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PRIVACY POLICY

The following document outlines the Privacy Policy for the JoJo Maman Bébé
website.
Terms Correct as of Tuesday 7th March 2023


Introduction

Choosing to shop with JoJo Maman Bébé means you've placed a great deal of trust
in us. In sharing your personal information we hope you in return benefit from a
tailored and convenient shopping experience. With trust comes responsibility and
we take this responsibility very seriously.


This privacy policy helps you to understand how we use your personal information
and who we share it with. It applies if you shop on a JoJo Maman Bébé or NEXT UK
website, using the NEXT app, shop in a NEXT or JoJo Maman Bébé store in the UK
or if you otherwise share your personal information with us; for example if you
contact us with a query or we send you marketing.


We change the terms of this privacy policy from time to time and you should
check it regularly. The last updated date is shown at the beginning of the
document. If we make any material changes we will take steps to bring it to your
attention.

Who we are

We are NEXT Plc (company number: 4412362), when we say “we”, “our” or “us” in
this policy we are referring to the companies that are part of the NEXT Group,
which are:


Next Retail Limited, Next Holdings Limited, Next Distribution Limited, Next
Manufacturing Limited, Next Sourcing Limited, Next Retail Ireland Limited, Next
Germany GmbH, Next Beauty Limited, Lipsy Limited, Victoria’s Secret (VS Brands
Holdings UK Limited), GAP (West Apparel UK Holdings Limited), Reiss (Pink Topco
Limited), JoJo Maman Bébé (Regent BidCo 1 Limited) and Joules (The Harborough
Hare Limited).


We are the data controller, which means we are responsible for deciding how and
why your personal information is used. We are also responsible for making sure
it is kept safe, secure and handled legally.


We operate to the highest standards when protecting your personal information
and respecting your privacy. If you have any questions about your personal
information, or how we use it, you can contact our Data Protection Officer via
email at dataprotection@next.co.uk or by writing to our registered office at the
following address: Data Protection Officer, NEXT Group, Desford Road, Enderby,
Leicester, LE19 4AT.



Your rights

You have a number of “Data Subject Rights”, we have explained below what they
are and how you can exercise them. You can read more about these rights on the
Information Commissioner's Office website at www.ico.org.uk

 * Right of access - You have the right to request a copy of the personal
   information that we hold about you.

 * Right to rectification – If you think any of your personal information that
   we hold is inaccurate, you have the right to request it is updated. We may
   ask you for evidence to show it is inaccurate.

 * Right to erasure (also known as the Right to be Forgotten) – You have the
   right to request that we delete your personal information that we hold.

 * Right to restriction of processing – You have the right to request we
   restrict or suppress the personal data we hold about you.

 * Right to data portability – You have the right to ask us to electronically
   transfer your personal information to another organisation in certain
   circumstances.

 * Rights with regards to automated decision making, including profiling – We
   sometimes use your personal information to make decisions by automated means.
   This involves us analysing your account activity including applications,
   orders, payments etc. We do this to confirm your identity, prevent and detect
   crime, and lend responsibly. This automated decision making is necessary if
   you would like to continue to shop with us online. You have a right to reject
   automated decisions, but it may mean that you can only shop with us in our
   stores.

 * Right to withdraw Consent – Where we are relying on your consent for
   processing you can withdraw or change your consent at any time.


The above rights may be limited in some circumstances, for example, if
fulfilling your request would reveal personal information about another person,
if you ask us to delete information which we are required to have by law, or if
we have compelling legitimate interests to keep it. We will let you know if that
is the case and will then only use your information for these purposes. You may
also be unable to continue using our services if you want us to stop processing
your personal information.


If you have any general questions or want to exercise any of your rights please
contact dataprotection@next.co.uk or visit https://www.next.co.uk/help for other
ways to contact us. In order to maintain the security of our customers' personal
details, we may need to request proof of identity before we disclose personal
information to you in response to any request.


We encourage you to get in touch if you have any concerns with how we collect or
use your personal information. You have the right to lodge a complaint directly
with the Information Commissioner's Office, the data protection regulator in the
UK, you can do this by visiting the ICO website:
https://ico.org.uk/make-a-complaint/

The lawful bases we use to process data

We will only ever process your information if we have a lawful basis to do so.
The lawful bases we rely on are:



 * Contract – This is where we process your information to fulfil a contractual
   arrangement we have made with you.

 * Consent – This is where we have asked you to provide explicit permission to
   process your data for a particular purpose.

