ENROUSH UK LIMITED PRIVACY POLICY

We understand that the security and confidentiality of the data of our members, subscribers, visitors, and customers are of utmost importance. That’s why we take data protection seriously and are committed to protecting your personal data throughout your use of the website www.enroush.co.uk (“the Website”) and our services.

1. General Information

This Privacy Policy ("Policy") explains how the company Enroush UK Limited, a legal entity incorporated and operating in accordance with the laws of the United Kingdom, with its registered office at 590 Green Lanes, London N13 5RY, United Kingdom, registered under company number 16447401, (hereinafter referred to as the "Company") collects, processes, and protects your personal data in accordance with the provisions of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Personal data refers to any information relating to an identified or identifiable individual (“Personal Data” or “Data”).

The Company acknowledges the importance of your data and is fully committed to protecting its confidentiality and security by processing your Personal Data in accordance with the UK GDPR and applicable UK data protection legislation.

We reserve the right to periodically update and amend this Policy to reflect changes in our practices or legal obligations. Any such updates will be posted on this Website, so we encourage you to review this Policy from time to time.

With respect to the Personal Data we collect, the Company acts as the data controller, meaning we determine the purposes and means of processing your personal data.

In line with our compliance efforts and commitment to safeguarding your data, we may collect and process Personal Data, which may include: names, surnames, phone numbers, email addresses, physical addresses, bank account information, order details, and other identifiers — depending on the nature and purpose of the interaction.

This data is used strictly for purposes such as:
• Processing and fulfilling orders
• Customer service and support
• Shipping and delivery
• Managing warranties and returns
• Recruitment processes
• Newsletters and promotional communications (only where permitted)
• Compliance with legal obligations

If you wish to contact us in relation to your Personal Data or this Policy, you may do so at:
Enroush UK Limited
590 Green Lanes, London N13 5RY, United Kingdom
Email: privacy@enroush.co.uk

If you wish to return a package, please use the following warehouse address:
DRMG House
Sittingbourne
Kent ME10 3US
United Kingdom

2. Principles Related to the Processing of Personal Data

We process Personal Data in accordance with the key principles set out in the UK General Data Protection Regulation (UK GDPR):
• Lawfulness, fairness, and transparency: Personal Data is processed lawfully, fairly, and in a transparent manner.
• Purpose limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
• Data minimisation: Data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
• Accuracy: Data is accurate and kept up to date. Inaccurate data is erased or rectified without delay.
• Storage limitation: Data is retained only for as long as necessary for the purposes for which it is processed.
• Integrity and confidentiality: Data is processed securely, protecting it against unauthorised or unlawful processing, accidental loss, destruction, or damage through appropriate technical and organisational measures.
• Accountability: Enroush UK Limited takes responsibility for ensuring compliance with UK data protection laws and can demonstrate such compliance.

3. Purposes and Legal Bases for Processing Your Personal Data

Enroush UK Limited processes your Personal Data for the following purposes and under the following lawful bases as set out in Article 6 of the UK GDPR:

a. Performance of a Contract
To fulfil the contractual relationship with you, including order processing, shipping, invoicing, returns, and customer service.
Legal Basis: UK GDPR Art. 6(1)(b) – necessary for the performance of a contract or to take steps at your request before entering into a contract.

b. Marketing Communications
To send you information about promotional campaigns, updates, or new product launches.
Legal Basis: UK GDPR Art. 6(1)(a) – your explicit consent is required before we send any such communication.

c. Legal Compliance
To comply with legal obligations such as tax and accounting requirements, cooperation with public authorities, archiving, and defending our legal rights.
Legal Basis: UK GDPR Art. 6(1)(c) – necessary for compliance with a legal obligation.

d. Service Improvement and Analytics
To improve our products, services, and website experience by analysing user preferences, trends, and engagement across social platforms and digital channels.
Legal Basis: UK GDPR Art. 6(1)(a) – based on your consent.

e. Responding to Inquiries
To respond to your questions, feedback, and requests.
Legal Basis: UK GDPR Art. 6(1)(f) – based on our legitimate interest in providing quality customer service.

f. User-Generated Content
If you share content about Enroush on social media (e.g., hashtags, photos, videos), we may feature such content on our platforms or in marketing materials.
Legal Basis: UK GDPR Art. 6(1)(a) – your consent.

If we ever intend to use your Personal Data for any purpose not listed above, we will provide you with all necessary information prior to doing so.

