improvement and optimization of our website.
13. Sharing Personal Data within the Group of Companies and other International Data Transfers
The Lovehoney Group is an internationally operating group of companies. Due to partially existing matrix structure, your personal data may be shared with other companies within the Lovehoney Group for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance), based on other legitimate interests or in the context of commissioned data processing. Your personal data may be transferred internationally. Our companies are located in countries within the European Union (EU)/the European Economic Area (EEA), in the United Kingdom (UK), Switzerland as well as in the United States of America (USA), Canada, Australia, and China.
In some cases, your data may also be processed by service providers or third parties located outside of your country.
Some countries have implemented transfer restrictions for personal information, in connection with which the Lovehoney Group takes various measures, including:
• Where required, implementing Standard Contractual Clauses approved by the EU Commission by the UK Information Commissioner Officer (ICO), the Swiss Federal Data Protection and Information Commissioner (FDPIC), or similar contractual clauses in other jurisdictions and effective safeguards;
• Transferring personal information to countries or specified sectors (such as companies certified under the EU-U.S. Data Privacy Framework, Swiss-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework) that regulators deemed to have adequate protections for the treatment of personal information;
• Where required by law, obtaining your consent to share your personal information outside of your country; and
• Any other exception granted by applicable data protection laws.
14. Data Security
We have comprehensive security measures, such as technical and organisational measures in place to protect your data from unauthorised access. We use an encryption process on our websites. Your data is transmitted from your computer to our server and vice versa via the Internet using TLS encryption. You can usually recognise this by the fact that the lock symbol in the status bar of your browser is closed and the address line begins with https://.
15. Cookies
We use a consent management platform (consent- or cookie-banner) on our websites. The processing in connection with the use of the consent management platform and the logging of the settings you have made is carried out in accordance with our legitimate interest to display our content according to your preferences and to be able to prove the consent(s) you have given. The settings you have made, the consent you have given and parts of your usage data are stored in a cookie. This means that it is retained for subsequent page requests and your consent can still be tracked. You can find more information on this under the heading "Required cookies". You can opt out of the sale or sharing of personal data via the Cookie Settings in our cookie banner.
15.1. Required Cookies
We use cookies on our websites that are necessary for the use of our websites. Cookies are small text files that can be stored and read on your end device. A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. We do not use these necessary cookies for analysis, tracking or advertising purposes. Some of these cookies only contain certain setting information and are not personally identifiable. They may also be necessary to enable user guidance, security and implementation of the site. We use these cookies based on our legitimate interest.
You can set your browser to inform you about the placement of cookies. You can also delete them at any time via the corresponding browser setting and prevent the setting of new cookies. Please note that if cookies are entirely prevented our web pages may then not be displayed in full and some functions may no longer be technically available. You can find more information on the individual cookies and the providers in our cookie banner.
15.2. Visitor Measurement (Cookies for Analysis Purposes)
We use web analysis tools to customise the design of our websites, improve and maintain our websites. These create user profiles on the basis of pseudonyms. For this purpose, permanent cookies are stored on your end device and read by us. It is also possible for us to retrieve recognition features for your browser or device (e.g. a so-called browser fingerprint or your unabridged IP address). In this way, we are able to recognise returning visitors and count them as such.
We also use the following functions as part of visitor measurement:
• We enrich the pseudonymised data with additional data provided to us by third-party providers. In this way, we are able to record demographic characteristics of our visitors, e.g. statements on age, gender and place of residence.
• We use a recognition method that allows us to record and subsequently analyze URL clickstreams, products viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information such as scrolling, clicks, mouse-overs or keyboard inputs of our visitors, and methods used to browse away from the page.
Data processing is based on your consent, given via our cookie banner, in accordance with applicable data protection legislation.
You can find more information on the individual cookies and the providers in our cookie banner.
15.3. Tracking Technologies from Third-Party Providers for Advertising Purposes
We use cross-device tracking technologies so that you can be shown targeted advertising on other websites based on your visit to our websites and we can recognise how effective our advertising measures were.
Data processing is based on your consent, given via our cookie banner, in accordance with applicable data protection legislation. Your consent is voluntary and can be revoked at any time by adjusting your preferences in the cookie settings.
How does tracking work?
