We understand that your personal data is exceptionally important to you — especially given the nature of the products we sell. When you trust us with your information, we have a duty to handle it with complete care, transparency, and respect. This policy tells you exactly what we collect, why we collect it, and what rights you have over it.

01

Who We Are

Sumptuous Pleasure is a trading name of Tees Luxury Label Ltd, a company registered in England and Wales. We operate the website at sumptuouspleasure.com and are the data controller responsible for your personal information collected through this website.

Company Name: Tees Luxury Label Ltd

Trading As: Sumptuous Pleasure

Registered In: England and Wales

Website: sumptuouspleasure.com

Privacy Contact: hello@sumptuouspleasure.com

ICO Registration: Registered with the Information Commissioner’s Office as required under UK GDPR

In this policy, references to “we”, “us” or “our” mean Tees Luxury Label Ltd. References to “you” mean you as a visitor to our website or a customer of Sumptuous Pleasure.

02

Who This Policy Applies To

This Privacy Policy applies to all individuals who interact with us, including:

  • Website visitors — anyone who browses sumptuouspleasure.com
  • Customers — anyone who places an order or purchases a product
  • Account holders — anyone who creates a customer account
  • Email subscribers — anyone who signs up to receive our marketing communications
  • Contact form users — anyone who sends us a message or enquiry

03

What Data We Collect

Information you give us directly

  • Identity data: First name, last name
  • Contact data: Email address, delivery address, billing address, telephone number
  • Transaction data: Details of products you have purchased, order history, order value
  • Payment data: Payment method type — we do not store card numbers; these are processed securely by our payment providers
  • Account data: Username, password (encrypted), account preferences
  • Communications data: Any information you provide when you contact us by email or via our contact form
  • Marketing preferences: Your preferences for receiving marketing from us and your communication preferences

Information collected automatically

When you visit our website, we automatically collect certain technical information:

  • Usage data: Pages visited, time spent on pages, links clicked, search terms used on our site
  • Technical data: IP address, browser type and version, device type, operating system, screen resolution
  • Referral data: The website or search engine that directed you to our site
  • Cookie data: Information collected through cookies and similar tracking technologies — see Section 12 for full details

IP addresses are stored for security purposes for seven days in a form that allows identification of suspicious activity, then anonymised or deleted.

Information from third parties

  • Payment providers (Stripe, PayPal): Confirmation of payment and transaction references
  • Delivery providers (Royal Mail): Delivery status updates
  • Analytics providers (Google Analytics): Aggregated and anonymised website usage data
  • Marketing platforms (Klaviyo): Email engagement data where you have subscribed to our list

04

How We Use Your Data

We use your personal data only for the purposes described below. We will never use your data in a way that is inconsistent with what you would reasonably expect.

Purpose Data Used Legal Basis
Processing and fulfilling your order Identity, contact, transaction, payment data Contract performance
Sending order confirmations and dispatch notifications Identity, contact, transaction data Contract performance
Responding to your enquiries and customer support Identity, contact, communications data Legitimate interests
Managing your customer account Identity, contact, account data Contract performance
Sending marketing communications Identity, contact, marketing preference data Consent
Personalising your experience on our website Usage, technical, cookie data Consent / Legitimate interests
Improving our website and product offering Usage, technical data (anonymised) Legitimate interests
Preventing fraud and ensuring website security Technical, identity, transaction data Legitimate interests / Legal obligation
Complying with legal and regulatory obligations Identity, contact, transaction, payment data Legal obligation
Running targeted advertising campaigns Cookie, usage data (with consent) Consent

05

Legal Basis for Processing

Under UK GDPR, we are required to have a lawful basis for processing your personal data. We rely on the following legal bases:

  • Contract performance (Article 6(1)(b)): Processing necessary to fulfil your orders, manage your account, and provide the services you have requested from us
  • Legitimate interests (Article 6(1)(f)): Processing necessary for our legitimate business interests — such as improving our website, preventing fraud, and responding to customer enquiries — where these interests are not overridden by your rights
  • Consent (Article 6(1)(a)): Processing based on your explicit consent — specifically for marketing communications and non-essential cookies. You may withdraw consent at any time.
  • Legal obligation (Article 6(1)(c)): Processing required to comply with applicable laws — such as retaining financial records for tax purposes

06

Sensitive Data & The Nature of Our Business

We recognise that purchases from The Intimacy Edit may be considered sensitive. Buying intimate wellness products could, in certain contexts, reveal information about your personal life, relationships, or preferences. We take this seriously.