4. Types of Personal Data Collected

The types of Personal Data that Enroush UK Limited may collect include (but are not limited to):
• Name, surname, company name, name of legal representative
• VAT number, trade registration number
• Gender, date of birth, email address
• Delivery address, billing details, payment method
• Phone number, bank card details
• Photos, public social media profile information (e.g., name, profile URL, posts, “likes,” publicly available info)
• User-generated content on social media (e.g., images, videos, text, hashtags, posts, symbols)
• Location data
• Hobbies and interests, consumption habits
• Browser and device data (e.g., IP address, MAC address, Google Ad ID, Advertiser ID)
• Server logs, app usage data, website engagement metrics (e.g., time of access, page views, features used)
• Any other information you may voluntarily provide in your interaction with our services.

Sensitive Personal Data

You may also choose to provide what the law considers "Special Category Data" (referred to in the EU as “Sensitive Information”), including:
• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Health or medical data
• Sex life or sexual orientation
• Criminal convictions and offences (where applicable)

Important: We ask that you do not submit any special category data via our website, social media channels, or any communications unless specifically requested and legally required for a purpose made clear to you.

Additional Collection Contexts

We may also collect data from the following scenarios:
• When you communicate with us via email, contact forms, or social media
• When other users or third parties send us information or feedback about your activity
• When you engage with features of the website, such as referral tools

Referral Services

If you use our referral service to invite friends, we may request your friend’s name and email address solely for the purpose of sending the invitation and tracking its status. This data will not be used for other purposes. Your friend may unsubscribe via the link provided in the email or contact us at privacy@enroush.co.uk to have their data removed.

Withholding Personal Data

If you choose not to provide certain Personal Data required to access or use parts of our services, we may be unable to provide those services to you.

5. How We Collect Personal Data

We may collect your Personal Data through various means, including:
• Direct interaction with you – such as when you contact our customer support team;
• When you use our services or purchase products – for example, placing an order on www.enroush.co.uk, where we require your information to process, deliver, and fulfil your purchase;
• When you register an account on our website or use features that require account creation;
• Via social media platforms – when you interact with our official pages on Instagram, Facebook, or similar platforms;
• When you subscribe to our newsletter or opt in to marketing communications.

If you create a user account, you will be able to access, review, and update your personal details (such as name, email, address, password, and preferences) at any time through your profile settings.

6. Duration of Data Processing

We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including:
• To perform contractual obligations (e.g., order fulfilment, returns)
• To comply with legal, tax, and regulatory requirements
• To maintain records for accountability and dispute resolution
• To support our legitimate business interests, such as fraud prevention and recordkeeping

Legal Retention Requirements

In some cases, we may be required to retain data for longer periods under applicable UK laws. For example:
• Accounting and tax records: typically retained for up to 6 years after the end of the financial year in which the transaction took place, as required by HMRC.
• Contractual relationships: retained as long as necessary to enforce or defend legal claims, including up to 6 years after the end of a contract.

In case of a potential dispute, complaint, or regulatory inquiry, we may retain your Personal Data until the issue is fully resolved.

Deletion of Data
• If you delete your user account, we will stop sending you promotional emails and SMS. However, please note that deleting your account does not automatically erase all associated Personal Data.
• If there are any active orders, account deletion will only be processed once those orders are fulfilled.
• You can withdraw your consent for marketing at any time by clicking the unsubscribe link or contacting us. This does not affect the lawfulness of any processing based on your consent prior to withdrawal.

For deletion or access requests, please refer to Section 9: Your Rights Under UK Data Protection Law.

7. Disclosure of Personal Data

To fulfil the purposes described in this Policy and to enable the operation of our services, Enroush UK Limited may disclose your Personal Data to carefully selected third parties and partners who assist us in delivering our services or performing business functions. These include:
• Payment processors, delivery companies, IT service providers, cloud hosting providers, data analytics companies, customer service platforms, and professional advisors (e.g., legal, accounting, tax).
• Subsidiaries or affiliated companies operating under the ENROUSH brand in other jurisdictions. They may contact you with relevant information about their services or products, where lawful and with your consent where required.
• Third-party platforms, such as social media networks (e.g., Meta, Instagram), where you interact with us or consent to sharing information via these services.

We ensure that all service providers processing your Personal Data do so under legally binding contracts requiring them to maintain strict confidentiality and adequate technical and organisational security measures. If any transfers occur to jurisdictions outside the United Kingdom, we will ensure appropriate safeguards are in place (e.g., International Data Transfer Agreements (IDTAs) or adequacy decisions).

Data Transfers Outside the UK

Your Personal Data may be transferred to or accessed from countries outside the UK. Where this occurs, we will take steps to ensure your data is afforded an adequate level of protection, consistent with UK data protection laws. This may include relying on:
• An adequacy decision issued by the UK government;
• Standard Contractual Clauses approved for international transfers;
• Binding Corporate Rules where applicable.

