Privacy Policy

Last Updated: December 1, 2025

1. INTRODUCTION

1.1 About This Privacy Policy

This Privacy Policy explains how Kenneth Cole Europe BV ("we", "us", "our", or "Kenneth Cole") collects, uses, shares, and protects your personal information when you:

• Visit our website at kennethcole.eu (the "Website");
• Purchase products from us;
• Create a Member Account;
• Contact our customer service team;
• Subscribe to our marketing communications;
• Otherwise interact with us.

1.2 Our Commitment to Privacy

We are committed to protecting your privacy and handling your personal information in an open and transparent manner. We comply with:

• The General Data Protection Regulation (GDPR)
• The UK General Data Protection Regulation (UK GDPR);
• The Data Protection Act 2018;
• The Privacy and Electronic Communications Regulations 2003 (PECR);
• All other applicable data protection laws.

1.3 Who We Are (Data Controller)

Kenneth Cole Europe BV is the data controller responsible for your personal information.

1.4 Purpose of This Policy

This Privacy Policy explains:

• What personal information we collect;
• Why we collect it (legal bases);
• How we use it;
• Who we share it with;
• How long we keep it;
• Your rights regarding your personal information;
• How to contact us.

Please read this Privacy Policy carefully. By using our Website or services, you acknowledge that you have read and understood how we process your personal information.

2. WHAT PERSONAL INFORMATION WE COLLECT

We collect different types of personal information depending on how you interact with us.

2.1 Information You Provide Directly

2.1.1 Account Registration

When you create a Member Account, we collect:

• Full name
• Email address
• Password (stored in encrypted form)
• Date of birth (optional)
• Gender (optional)
• Communication preferences

2.1.2 Order and Purchase Information

When you place an order, we collect:

• Full name
• Email address
• Delivery address
• Billing address (if different)
• Phone number
• Order details (products, quantities, prices)
• Delivery preferences

Payment information: We do not collect or store your payment card details. Payment processing is handled by our third-party payment service provider. Please see Section 5.3 for details.

2.1.3 Customer Service and Communications

When you contact us, we collect:

• Name
• Email address
• Phone number
• Order number (if applicable)
• Content of your communications (emails, chat transcripts, phone call recordings)
• Any other information you choose to provide

2.1.4 Marketing Preferences

When you sign up for marketing communications:

• Email address
• Name (optional)
• Communication preferences (topics of interest, frequency)

2.1.5 Product Reviews and User Content

If you post product reviews or other content:

• Username or display name
• Email address
• Review content (text, ratings, photos)
• Product purchased (if verified purchase)

2.1.6 Surveys and Competitions

If you participate in surveys, competitions, or promotions:

• Contact details
• Responses to survey questions
• Any other information required for the specific promotion

2.2 Information Collected Automatically

2.2.1 Website Usage and Technical Information

When you visit our Website, we automatically collect:

Device information:

• Device type (computer, mobile, tablet)
• Operating system
• Browser type and version
• Screen resolution

Connection information:

• IP address
• Internet Service Provider
• Approximate geographic location (country, city level)

Website usage information:

• Pages visited
• Time spent on pages
• Links clicked
• Products viewed
• Search terms entered
• Referring website/source
• Date and time of visit

This information is collected using cookies and similar technologies. For more information, see our Cookie Policy below.

2.2.2 Shopping Behaviour

We collect information about your shopping activity:

• Products browsed and viewed
• Items added to basket
• Abandoned baskets
• Purchase history
• Product preferences and interests

2.2.3 Email Engagement

When we send you marketing emails, we may collect:

• Whether you opened the email
• Which links you clicked
• Whether you unsubscribed

2.3 Information from Third Parties

2.3.1 Payment Processors

We receive limited information from our payment processor:

• Confirmation that payment was successful or declined
• Transaction ID
• Last 4 digits of card number (for your reference only)
• Card type (Visa, Mastercard, etc.)

We do not receive or store your full payment card details.