We do not collect data about your sexual preferences, identity, or lifestyle. We collect only the information necessary to process your order and, where you have chosen to subscribe, to send you marketing.

Your order history — including purchases from The Intimacy Edit — is stored securely and is never shared with third parties for their own marketing or profiling purposes. Our staff access order data only when necessary to process, fulfil, or support your order.

All Intimacy Edit orders are dispatched in discreet packaging. Your bank statement shows a charge from Tees Luxury Label Ltd only. We have designed every step of the purchase journey to protect your privacy.

07

How We Share Your Data

We do not sell your personal data to any third party. We do not share your data with third parties for their own marketing purposes. Full stop.

We share your data only where it is necessary to operate our business and fulfil your order:

  • Royal Mail: Your name and delivery address are shared to fulfil your delivery. Royal Mail acts as a data processor under our instruction.
  • Stripe and PayPal: Payment data is processed by our payment providers. We do not store or have access to your full card details.
  • Klaviyo: Email address and marketing preferences are processed by Klaviyo to manage our email communications where you have subscribed.
  • Google Analytics: Anonymised website usage data is shared with Google for analytics purposes.
  • WooCommerce / WordPress: Our e-commerce platform processes data necessary to operate our store.
  • Legal authorities: We will disclose personal data to law enforcement or regulatory bodies if required to do so by law or in response to a valid legal request.

All third-party providers with whom we share data are required to handle it in accordance with applicable data protection law and our data processing agreements.

08

Third-Party Processors

The following third-party services process personal data on our behalf as data processors:

Provider Purpose Data Shared
Stripe Payment processing Payment details, billing address
PayPal Payment processing Payment details, billing address
Royal Mail Order delivery and tracking Name, delivery address
Klaviyo Email marketing and automation Name, email, order data (where subscribed)
Google Analytics Website analytics Anonymised usage and technical data
TikTok Pixel Advertising and conversion tracking Anonymised usage data (with consent)
Pinterest Tag Advertising and conversion tracking Anonymised usage data (with consent)
Meta Pixel Advertising and conversion tracking Anonymised usage data (with consent)
WooCommerce E-commerce platform operation Order, account and transaction data

09

International Data Transfers

Some of our third-party service providers are located outside the UK. Where your personal data is transferred outside the UK, we ensure that appropriate safeguards are in place in accordance with UK GDPR, including:

  • Transfers to countries with UK adequacy decisions
  • Standard contractual clauses approved by the ICO
  • The UK International Data Transfer Agreement (IDTA) where applicable

Klaviyo and Google are both based in the United States. Both are certified under applicable data transfer frameworks and operate under standard contractual clauses where required.

If you would like more information about the safeguards in place for any specific transfer, please contact us at hello@sumptuouspleasure.com.

10

How Long We Keep Your Data

We retain personal data only for as long as necessary for the purpose it was collected, or as required by law. Our standard retention periods are:

Data Type Retention Period Reason
Order and transaction records 7 years UK tax law requirement
Customer account data Duration of account + 2 years after last activity Legitimate interests / Contract
Marketing list data Until you unsubscribe or request deletion Consent
Contact and enquiry records 2 years from date of contact Legitimate interests
IP addresses (full) 7 days Security and fraud prevention
Website analytics data 26 months (anonymised) Legitimate interests
Cookie consent records 1 year Legal compliance

When data is no longer required, we delete it securely or anonymise it so it can no longer be linked to you.

11

Marketing Communications

How we market to you

We will only send you marketing emails if you have explicitly consented to receive them — either at checkout, via a sign-up form, or by subscribing to our email list. We do not add customers to marketing lists without consent.

Our marketing may include new product announcements, promotions, skincare education, fragrance guides, and wellness content. All emails are sent via Klaviyo.

