Trouva respects your privacy and is committed to protecting your Personal Data. This Privacy Policy will tell you how we look after your personal data when you visit our website and/or use our mobile app, (together referred to as the “website” or “site”).This privacy policy covers both:

1. Users of the Trouva website and shoppers (someone who uses our services to shop with a boutique or brand, or uses our video call and messaging service to make an enquiry (e.g. seek advice or view a product demo), or interacts with or creates content on Trouva) where Trouva is the controller of such data (in come cases alongside any boutique from whom a user purchases); and

2. Representatives of boutiques or brands (someone who uses the video call and messaging service to respond to enquiries on behalf of the boutiques and brands and posts content). We are an independent data controller of the data for the purposes of providing the service to boutiques, analyzing and improving the services and moderating the services. Please note that the boutique that you work with will also be a separate data controller of any personal data you submit to the platform (or someone submits on your behalf) and may use it for their own purposes subject to and in accordance with their privacy policy.

We want to be transparent with you and we want to make sure you know what happens to your Personal Data, what your rights are and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

- Who we are and how to contact us.
- Your rights relating to your Personal Data.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use your Personal Data and why.
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources.
- How we use cookies and other tracking or profiling technologies.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Third party links.

The Privacy Policy is intended to meet our duties of Transparency under the UK and EU General Data Protection Regulation or “GDPR”. We will post any modifications or changes to this Privacy Policy on this page, unless we specifically notify you otherwise.

Who we are.

‍Found FY Ltd, an English limited company trading under the name “Trouva”, is the Controller of your Personal Data (referred to in this Privacy Policy as either “Trouva”, “we”, “us” or “our”). Our address is: Prince Albert House, 18a/20 King Street, Maidenhead, Berkshire, United Kingdom, SL6 1EF.

‍How to contact us.

‍You can contact us directly with any privacy-related queries or complaints by submitting a query. For our customers located in the EU, please contact our EU representative for any questions about this Privacy Policy or any other requests, using the details set out below:

Name: Privacy Officer

Email address: privacy.eu@trouva.com

Postal address: Avenida D. João II 46, 4, 1990-095 Lisboa

Your rights in connection with your Personal Data Under certain circumstances (and depending on the lawful basis for processing), by law you have the right to:

- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

‍How to exercise your rights
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‍If you want to exercise any of the rights described above, please contact us by submitting a query.

‍Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights outlined above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may simply refuse to comply with your request in these circumstances.

- What do we need from you?
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‍We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

- How long do we typically take to resolve requests?
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‍We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

‍Complaints

‍If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us here. We will reply to your complaint as soon as we can. If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office. If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click here for a list of contact details for the EEA data protection authorities

You can ask us to stop sending you marketing messages at any time by:

- Following the “Unsubscribe” links on any marketing message sent to you (including emails relating to Boutiques you have chosen to ‘Follow’ on the Trouva platform); and/or
- contacting us at any time by submitting a query.

‍Where you opt out of receiving these marketing messages, this opt-out will not apply to service-related communications (and any processing of your Personal Data involved in sending such communications). As a non-exhaustive list of what these service-related communications may include, they might be emails or notifications:
- about orders you make using the Trouva platform;
- relating to the management of your account on the Site;
- about your use of the Site;
- or concerning updates to this Privacy Policy or our Terms & Conditions etc.

If you use our Trouva App, you may receive push notifications from us if you have opted in to receive them. You can choose to turn these off at any time through your relevant device.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below. Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it means: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.


Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it means: information about an individual, from which that individual is either directly identified or can be identified.It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

‍Category of Personal Data collected
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No Special Categories of Personal Data
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We do not collect any “Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We will never ask for, and you should not provide, any such data when using the platform.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our "legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

- Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity).

- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law“).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

‍Processing Purposes

Where you fail to provide Personal Data that we need to process based on Contractual Necessity or for the purposes of Compliance with Law, we may not be able to perform the contract we have or are trying to enter into with you (for example, we may not be able to open your account, we may have to close your account, we may not be able to procure the fulfilment of your order or process a return etc).

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Please refer to our Cookie Policy.

The table below describes who we share your Personal Data with, what we share and why we share it. We may share your Personal Data with other Controllers (i.e., people who can use the relevant data for their own purposes), as well as Processors (i.e., people who use the relevant data only on our behalf and under our instruction).Data transfersWe share your Personal Data with certain external third parties who are based outside the UK and European Economic Area (“Europe"). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of the UK and Europe.We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK ICO and European Commission.- Where we use service providers outside the UK and Europe, we may use specific contracts approved by the European Commission and ICO in the UK, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Standard Contractual Clauses (SCC) (europa.eu) and international-data-transfer-agreement.pdf (ico.org.uk)

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. The efficacy of these security measures is evidenced by the fact that we have attained the following certifications and accreditations:- Attestation of PCI DSS compliance by an independent certified party-Cyber Essentials SchemeAll our employees are subject to a contractual duty of confidentiality, alongside other protective measures. We strive to maintain appropriate administrative, technical and physical safeguards designed to protect personal data we collect. You should take every precaution in protecting your personal data by for example creating strong passwords by using a combination of upper and lower case letters, special characters and numbers, change passwords frequently, and use a secure browser. We require our service providers to protect your personal data as we do in this policy, and they may not use this for any other purpose. We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

We are committed to only keeping your Personal Data for so long as we reasonably need to use it for the purposes set out above. This general rule applies unless a longer retention period is required by law (for example for regulatory purposes). In respect of the Personal Data we process to provide you with the Trouva platform and associated services, we will only keep this Personal Data for so long as you have an open account on the Site. When you close your account, we will delete or irreversibly anonymise your Personal Data within thirty (30) days (save that we may keep any personal data we are required to by law, or for the completion of any outstanding sales for example). As noted above:- in respect of any Personal Data we process based on our, or a third party’s, legitimate interests, you have the right to object to processing of your Personal Data for this purpose at any time; and- you also have a general right to request erasure of your Personal Data where there is no good reason for us continuing to process it.If you want to exercise either of these rights, please contact us. Please note that this data retention framework does not apply to Aggregated Data, which we may store for a longer period of time.

This Site is not intended for children below 18 and we do not knowingly collect data relating to such children.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.Found FY Ltd t/a Trouva, 2024