When you visit our websites, it is possible that the third-party service providers mentioned in our cookie banner may retrieve unique identifiers from your browser or your end device (e.g. a so-called browser fingerprint), analyse your IP address, store or read recognition features on your end device (e.g. cookies) or gain access to individual tracking pixels.
The individual features can be used by third-party service providers to recognise your device on other websites. We can commission the relevant third-party service providers to place advertisements based on the pages you visit on our website.
What does cross-device tracking mean?
If you log in to the third-party service provider with your own user data, the respective unique identifiers of different browsers and end devices can be linked to each other. For example, if the third-party provider has created a separate feature for the laptop, desktop PC or smartphone or tablet you are using, these individual features can be assigned to each other as soon as you use a service of the third-party provider with your login data. In this way, the third-party service provider can also target our advertising campaigns across different end devices.
You can find more information about the individual cookies and the providers, as well as the option to adjust your settings, in our cookie banner.
15.4. Integration of other Technical Third-Party Content and Functions
We use the technical functions and content of third-party service providers to display our websites.
When you access our pages, the content of the third-party service provider that provides these functions and content is loaded. As a result, the third-party service provider receives the information that you have accessed our site and the usage data technically required to do so. We have no influence on further data processing by these third-party service providers. The data processing takes place on the basis of your consent, provided that you have previously given your consent via our cookie banner.
You can find more information about the individual cookies and the providers, as well as the option to adjust your settings, in our cookie banner.
15.5. Embedded Videos and Players
We embed videos and players on our websites that are not stored on our servers. When you access our pages with embedded videos and players, the content of the third-party service provider that makes the videos available is loaded. As a result, the third-party service provider receives the information that you have accessed our site and the usage data technically required to do so. We have no influence on further data processing by these third-party service provider. The data processing takes place on the basis of your consent, provided that you have previously given your consent via our cookie banner.
You can find more information about the individual cookies and the providers, as well as the option to adjust your settings, in our cookie banner.
15.6. Map Services
We embed map services on our websites that are not hosted on our servers. For data protection reasons, no content from the third-party provider is loaded and no information is transmitted to the third party when you access our websites.
Only once you have given your consent via our banner content from the third-party provider will be loaded. This means the third party will receive the information that you accessed our website, along with the technically required usage data in this context. We have no influence over the further processing of data by the third-party provider. Your consent includes the loading of content from the third-party provider.
The embedding is carried out based on your consent, provided you have given this consent via our banner.
You can find more information about the individual cookies and the providers, as well as the option to adjust your settings, in our cookie banner.
15.7. Affiliate Marketing
We sometimes advertise and link to services offered by third parties on our website. As the operator of the website, we receive a commission if you follow the affiliate link and subsequently take advantage of the third party's offers. In order to operate affiliate programs and ensure the economic viability of our online offer, we use tracking cookies to store information on the end devices of our website visitors and collect this information from these devices. For this purpose, the affiliate links and our offers are supplemented by certain values that form part of the link or are stored in a cookie. The values include, in particular, the source website (referrer), time of access, our online identifier as the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of you as a website visitor, as well as specific values such as advertising material ID, partner ID and categorisations.
These pseudonymous online identifiers are then used to track whether website visitors became aware of the offers of our partner companies due to our online presence, so that we receive the corresponding remuneration.
Data processing is based on your consent in accordance with applicable data protection legislation, provided that you have given your consent via our cookie banner. You can revoke your consent at any time. To do so, please adjust the settings in our cookie banner.
In addition, our partners set our affiliate links on the websites they operate. In this case, the data is processed in the same way as described above, except that you access our websites from the website of a third party via the affiliate link.
15.8. Captcha
To protect our web forms from automated enquiries, we use a so-called captcha from a third-party service provider. As part of the captcha function, you may be asked to complete tasks or tick checkboxes. The user entries made in this context and, if applicable, the mouse movements are used to assess whether the entries originate from a human or an automated programme.
As the function is provided by a third-party service provider, the display of the captcha leads to the third-party service provider's content being reloaded. As a result, the third-party service provider receives the information that you have accessed our site and the usage data technically required in this context. We have no influence on further data processing by the third-party service provider.
The embedding takes place in accordance with our legitimate interest of protection against spam and misuse. If you wish to object to the associated data processing, please do not use our web forms, instead contact us in another way.