2.3.2 Delivery Partners

We receive information from our delivery partners:

• Delivery status updates
• Proof of delivery
• Failed delivery attempts

2.3.3 Social Media

If you interact with us on social media (e.g., Facebook, Instagram, Twitter):

• Your public profile information (name, username, profile picture)
• Content of your messages or comments
• Information you choose to share with us

We process this information in accordance with the relevant social media platform's terms and our own privacy practices.

2.3.4 Fraud Prevention Services

We may receive information from fraud prevention and credit reference agencies to verify your identity and prevent fraud:

• Fraud risk scores
• Identity verification results
• Device fingerprinting data

2.4 Sensitive Personal Information

We do not intentionally collect "special category" personal data (such as information about your health, race, religion, political opinions, or sexual orientation) unless you voluntarily provide it (for example, in communications with customer service).

If you do provide such information, we will only use it for the specific purpose for which you provided it and will handle it with extra care in accordance with data protection law.

3. HOW WE USE YOUR PERSONAL INFORMATION (LEGAL BASIS)

Under UK GDPR, we must have a "legal basis" for processing your personal information. This section explains what we do with your information and our legal basis for each purpose.

3.1 To Process Your Orders (Contract Performance)

What we do:

• Process and fulfill your orders
• Arrange delivery
• Send order confirmations and dispatch notifications
• Process returns and refunds
• Handle customer service inquiries related to your order

Legal basis: Processing is necessary to perform our contract with you (the Terms and Conditions you agreed to when placing your order).

Information used: Name, email, delivery address, phone number, order details, payment confirmation.

3.2 To Manage Your Member Account

What we do:

• Create and maintain your Member Account
• Provide access to account features
• Store your order history and preferences
• Enable faster checkout

Legal basis:

• Contract performance: Where you have requested these services by creating an account.
• Legitimate interests: To provide you with enhanced services and improve your shopping experience.

Information used: Account details, order history, saved addresses, preferences.

3.3 To Communicate with You

What we do:

• Respond to your inquiries and requests
• Provide customer service
• Notify you of important changes (e.g., to our Terms or this Privacy Policy)
• Send service messages related to your orders or account

Legal basis:

• Contract performance: Communications necessary to fulfill our obligations to you.
• Legal obligation: Where we are required by law to communicate certain information.
• Legitimate interests: To maintain good customer relationships and provide quality service.

Information used: Contact details, order information, communication history.

3.4 For Marketing Communications

What we do:

• Send you marketing emails about products, offers, and promotions
• Personalize marketing based on your interests and preferences
• Send you newsletters

Legal basis:

• Consent: Where you have explicitly opted in to receive marketing (e.g., by ticking a box during account creation or signup).
• Legitimate interests: Where you have purchased from us and we are marketing similar products, and you have not opted out. This applies only if you are an existing customer.

Information used: Email address, name, purchase history, browsing behavior, preferences.

Your rights: You can opt out of marketing at any time by:

• Clicking "unsubscribe" in any marketing email
• Updating your preferences in your Member Account
• Contacting us at hello@kc-eu.com

Opting out of marketing does not affect service communications related to your orders.

3.5 To Personalize Your Experience

What we do:

• Recommend products you might like
• Show you relevant content
• Remember your preferences
• Customize your shopping experience
• Display personalized offers

Legal basis:

• Legitimate interests: To improve your shopping experience and show you relevant content.
• Consent: Where personalization involves profiling or tracking beyond what is reasonably expected.

Information used: Browsing history, purchase history, preferences.

Your rights: You have the right to object to personalization based on legitimate interests.

3.6 To Improve Our Website and Services

What we do:

• Analyze how customers use our Website
• Identify technical issues and fix bugs
• Test new features
• Conduct research and analysis
• Improve product offerings and services

Legal basis: Legitimate interests in understanding our customers, improving our services, and growing our business.

Information used: Website usage data, technical information, shopping behavior, customer feedback.

3.7 For Security and Fraud Prevention

What we do:

• Verify your identity
• Detect and prevent fraud, abuse, and security incidents
• Protect our Website from malicious activity
• Investigate suspected violations of our Terms and Conditions
• Maintain records for legal and regulatory compliance

Legal basis:

• Legitimate interests: To protect our business, customers, and Website from fraud and security threats.
• Legal obligation: To comply with legal requirements (e.g., anti-money laundering, consumer protection).