Legal and Regulatory Disclosures

We may disclose your Personal Data:
• To comply with legal obligations, such as a court order, law enforcement request, subpoena, or regulatory authority;
• When we believe in good faith that such disclosure is necessary to protect our rights, enforce our Terms & Conditions or this Policy, investigate potential violations, or prevent harm;
• To report threats to public safety or serious bodily harm where lawfully required.

Marketing and Aggregated Data

We do not sell or rent your Personal Data to third parties for direct marketing purposes.

However, we may share aggregated or anonymised data that does not directly identify you for analytical, research, or promotional purposes.

Change of Control

If Enroush UK Limited undergoes a change in ownership or control, including a merger, acquisition, or sale of assets, your Personal Data may be transferred to the new controlling entity, provided that the use remains consistent with this Privacy Policy.

User Responsibilities

You are strictly prohibited from using other users’ personal information obtained via the Enroush website for any commercial, spam, harassment, or unlawful purposes.

If you do not agree to the terms of this Policy or the use of your data in the ways described, we advise you not to provide your Personal Data. However, this may prevent us from delivering some or all of our services to you.

8. International Transfers of Personal Data

Your Personal Data may be transferred to and stored in countries outside the United Kingdom, including countries where our partners, service providers, or affiliated companies are located.

Please note:
• These countries may not offer the same level of protection for your data as the UK.
• Where we transfer Personal Data internationally, we ensure appropriate safeguards are in place, including the use of:
    ○ UK Government adequacy regulations, or
    ○ Standard Contractual Clauses (SCCs) approved for UK data transfers, or
    ○ International Data Transfer Agreements (IDTAs).

We take all reasonable steps to ensure that your data remains protected and handled in accordance with this Policy and the UK GDPR.

9. Your Rights Under UK Data Protection Law

Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have the following rights as a data subject:
• Right to be informed – You have the right to be informed about the collection and use of your Personal Data.
• Right of access – You can request confirmation of whether we hold Personal Data about you, and obtain a copy, as well as details on how and why it is processed.
• Right to rectification – You can request the correction or completion of inaccurate or incomplete Personal Data.
• Right to erasure (“right to be forgotten”) – You may request deletion of your data under specific conditions, such as where data is no longer necessary, consent is withdrawn, or data has been unlawfully processed.
• Right to restrict processing – You may ask us to restrict the processing of your Personal Data in certain cases, such as while a dispute about its accuracy is being resolved.
• Right to data portability – You may request your data in a structured, commonly used, machine-readable format, and have it transferred to another data controller.
• Right to object – You can object to the processing of your data, particularly where processing is based on legitimate interests or used for direct marketing purposes.
• Right not to be subject to automated decision-making – You have the right not to be subject to decisions made solely by automated means that significantly affect you.
• Right to lodge a complaint – If you believe your rights have been violated, you may file a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection (www.ico.org.uk).

How to Exercise Your Rights

To submit a request, please contact us at:

Enroush UK Limited
Email: privacy@enroush.co.uk
Postal Address: 590 Green Lanes, London N13 5RY, United Kingdom

We will respond to all legitimate requests within one month. If your request is particularly complex or you’ve made multiple requests, we may extend this period by a further two months and will notify you of this extension.

In the event of a dispute, we will investigate and take appropriate action. If you are not satisfied with our response, you can escalate your complaint to the ICO.

10. Use of Website by Minors

Our websites and services are intended for individuals aged 18 and over. Children under the age of 18 are not permitted to use the Enroush UK website or any of our services.

We do not knowingly collect or process Personal Data from individuals under 18 years of age. If we become aware that such data has been provided, we may request proof of parental or guardian consent before continuing any processing of such data. Where consent is not provided, the data will be deleted.

11. Data Security

Enroush UK Limited takes the security of your Personal Data seriously and implements appropriate technical and organisational measures to protect it from loss, misuse, and unauthorised access.

We protect your data against threats including:
• Accidental loss or theft
• Unauthorised access, use, or disclosure
• Alteration or falsification of data
• Unlawful or unnecessary data retention
• Destruction of data (accidental or malicious)

Our employees are trained in data protection procedures and are required to follow internal policies designed to ensure your data is processed securely and lawfully. Any suspected data breaches, unauthorised access, or security incidents are reported immediately to the designated data protection officer or system administrator.

We strongly advise users:
• Not to share Personal Data on public forums or platforms where information can be accessed by others (e.g., blog comments, social media, chat rooms).
• Not to disclose your user account password to anyone else.
• If you believe your account has been compromised, you should change your password immediately and notify us at privacy@enroush.co.uk.

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