16. Social Media
On our website you will find links to the social media services Facebook, Instagram, TikTok, X and YouTube. If you follow these links, you will reach our company presence or be given the opportunity to share a page, provided you have an account with the respective social media service. When you click on the link to a social media service, a connection is established to the servers of the social media service. This informs the servers of the social media service that you have visited our website. In addition, further data is transmitted to the provider of the social media service. For example:
• Address of the website on which the activated link is located
• Date and time of website access or link activation
• Information about the browser and operating system used
• IP address
If you are already logged in to the relevant social media service when you activate the link, the provider of the social media service may be able to determine your username and possibly even your real name from the transmitted data and assign this information to your personal user account with the social media service. You can exclude this possibility of assignment to your personal user account if you log out of your user account beforehand.
For more information on the use of your data by the social media services integrated on our website, please refer to the privacy policy of the respective social media service.
17. Product Testing Campaigns
In connection with your participation in a product testing campaign, including surveys, we may collect and use the following information of you: name, postal address, email address, telephone number, bank account details, age and/or date of birth, your profession, your opinion to our products or other topics and other information as specified in the rules of the campaign, as the case may be.
The main purpose of the data processing is to verify your eligibility to participate in the campaign and, in case you receive a remuneration or a gift, to send or transfer it to you. The respective rules could provide for further purposes.
We process your data for those purposes based on your meaningful and express consent. You can revoke your consent at any time with effect for the future under the provided contact information. Please note, that, should you revoke your consent during an ongoing campaign, your participation can then no longer be considered and you will no longer have the chance to win a price.
Based on your consent we will also use your data to send you information about products, services, events and other information worth knowing about the sponsor(s) and/or us. If you do not wish to receive any further marketing promotions, you can revoke your consent at any time with effect for the future. To unsubscribe please use the link provided at the bottom of every email or contact us directly.**
IV. Your Rights
You may have certain rights in relation to your personal data, including sensitive personal data, under local data protection legislation. Depending on the applicable laws and under certain conditions, you may have the right to:
• Ask us to provide you with information on how we use and process your personal information;
• Ask us to provide you with a copy of your personal information that we hold;
• Ask us to update any inaccuracies in the personal information we hold;
• Ask us to delete personal information we no longer have grounds to process;
• Ask us to electronically transmit the personal information you have provided to us and we still hold about you to a third party;
• Restrict how we process your personal information while we consider an inquiry you have raised;
• Where processing is based on consent, withdraw the consent—some countries may require a written withdrawal request. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can withdraw your consent as follows: send an email request to privacy@lovehoneygroup.com or use the “unsubscribe” button if you have received newsletters or regular communication and wish to withdraw your consent to such communication. Further, you can object to the use of your personal data for the purposes of marketing without incurring any costs other than the transmission costs;
• Object to any processing of personal information that we process, among the other purposes, on the “legitimate interests” or “public interests” grounds, including profiling, unless our reasons for the underlying processing outweighs your interests, rights, and freedoms and according to the applicable legislation;
• Object to any non-essential processing of your personal information;
• Object to direct marketing (including any profiling for such purposes); register with your local government if applicable or request to restrict the use of your personal information on the grounds provided by applicable legislation; and
• Make a complaint to your local government or supervisory authority if you feel your rights have been violated. If you are located in the EU/EEA, United Kingdom or Switzerland, you have the right to contact the data protection regulator of the country in which you are based, you have your place of work or where the Lovehoney Group is based. A list of the EU data protection regulators and their contact details can be found online.
These rights are subject to certain exemptions, including without limitation to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege).
If you have further questions or a complaint about how we use your personal information, we would always prefer you to contact us first. Please note that – depending on the applicable law – it may even be necessary for you to contact us first before you can lodge a complaint with the competent supervisory authority.
To exercise your rights described above, please submit a verifiable request to us either:
by emailing us at privacy@lovehoneygroup.com; or by post. The addresses of the respective companies can be found above.
You can also submit requests for access to or deletion of your personal data using the form in our Privacy Center.
Only you, or someone you authorize, can make a request about your personal information. If you allow someone else (such as an agent) to act on your behalf, we may ask them to provide proof of your signed permission. We may also ask you to verify your identity or confirm that you have given them permission.
If we cannot confirm your identity or the authority of the person making the request, we may not be able to process it or provide your personal information. To verify your identity, we may ask for up to three pieces of personal information and, if needed, take additional steps to prevent fraudulent requests.