Information used: Account details, order information, payment verification data, IP address, device information, fraud risk scores.

3.8 For Legal Compliance

What we do:

• Comply with legal and regulatory requirements
• Respond to legal requests from authorities
• Maintain records required by law (e.g., tax, accounting)
• Enforce our legal rights

Legal basis: Compliance with legal obligations to which we are subject.

Information used: All information as necessary to comply with specific legal requirements.

3.9 For Business Transfers

What we do:

• Transfer your information if we sell, merge, or reorganize our business

Legal basis: Legitimate interests in conducting business transactions and ensuring continuity of services.

Information used: All personal information necessary for the business transaction.

Your rights: You will be notified of any business transfer that affects your personal information.

4. CUSTOMIZATION AND AUTOMATED DECISION-MAKING

4.1 What Is Customization?

Customization means using your personal information to analyze or predict your:

• Personal preferences
• Interests
• Behavior
• Purchasing patterns
• Economic situation

4.2 How We Use Customization

We use profiling for:

Product Recommendations:

• Suggesting products based on your browsing and purchase history
• Showing "You might also like" recommendations
• Personalizing product displays

Marketing Customization:

• Tailoring email content to your interests
• Segmenting customers for targeted promotions
• Sending relevant offers based on past purchases

Website Customization:

• Customizing website content based on your behavior
• Remembering your preferences
• Improving your user experience

4.3 Legal Basis for Customization

We rely on:

• Legitimate interests for basic personalization that improves your shopping experience.
• Consent for more extensive profiling or where required by law.

4.4 Automated Decision-Making

We do not make solely automated decisions that have legal or similarly significant effects on you.

Decisions that significantly affect you (such as order acceptance, credit decisions, or account termination) are reviewed by a human and are not based solely on automated processing.

Exception - Fraud Prevention:

We use automated fraud detection systems to assess the risk of fraudulent transactions. If our system flags a transaction as high risk, a human will review it before we take action (such as declining or canceling an order). You have the right to:

• Request human intervention
• Express your point of view
• Challenge the decision

Contact us at hello@kc-eu.com if you wish to exercise these rights.

4.5 Your Rights Regarding Customization

You have the right to:

• Object to profiling based on legitimate interests (see Section 10.6)
• Withdraw consent if profiling is based on your consent
• Request human intervention in automated decisions
• Opt out of personalized marketing at any time

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your personal information with trusted third parties who help us operate our business, with our Affiliates and with Global-E who is our service provider for the purposes of operating this Website. We only share what is necessary and require all third parties to protect your information.

5.1 Service Providers

We work with third-party companies, including Global-E, that process personal information on our behalf. These companies act as "data processors" and can only use your information as we instruct them.

5.1.1 IT and Website Services

Purpose: To host, maintain, and support our Website and IT systems.

Information shared: All information necessary to provide the service (website usage data, account information, technical data).

5.1.2 Email and Communication Services

Purpose: To send emails and other communications to you.

Information shared: Email address, name, communication preferences, email engagement data.

5.1.3 Customer Service Tools

Purpose: To manage customer service inquiries and support.

Information shared: Contact details, order information, communication history.

5.1.4 Analytics and Research

Purpose: To analyze website usage and customer behavior to improve our services.

Information shared: Website usage data, shopping behavior (anonymized information only).

Examples: Google Analytics.

Business Partners

Delivery Partners

Purpose: To deliver your orders to you.

Information shared: Name, delivery address, phone number, email address, order details.

Who: Courier and delivery companies e.g., DHL, UPS and Fedex.

Their privacy policies: Delivery partners have their own privacy policies governing how they handle your information.

5.2.2 Payment Processors

Purpose: To process payments securely.

Information shared: We share minimal information with our payment processor. Your payment card details are entered directly into the payment processor's secure system - we never see or store your full card details.

Information we share with payment processor:

• Order amount
• Currency
• Order reference
• Your email address (for payment receipts)

Information payment processor shares with us:

• Payment confirmation (success or failure)
• Transaction ID
• Last 4 digits of card number (for your reference)
• Card type

Who: e.g., Stripe, PayPal etc.