How to unsubscribe

You can unsubscribe from our marketing emails at any time by:

  • Clicking the unsubscribe link at the bottom of any marketing email
  • Emailing hello@sumptuouspleasure.com with the subject “Unsubscribe”
  • Updating your preferences in your customer account

Unsubscribing from marketing will not affect transactional emails — we will still send order confirmations and dispatch notifications as these are necessary to fulfil your order.

Targeted advertising

With your consent, we may use cookies and tracking pixels (TikTok, Pinterest, Meta) to show you relevant advertisements on other platforms. This is based on your browsing behaviour on our website. You can manage these preferences through our cookie consent tool at any time.

12

Cookies

Our website uses cookies — small text files stored on your device that help the website function correctly and allow us to understand how it is being used. We use four categories of cookies:

  • Strictly necessary: Essential for the website to function. These cannot be disabled. They enable core features such as your shopping basket, checkout, and account login.
  • Performance: These collect anonymised data about how visitors use our site — pages visited, time on site, error messages. We use Google Analytics for this purpose.
  • Functional: These remember your preferences to provide a more personalised experience.
  • Marketing: Used to show you relevant adverts on other platforms (TikTok, Pinterest, Meta). These require your consent and can be managed through our cookie consent tool.

For full details on the cookies we use and how to manage them, please see our Cookie Policy at sumptuouspleasure.com/cookie-policy.

13

Your Rights

Under UK GDPR, you have the following rights in relation to your personal data. We will respond to all valid requests within 30 days.

Right to Access

Request a copy of the personal data we hold about you (a Subject Access Request). We will provide this free of charge.

Right to Rectification

Request correction of inaccurate or incomplete personal data we hold about you.

Right to Erasure

Request deletion of your personal data where we no longer have a lawful basis to hold it. Also known as the “right to be forgotten.”

Right to Restrict Processing

Request that we limit how we use your data in certain circumstances — for example, while you contest its accuracy.

Right to Data Portability

Request your personal data in a structured, machine-readable format so you can transfer it to another service.

Right to Object

Object to processing based on legitimate interests or for direct marketing purposes. We will stop unless we have compelling legitimate grounds.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.

To exercise any of these rights, please contact us at hello@sumptuouspleasure.com. We may ask you to verify your identity before processing your request. There is no charge for exercising your rights.

14

Data Security

We take data security seriously and implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction.

These measures include:

  • SSL encryption on all pages of our website to protect data in transit
  • Encrypted password storage — your account password is stored in hashed, unreadable form
  • Payment card security — we use PCI-DSS compliant payment providers. We never store your full card details.
  • Access controls — personal data is accessible only to staff and systems that require it for legitimate business purposes
  • Regular security reviews of our systems and third-party providers

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and will report the breach to the ICO within 72 hours as required by UK GDPR.

15

Children’s Privacy

Products from The Intimacy Edit are for adults aged 18 and over only. Our website is not directed at children. We do not knowingly collect personal data from anyone under the age of 16.

If you believe a person under 16 has provided personal data to us, please contact us immediately at hello@sumptuouspleasure.com and we will delete that data promptly.

Online purchases through our website require you to be at least 16 years old, or to have parental consent.

16

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. The date at the top of this page shows when the policy was last updated.

Where changes are significant, we will notify you by email (where we hold your address) or by a prominent notice on our website. We encourage you to review this page periodically to stay informed about how we protect your data.

Continued use of our website or services following any update constitutes your acknowledgement of the revised policy.

17

Contact Us & Complaints

Exercise your rights or ask a question

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how we handle your personal data, please contact us:

Email: hello@sumptuouspleasure.com

Subject line: Privacy — [your request]

Response time: Within 30 days of receipt

Right to complain to the ICO

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) — the UK supervisory authority for data protection:

  • Website: ico.org.uk
  • Telephone: 0303 123 1113
  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We would always appreciate the opportunity to address your concern directly before you contact the ICO, but you are of course free to contact them at any time.

Sumptuous Pleasure is a trading name of Tees Luxury Label Ltd, registered in England and Wales.