To appeal our decision on your data subject requests, you may contact us as well. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal.
We will respond to your requests and appeals in accordance with applicable law.
V. Supplementary Country-Specific Information
1. US State Residents‘ Additional Information
This US Residents’ additional information section forms part of the Privacy Policy and applies to individuals who reside in the United States. This section sets out the additional information that we are required to provide to you, in particular under the California Consumer Privacy Act (CCPA) and under the California Privacy Rights Act (CPRA). This section should be read alongside the Privacy Policy and terms used in this section have the same meaning given in the Privacy Policy, unless otherwise stated.
1.1. Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising
We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies via our website. Under certain US state privacy laws, this may constitute a “sale” or “share” of personal information or “targeted advertising”. We may have “sold” or “shared” personal information, which consists of identifiers, commercial information, and internet or other electronic network activity information to data analytics providers, advertisers, and social networks for the business and commercial purposes of online advertising and to provide third-party social network features and functionality. Under certain US state privacy laws, you have the right to opt-out of this disclosure of your information, which may be considered a “sale”, “sharing”, or “targeted advertising” under such laws. You may opt-out of this “sale”, “sharing”, or “targeted advertising” on our website by setting a browser-level opt-out, the Global Privacy Control or, in some states, through rejecting cookies in our cookie banner. You may also request to opt-out of this “sale”, “sharing”, or “targeted advertising” by e-mailing us at privacy@lovehoneygroup.com.
1.2. California Residents
(a) This Section contains certain required information and informs California residents of certain rights arising under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA) and the California Civil Code Section 1798.83. (b) Direct Marketing. The California Civil Code Section 1798.83 permits users of the services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as set out below. (c) Categories of Personal Information Collected. We may have collected the following categories of personal information from you within the last twelve (12) months:
· Identifiers, such as name, address, online identifier, internet protocol address, e-mail address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
· Additional personal information described in California Civil Code Section 17980.80, such as telephone number, bank account number, credit card number, debit card number, or any other financial information, employment, and employment history;
· Characteristics of protected classifications under California or federal law;
· Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming tendencies;
· Internet or other electronic network activity information;
· Audio and visual information, including pictures and videos;
· Inferences drawn from other personal information;
· Biometric data; and
· Sensitive personal information.
(d) Categories of Sources from which Personal Information Is Collected. We may have collected personal information from you from the following categories of sources: (1) directly from you via the services or when you visit one of our websites; (2) your devices; (3) our affiliates and subsidiaries; (4) our third-party providers; (5) social networks; and (6) other available sources, such as public records. (e) Business or Commercial Purposes for Collecting Personal Information. The business or commercial purposes for collecting your personal information are set forth in the respective sections of this Privacy Policy describing the specific processing. (f) Categories of Personal Information “Sold” or “Shared” to Third Parties and the Business and Commercial Purposes. The categories of personal information that we have “sold” or “shared” to third parties in the last twelve (12) months and the business and commercial purposes for “selling” or “sharing” such personal information are set forth in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Policy. We do not knowingly “sell” or “share” the personal information of individuals under sixteen (16) years of age. (g) Categories of Personal Information Disclosed to Third Parties. All categories of personal information described above may be shared with third parties as set forth in the respective sections of this Privacy Policy describing the specific processing.
(h) Personal Information Retention. We retain the personal information that we collect to achieve the purposes for which the personal information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law. (i) Use and Disclosure of Sensitive Personal Information. We may collect “sensitive” personal information for limited purposes, such as for selling our products and offering our website. We do not use or disclose your sensitive personal information outside of the following purposes:
· Performing our service or providing goods,
· detecting security incidents,
· resisting malicious, deceptive, fraudulent, or illegal actions,
· ensuring physical safety,
· for short-term transient use, including certain non-personalized advertising,
· maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and
· verifying and maintaining the quality or safety of a service or product or improving, upgrading, or enhancing a service or product. As such, the right to limit our use and disclosure of such sensitive information does not apply. (j) Your California Privacy Rights. The following rights apply to California residents:
· The right to know what personal information that we have collected about you, including the categories of information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you;
· The right to delete personal information that we have collected from you and the right to correct inaccurate personal information that we maintain about you (each subject to certain exceptions);
· The right to opt-out of the “sale” or “sharing” of your personal information (as described in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Policy); and
· The right to exercise your rights under the CCPA free of discrimination by us including, but not limited to: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
(k) Exercising Your California Privacy Rights. For information on how to exercise your rights under the CCPA, please review the “Exercising Your Rights” Section of this Policy.