5.2.3 Fraud Prevention Services

Purpose: To verify identity and prevent fraud.

Information shared: Transaction details, device information, IP address.

Who: Fraud detection and prevention service providers, credit reference agencies.

5.2.4 Marketing Partners (with your consent)

Purpose: To provide you with marketing communications or enable social media features.

Information shared: Limited information as necessary (typically email address, engagement data).

Who:

• Social media platforms (if you use social login or share features)
• Marketing technology providers

Your rights: You can opt out of marketing and limit data sharing by managing your cookie preferences and communication preferences.

5.3 Legal and Regulatory Authorities

We may share your personal information with:

• Law enforcement agencies
• Regulatory bodies
• Courts and tribunals
• Government authorities

When: Only when required by law, court order, or to:

• Comply with legal obligations
• Protect our legal rights
• Prevent or detect crime
• Protect the safety of individuals

Information shared: Only what is necessary and legally required.

5.4 Professional Advisors

We may share your information with:

• Lawyers
• Accountants
• Auditors
• Insurance advisors
• Business consultants

Purpose: To obtain professional advice and services.

Information shared: Only what is necessary, and under strict confidentiality obligations.

5.5 Business Transfers

If we:

• Sell or buy any business or assets
• Merge with another company
• Reorganize our corporate structure
• Go into administration or liquidation

We may share your personal information with prospective buyers, sellers, or successors.

Your rights: You will be notified of any such transfer and the new controller's identity and contact details.

5.6 With Your Consent

We may share your information with other third parties where you have specifically consented to such sharing.

5.7 Aggregated and Anonymized Data

We may share aggregated, anonymized, or statistical data that does not identify you personally with:

• Business partners
• Advertisers
• Industry analysts
• Researchers

This information cannot be used to identify you.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

6.1 Transfers Outside the UK

Some of the third parties we work with are located outside the United Kingdom. This means your personal information may be transferred to, and processed in, countries outside the UK.

Countries we transfer to:

European Economic Area (EEA), United States, Israel

6.2 How We Protect International Transfers

When we transfer your personal information outside the UK, we ensure it is protected by using one or more of the following safeguards:

For transfers to the EEA and Israel:

• The UK government has determined that the EEA and Israel provides an adequate level of protection for personal information (adequacy decision).

For transfers to other countries:

• Standard Contractual Clauses (SCCs): We use UK-approved Standard Contractual Clauses, which are legal contracts that require the recipient to protect your information to UK standards.
• Appropriate Safeguards: We use other appropriate safeguards approved under UK data protection law.

7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We only keep your personal information for as long as necessary to fulfill the purposes for which we collected it, including to satisfy legal, accounting, or reporting requirements.

7.2 Determining Retention Periods

When determining how long to keep your information, we consider:

• The amount, nature, and sensitivity of the information
• The purposes for which we process it
• Whether we can achieve those purposes through other means
• Legal, regulatory, tax, accounting, or other requirements
• The risk of harm from unauthorized use or disclosure
• Whether you have requested deletion (subject to legal requirements)

7.3 Secure Deletion

When we no longer need your personal information, we will:

• Delete it securely from our systems; or
• Anonymize it so it can no longer identify you; or
• Archive it securely if we are legally required to keep it.

7.4 Exceptions

We may keep your personal information for longer periods if:

• Required by law
• Necessary to establish, exercise, or defend legal claims
• Necessary to protect vital interests
• You have consented to longer retention

8. HOW WE PROTECT YOUR PERSONAL INFORMATION

We take the security of your personal information seriously and use appropriate technical and organizational measures to protect it against unauthorized or unlawful processing, accidental loss, destruction, or damage.