1.3. Other US States
This portion of the Policy describes the rights that may be available to you if you reside in a US state, where there is already a comprehensive data protection law, such as Colorado, Connecticut, Texas or Virginia. For more information about our privacy practices related to consumer health data subject to the Washington My Health My Data Act (MHMDA) please visit our Washington Consumer Health Data Privacy Policy, available here<u>.</u>
If you reside in a state with a comprehensive data protection law, you may have the following rights regarding your personal data:
• Right to Know and Access: The rights to confirm whether we are processing your personal data and to access such personal data.
• Right to Correct: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and our purposes of the processing of such personal data.
• Right to Delete: The right to delete personal data provide by or obtained about you.
• Right to Obtain a Copy: The right to obtain a copy of your personal data that you previously provided to us in a portable and to the technically feasible, readily useable format that allows you to transmit to the data to another controller without hindrance, where the processing is carried out by automated means.
• Right to Opt-Out: The right to opt out of the processing of your personal data for purposes of: (1) targeted advertising, (2) the sale of personal data, or (3) profiling in furtherance of decisions that product legal or similarly significant effects concerning you. Note, however, that we do not engage in (3), so that right does not apply.
1.4. Exercising Your Rights
You can exercise these rights by contacting us at privacy@lovehoneygroup.com or as set out below. Please see the “Notice of Right to Opt-Out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Policy above for additional information on how to opt-out of “sale”, “sharing”, or “targeted advertising.” You may designate an authorized agent to make such requests on your behalf by having your authorized agent make a privacy request as set forth above. Please note that we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your information. We may need to collect information such as your name, email or transaction history in order to verify your identity. If you designate an authorized agent to make a request on your behalf, your authorized agent need to provide similar information for verification. If we refuse to take action upon your request, you may appeal such refusal by contacting us after your receipt of the refusal at privacy@lovehoneygroup.com.
2. Canada Residents’ Additional Information
This Canada and Quebec Residents’ additional information section forms part of the Privacy Policy and applies to individuals who reside in Canada. Certain sections pertain to specific privacy legislation applicable in Alberta, British Columbia and Quebec. This section provides additional information required under applicable Canadian privacy legislation. It should be read alongside the Privacy Policy, and terms used here have the same meaning as in the Privacy Policy, unless otherwise stated.
2.1. What Sensitive Personal Information Do We Collect?
We may collect sensitive personal information, which includes:
Your financial information such as bank account, credit card, debit card, or other payment instrument details.
2.2. Disclosure of Sensitive Personal Information
We may disclose your sensitive personal information to third parties as described in the Privacy Policy. If we disclose your sensitive personal information to a third party, we will obtain your consent before making such disclosure unless the disclosure is:
• Necessary for compliance with a legal obligation;
• Agreed upon pursuant to a contract between you and us;
• Mandated by an order, decree, or judgment under federal or provincial law; or
• to a government agency for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offenses.
We or any person on our behalf shall not publish sensitive personal information we collect.
2.3. Data Storage, Cross-Border Transfers, and Protection
We may store your personal information on servers and systems under our control or on servers and systems that we license. To carry out the purposes described in the Global Privacy Policy, your personal information may be transferred and stored outside of Canada, including in the United States. This means your data may be subject to the laws of other jurisdictions, which may not provide the same level of protection as in your province or in Canada. If we transfer your data, it will be subject to appropriate contractual safeguards, and the jurisdiction will be evaluated as required by applicable law.
2.4. Additional Privacy Rights
You may exercise your rights by submitting a verifiable request to us in the manner prescribed below. We will respond to these requests as follows:
• For residents of Alberta: Upon receiving a request to access, delete, or to correct an error or omission, we will respond within forty-five (45) days of its receipt. If we require more time (up to an additional 30 days for a total of 75 days), we will inform the requestor of the reason and extension period in writing.
• For residents of Quebec: Upon receiving a request to access, delete, or to correct an error or omission, we will respond within thirty (30) days. If the request cannot be processed or additional information is needed you will be informed in writing.