8.1 Security Measures

Our security measures include:

Technical Measures:

• Encryption of data in transit (SSL/TLS certificates - you'll see "https://" in your browser)
• Encryption of sensitive data at rest
• Secure servers with firewalls and intrusion detection systems
• Regular security testing and vulnerability assessments
• Secure authentication (passwords, two-factor authentication where available)
• Automated backup systems

Organizational Measures:

• Access controls - only authorized personnel can access personal information
• Need-to-know basis - staff only access information necessary for their role
• Confidentiality obligations for all staff and contractors
• Regular training on data protection and security
• Data protection policies and procedures
• Incident response and breach notification procedures
• Vendor security assessments

Payment Security:

• We do not store payment card details
• Payment processing is handled by PCI-DSS certified payment processors
• Secure payment gateway with encryption

8.2 Your Responsibilities

You can help keep your information secure by:

• Choosing a strong, unique password for your Member Account
• Keeping your password confidential
• Not sharing your account with others
• Logging out after using your account on shared devices
• Keeping your devices and software up to date
• Being cautious of phishing emails claiming to be from Kenneth Cole

If you suspect unauthorized access to your account, contact us immediately.

8.3 Limitations

While we implement strong security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously work to improve our security practices.

8.4 Data Breaches

If we experience a data breach that is likely to result in a high risk to your rights and freedoms, we will:

• Notify the Information Commissioner's Office (ICO) as required by law
• Notify you without undue delay
• Provide information about the breach and steps you can take to protect yourself
• Take immediate action to contain and remedy the breach

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to improve your experience on our Website and to analyze how it is used.

9.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help the website remember information about your visit, such as your preferences and login status.

9.2 Types of Cookies We Use

We use the following types of cookies:

9.3 Cookie Policy

For detailed information about the cookies we use, including:

• Specific cookie names and purposes
• Who sets them (first-party vs. third-party)
• How long they last
• How to manage your cookie preferences

9.4 Managing Cookies

You can control and manage cookies in several ways:

Browser Settings:

• Most browsers allow you to refuse or accept cookies
• You can also delete cookies already stored on your device
• See your browser's help section for instructions

Third-Party Opt-Outs:

• Google Analytics: https://tools.google.com/dlpage/gaoptout

Please note: Disabling certain cookies may affect the functionality of our Website and your user experience.

9.5 Do Not Track Signals

Some browsers have a "Do Not Track" feature. Our Website does not currently respond to Do Not Track signals, as there is no industry standard for how to respond to them.

10. YOUR RIGHTS UNDER UK DATA PROTECTION LAW

Under UK GDPR and the Data Protection Act 2018, you have several rights regarding your personal information.

10.1 Right of Access (Subject Access Request)

What it means: You have the right to request a copy of the personal information we hold about you.

What we'll provide:

• Confirmation that we process your personal information
• A copy of your personal information
• Additional information about our processing (purposes, categories, recipients, retention periods, etc.)

How to request: Email us at hello@kc-eu.com. We may ask for identification to verify your identity.

Timeframe: We will respond within 1 month (extendable by 2 months for complex requests).

Cost: Free (we may charge a reasonable fee for manifestly unfounded or excessive requests, or for additional copies).

10.2 Right to Rectification

What it means: You have the right to have inaccurate personal information corrected and incomplete information completed.

Examples:

• Updating your address
• Correcting your name or email address
• Adding missing information

How to request:

• Update your Member Account directly (if you have one)
• Contact us at hello@kc-eu.com

Timeframe: We will respond within 1 month.

10.3 Right to Erasure ("Right to be Forgotten")

What it means: In certain circumstances, you have the right to request deletion of your personal information.

When this applies:

• The information is no longer necessary for the purposes we collected it
• You withdraw consent (where processing was based on consent)
• You object to processing (and there are no overriding legitimate grounds)
• We processed your information unlawfully
• We must delete it to comply with a legal obligation
• The information relates to a child (under 18) and was collected online

When we may refuse:

• We need the information to comply with legal obligations (e.g., tax, accounting)
• We need it to establish, exercise, or defend legal claims
• Other legal grounds apply

How to request: Contact us at hello@kc-eu.com or close your Member Account.

Timeframe: We will respond within 1 month.

Please note: Deleting your account or exercising this right may prevent us from fulfilling ongoing orders or resolving disputes.

10.4 Right to Restriction of Processing

What it means: In certain circumstances, you can request that we limit how we use your personal information.

When this applies:

• You contest the accuracy of the information (restricted while we verify)
• Processing is unlawful but you don't want deletion
• We no longer need the information but you need it for a legal claim
• You have objected to processing (restricted while we verify our grounds)

Effect: We can store the information but not use it further without:

• Your consent
• For legal claims
• To protect another person's rights
• For important public interest reasons

How to request: Contact us at hello@kc-eu.com.

Timeframe: We will respond within 1 month.

10.5 Right to Data Portability

What it means: You have the right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.

When this applies:

• Processing is based on consent or contract performance
• Processing is carried out by automated means

What we'll provide:

• Your personal information in a portable format
• Where technically feasible, we will transmit it directly to another controller if you request

Information covered: Only information you provided to us (not derived or inferred data).

How to request: Contact us at hello@kc-eu.com.

Timeframe: We will respond within 1 month.

10.6 Right to Object

What it means: You have the right to object to processing based on:

• Legitimate interests (including profiling)
• Direct marketing
• Scientific/historical research or statistics

10.6.1 Objecting to Direct Marketing

Absolute right: You have an absolute right to object to direct marketing at any time, including profiling for marketing purposes.

How to object:

• Click "unsubscribe" in any marketing email
• Update your preferences in your Member Account
• Contact us at hello@kc-eu.com

Effect: We will stop sending you marketing communications immediately.

10.6.2 Objecting to Processing Based on Legitimate Interests

How to object: Contact us at hello@kc-eu.com and explain your objection.

Our response: We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or we need the information for legal claims.

Timeframe: We will respond within 1 month.

10.7 Rights Related to Automated Decision-Making

What it means: You have the right not to be subject to decisions based solely on automated processing (including profiling) that have legal or similarly significant effects on you.

Our practice: We do not make solely automated decisions that significantly affect you.

Your rights: If we do use automated decision-making, you have the right to:

• Request human intervention
• Express your point of view
• Challenge the decision

10.8 Right to Withdraw Consent

What it means: Where we process your personal information based on your consent, you have the right to withdraw consent at any time.

Examples:

• Opting out of marketing
• Withdrawing consent for cookies (see Section 9)
• Withdrawing consent for optional processing

How to withdraw:

• Click "unsubscribe" in marketing emails
• Update your preferences in your Member Account
• Manage cookie preferences in your browser or our Cookie Preference Center
• Contact us at hello@kc-eu.com

Effect: Withdrawal does not affect the lawfulness of processing before withdrawal. We may still be able to process your information on other legal grounds (e.g., contract performance, legal obligation).

10.9 How to Exercise Your Rights

Contact us at the email: hello@kc-eu.com

What we need:

• Your full name
• Email address or Member Account details
• Proof of identity (to prevent unauthorized disclosure)
• Clear description of your request

Verification: To protect your information, we may ask you to verify your identity (e.g., by providing account information or identification documents).

Timeframe: We will respond to all requests within 1 month (extendable by 2 months for complex requests - we'll let you know if this applies).

No fee: Exercising your rights is generally free. We may charge a reasonable fee for manifestly unfounded or excessive requests.

Refusal: If we refuse your request, we will explain why and inform you of your right to complain to the ICO.

11. CHILDREN'S PRIVACY

11.1 Age Restrictions

Our Website and services are not intended for children under the age of 18.

We do not knowingly collect personal information from children under 18. You must be at least 18 years old to:

• Create a Member Account
• Place an order
• Use our services

11.2 Parental Responsibility

If you are under 18, you may only use our Website and services with the involvement and consent of a parent or guardian.

11.3 If We Discover We Have Collected Children's Data

If we become aware that we have collected personal information from a child under 18 without appropriate parental consent:

• We will take steps to delete the information as soon as possible
• We will restrict or block access to the account
• We will not use or share the information

11.4 Parents and Guardians

If you believe we have collected information from a child under 18, please contact us immediately at hello@kc-eu.com and we will take prompt action.