• For residents in provinces other than Quebec and Alberta: Upon receiving a request to access, delete, or to correct an error or omission, we will respond within thirty (30) days of its receipt. If we require more time (up to an additional 30 days for a total of 60 days), we will inform the requestor of the reason and extension period in writing.
(i) Quebec Residents
The Quebec Privacy Act provides residents with specific rights regarding their personal information. This sub-section describes those rights and explains how to exercise them.
(a) Right to be de-indexed or re-indexed: You have the right to request that we stop disseminating your personal information, deindex or reindex a hyperlink associated with your name that provides access to your information, particularly if such dissemination causes harm or violates the law or a court order. Once we receive and confirm your privacy request, we will delete (and instruct our service providers to delete) your personal information from our records, unless an exception applies under applicable privacy laws, including the Quebec Privacy Act. Please note that we may not be able to delete your personal information entirely in the following cases:
• If deleting the information would violate any law, legal requirement, or make the information incorrect.
• If the information is necessary for servicing or collecting on an active employee following acceptance of a position with our Company.
• Some data may remain in backups, which are retained by our disaster recovery policies.
(b) Geolocation Data and profiling: When collecting geolocation data or any data associated with a technology that permits us to create a profile on you, which includes time and physical location related to your use of our website, application, device, or physical access to our office location, we will only use such geolocation or profiling features with your consent.
(c) Automated Decision-Making: We do not profile or use any form of automated processing on your personal information in furtherance of decisions that produce legal or similarly significant effects.
(ii) All Canadian Residents
In Canada, we will not collect personal information or sensitive personal information from a child under the age of 14 years without a parent's or guardian's prior consent.
For any further information or to exercise your rights, please contact us using the details provided below.
2.5. Complaints and Regulatory Authority
In Canada you have the right to lodge a complaint with the responsible supervisory authority; the process depends on the applicable privacy law:
Private Sector (PIPEDA - Personal Information Protection and Electronic Documents Act): Under PIPEDA, individuals can file a complaint with the Office of the Privacy Commissioner of Canada (OPC) if they believe an organization has mishandled their personal information. The OPC is available under https://www.priv.gc.ca/en/
Provincial Privacy Laws: Some provinces (such as Québec, British Columbia and Alberta) have their own privacy laws and supervisory authorities:
• Québec: Commission d’accès à l’information du Québec (CAI), https://www.cai.gouv.qc.ca/
• British Columbia: Office of the Information and Privacy Commissioner (OIPC BC), https://www.oipc.bc.ca/
• Alberta: Office of the Information and Privacy Commissioner (OIPC AB), https://oipc.ab.ca
3. Australian Resident’s Additional Information
This Australian Residents’ additional information section forms part of the Privacy Policy and applies to individuals who reside in Australia. This section provides additional information and addresses specific requirements under the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles (APPs). It should be read alongside the Privacy Policy, and terms used here have the same meaning as in the Privacy Policy, unless otherwise stated.
3.1. Additional Data Subject Rights Under Australian Law
As an Australian data subject, you have the following rights under the Privacy Act:
• Right to Anonymity and Pseudonymity (APP 2): Individuals have the right to interact with organizations without identifying themselves, unless impractical.
• Right to Not Have Data Transferred Overseas Without Protections (APP 8): If we transfer personal data outside of Australia, we must take reasonable steps to ensure that foreign recipients comply with the APPs, unless an exception applies.
• No Right to Data Portability: Australian law does not grant a direct right to data portability.
• Right to Direct Marketing Opt-Out (APP 7): Individuals must be given an option to opt out of direct marketing communications.
For any further information or to exercise your rights, please contact us using the details provided below.
3.2. Cross-Border Data Transfers
If we disclose your personal information outside of Australia, we will ensure that the recipient is subject to laws that offer similar protections to the APPs or we will obtain informed consent from you before transferring your data. Key destinations where data may be transferred include the European Union (EU)/European Economic Area (EEA), the United States, and other regions where companies of the Lovehoney Group and our service providers are located.
3.3. Complaints and Regulatory Authority
If you believe we have breached Australian data protection requirements, please contact us as prescribed below. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) under https://www.oaic.gov.au/
4. New Zealand Residents’ Additional Information
This New Zealand Residents’ additional information section forms part of the Privacy Policy and applies to individuals who reside in New Zealand. This section provides additional provisions required under New Zealand’s Privacy Act 2020 and the Information Privacy Principles (IPPs). It should be read alongside the Privacy Policy, and terms used here have the same meaning as in the Privacy Policy, unless otherwise stated.