12. MARKETING COMMUNICATIONS

12.1 Types of Marketing Communications

We may send you marketing communications about:

• New products and collections
• Special offers and promotions
• Sales and discounts
• Exclusive Member benefits
• News and updates about Kenneth Cole
• Fashion tips and styling advice
• Surveys and feedback requests

12.2 How We Send Marketing

We send marketing communications primarily by:

• Email
• SMS/text message (if you have opted in)
• Push notifications (if you have opted in to app notifications)

12.3 Legal Bases for Marketing

We send marketing communications based on:

12.3.1 Consent (Direct Opt-In)

If you have actively opted in to receive marketing (e.g., by ticking a box when creating your account or subscribing to our newsletter), we rely on your consent.

12.3.2 Legitimate Interests

If you are an existing customer (you have purchased from us or created an account), we may send you marketing about similar products based on our legitimate interests, provided:

• You have not opted out
• The marketing relates to similar goods or services
• You were given a clear opportunity to opt out when we first collected your details and in every subsequent communication

This applies only to email marketing to existing customers.

12.4 Opting In to Marketing

You can opt in to marketing by:

• Ticking the marketing consent box when creating a Member Account
• Subscribing through our newsletter signup form
• Updating your preferences in your Member Account

12.5 Opting Out of Marketing (Unsubscribing)

You can opt out at any time, easily and free of charge.

How to opt out:

• Email marketing: Click the "unsubscribe" link at the bottom of any marketing email
• Member Account: Update your communication preferences in your account settings
• SMS marketing: follow the unsubscribe instruction available in any SMS received

Effect of opting out:

• We will stop sending you marketing communications
• You will still receive service-related communications (order confirmations, delivery updates, customer service responses, important account information)
• Your opt-out preference will be recorded and honored

Timeframe: We will process opt-outs immediately, but please allow up to 5 business days for your opt-out to be fully implemented across all our systems. You may receive communications already in progress during this time.

12.6 Managing Your Preferences

You can manage your marketing preferences at any time, including:

• Choosing which types of marketing you receive (products, offers, newsletters, etc.)
• Choosing how often you receive marketing (if we offer frequency options)
• Opting in or out of specific marketing channels (email, SMS, etc.)

Update your preferences in your Member Account.

12.7 Marketing to Non-Customers

If you are not an existing customer (you have not purchased from us or created an account), we will only send you marketing if you have explicitly consented (opted in).

13. CHANGES TO THIS PRIVACY POLICY

13.1 Updates

We may update this Privacy Policy from time to time to reflect:

• Changes in law or regulation
• Changes to our business or services
• New ways of processing your information
• Changes to data protection best practices
• Improvements for clarity

13.2 Notice of Changes

Material changes: If we make significant changes that affect your rights or how we use your personal information, we will notify you by:

• Email (to the email address on your account)
• Prominent notice on our Website
• Notification through your Member Account

Minor changes: For minor changes (e.g., updates for clarity, contact information changes), we may simply update this Privacy Policy and note the "Last Updated" date at the top.

13.3 Reviewing Changes

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

The latest version is always available at the URL in which this Privacy Policy is available.

13.4 Continued Use

Your continued use of our Website and services after we publish or notify you of changes constitutes your acceptance of the updated Privacy Policy.

If you do not agree with the changes, you should stop using our services and contact us to close your account or exercise your rights under Section 10.

14. YOUR RIGHT TO COMPLAIN

14.1 Contact Us First

If you have any concerns about how we handle your personal information, please contact us first so we can try to resolve the issue:

Email: hello@kc-eu.com

We take privacy concerns seriously and will investigate and respond to your complaint.

14.2 Complaint to the ICO

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection supervisory authority, if you believe we have not handled your personal information properly or have violated your data protection rights.

Information Commissioner's Office (ICO):

14.3 No Retaliation

You will not suffer any detriment or negative consequences for making a complaint to us or the ICO. We respect your rights and take all complaints seriously.

15. CONTACT US

15.1 Privacy Questions and Requests

For any questions about this Privacy Policy or to exercise your data protection rights, please contact:

Privacy Team

Email: hello@kc-eu.com

15.2 General Inquiries

For general customer service inquiries:

Email: hello@kc-eu.com

© 2026 Kenneth Cole Europe BV. All rights reserved.