4.1. Additional Data Subject Rights
In addition to the general rights provided under the Privacy Policy, as a New Zealand data subject you have the following specific rights:
• Right to Access and Correction (IPP 6 & 7): You have the right to request access to the personal information we hold about you and to request corrections if the information is inaccurate, incomplete, or outdated.
• No Right to Erasure ('Right to be Forgotten'): The Privacy Act 2020 does not provide an automatic right to request the deletion of personal data unless retention is no longer necessary.
• No Direct Right to Data Portability: The Privacy Act 2020 does not mandate a specific right to data portability. However, we may provide data in a structured format upon request where reasonably possible.
For any further information or to exercise your rights, please contact us using the details provided below.
4.2. Cross-Border Data Transfers
New Zealand’s Privacy Act 2020 requires that before transferring personal data overseas, we take reasonable steps to ensure that the recipient country has comparable privacy protections (IPP 12). In this context we rely on:
• The recipient being in a country with comparable privacy laws, such as those recognized by the New Zealand Government.
• The recipient providing contractual safeguards ensuring compliance with New Zealand privacy standards.
4.3. Supervisory Authority
If you believe that we have mishandled your personal information, you may lodge a complaint with the New Zealand Privacy Commissioner under www.privacy.org.nz
5. Japan Resident’s Additional Information
This Japan Residents’ additional information section forms part of the Privacy Policy and applies to individuals who reside in Japan. This section provides additional provisions required under Japan’s Act on the Protection of Personal Information (APPI). It should be read alongside the Privacy Policy, and terms used here have the same meaning as in the Privacy Policy, unless otherwise stated.
5.1. Specific Additional Data Subject Rights
In addition to the general rights provided under the Privacy Policy, as a data subject in Japan you have the following specific rights under the APPI:
• Right to Access (Article 33 APPI): You have the right to request access to the personal information we hold about you.
• Right to Correction, Addition, or Deletion (Article 34 APPI): If your personal information is inaccurate, incomplete, or outdated, you may request a correction, addition, or deletion.
• Right to Stop Use or Erasure (Article 35 APPI): You may request us to stop using or delete your personal data if it is no longer necessary for the stated purpose, if it was obtained unlawfully or it was leaked or mishandled.
• No Automatic Right to Data Portability: APPI does not provide a formal right to data portability. However, we may provide your data in a structured format upon request where reasonably possible.
For any further information or to exercise your rights, please contact us using the details provided below.
5.2. Cross-Border Data Transfers
Under APPI, businesses must ensure adequate protections before transferring personal data outside of Japan. The Lovehoney Group relies on one of the following:
• The recipient country has equivalent data protection standards, as determined by Japan’s Personal Information Protection Commission (PPC) (e.g., European Economic Area (EEA)).
• The recipient provides contractual safeguards, ensuring the data is handled in accordance with APPI.
• We obtain explicit consent from the user before transferring data to a jurisdiction with lower data protection standards.
5.3. Supervisory Authority
If you believe that we have mishandled your personal information, you may lodge a complaint with the Personal Information Protection Commission (PPC), available under www.ppc.go.jp.
VI. Contact us
If you have further questions or a complaint about how we use your personal information, we will always prefer you to contact us first at privacy@lovehoneygroup.com.
To get more information or exercise your data subject rights described above, please submit a verifiable request to us either:
• by emailing at privacy@lovehoneygroup.com; or
• by post. The addresses of the respective companies can be found above; or
• by submitting a request via the Privacy Center.
We will respond to your requests and appeal in accordance with applicable law.
Alternatively, you can contact our Data Protection Officer (DPO).
The DPO for Lovehoney Group companies based in Germany is:
datenschutz nord GmbH, Konsul-Smidt-Str. 88, 28217 Bremen, Germany, office@datenschutz-nord.de
The DPO for Lovehoney Group companies based in other countries is:
FIRST PRIVACY GmbH, Konsul-Smidt-Str. 88, 28217 Bremen, Germany, office@first-privacy.com
VI. Updates to the Privacy Policy
As both legal requirements and our internal processes and the associated processing of your data can change constantly, we update this Privacy Policy from time to time. We therefore recommend reviewing the Privacy Policy regularly to stay up to date.
Last updated: October 2025