 * Legitimate Interests - This is where we rely on our interests as a basis for
   processing. Generally this is to provide you with the best products and
   services in the most secure and appropriate way, but not where our interests
   are overridden by your interests.

 * Legal Obligation – This is where we have a statutory or other legal
   obligation to process the information, such as for the investigation of crime
   or to meet responsible lending criteria.

 * Vital interests – This is where the processing of personal information is
   necessary to protect someone’s life.

The information we collect and how we use it

We collect and use the information that you provide to us directly, for example;
when you register for an account; we use cookies and other similar technologies
to collect information from your devices when you interact with our advertising
or use our website (you can find out more information in the “Cookie Policy”
section below); we keep records when you speak to our customer service teams; we
use CCTV in our stores for security monitoring and market research purposes; we
take personal information from a number of third parties to help us manage your
account and improve your shopping experience.


To process any orders that you place with us and to facilitate any returns
(Contract)

 * We take payment details to process payment for any credit or debit card
   orders you place with us. We share these details with our chosen payment
   processors (for example Worldpay, Klarna or Paypal)

 * We use your account information plus your chosen delivery address details to;
   deliver your purchases and keep you informed of their status, and to process
   any returns including (where appropriate) collecting the item from you (for
   example Evri or DHL).

 * Our chosen payment processors may store your payment card details at your
   request to speed up your checkout in the future (consent).


To provide you with access to an account (Contract)

 * To register an account with us we capture information such as your name,
   contact and delivery information, and a password to protect your account
   (account information). We use the same information on an ongoing basis to
   manage and provide secure access to your account, and provide you with the
   services you request.


To provide customer service to you (Legitimate Interest)

 * We record calls and keep correspondence (customer service records) when you
   contact our customer service teams or interact with us on social media. We
   use these customer service records to manage your queries or complaints
   effectively, for quality monitoring and to continually improve our services.


To offer and manage any credit we provide to you (Contract & Legitimate
Interest)

 * When you apply for and use credit with us we will use your account
   information to make searches with third parties who will give us information
   about you, such as your financial history. We do this to assess your
   creditworthiness and product suitability.

 * We use purchase and payment history, along with your account information on a
   cyclical basis to manage your credit facility with us.

 * We use your account information, purchase history, payment history and third
   party information to collect and recover money that is owed to us should your
   account fall into arrears. Please see the section on “third parties we share
   data with and receive data from” below for more information.


To personalise and improve your experience when you shop (Legitimate Interest)

 * We keep a record of how you interact with our website and any marketing you
   are exposed to, we use this data, along with purchase history, demographics,
   account information and third party information, to show you products and
   offers from across our brands that we think you will be most interested in
   and to tailor your experience.

 * In our stores we use CCTV footage for market research purposes so that we can
   best arrange our stores and stock the ranges our customers will be most
   interested in.

 * We will send you a receipt by email if you have requested this when you shop
   in one of our stores (consent).

 * We use your account information, information on the devices you use to access
   our sites and your interactions with us to operate personalised features
   across our websites, apps and communication.

To inform you about products and services that may interest you (Legitimate
Interest)

 * We use technologies such as cookies within digital marketing networks, ad
   exchanges and social media networks such as Facebook’s Custom Audience to get
   relevant marketing messages across to you and other customers. We share
   aggregated and anonymised information about the customer segments we are
   interested in reaching with advertising partners, so they can focus on
   showing adverts to those who are most likely to be interested in our
   products, services and offers, and to prevent them showing you irrelevant or
   repetitive advertisements.

 * We share limited information with selected suppliers to enable them to
   identify new prospective customers on our behalf and to prevent us from
   repeatedly advertising products or services you have already bought.

 * We receive information on how you interact with our adverts and content on
   third party websites and social media platforms (such as Google or Facebook)
   which we use to tailor the information that is displayed to you.


To keep in touch with you (Legitimate Interest)

 * When you register for an account and shop with us we will keep you up to date
   with news of products and services including store events, offers, promotions
   and sale information - unless you tell us you don’t want us to through the
   “my account” or using the link in every email that we send to you.

 * When we send you communications we use records of how you interact with our
   website and any other marketing we have sent to you, along with purchase
   history, to tailor the messages to include information you are most likely to
   be interested in.

 * We use your account information to notify you about important service
   messages, such as material changes to this policy, product recalls or
   information about your account.

 * If you enter or apply for a prize draw or competition we will collect your
   contact details so that we can inform you if you are a winner (Contract).

n.b. If at any point you have made amendments to your contact preferences in the
“my account” section of our website, selecting to receive communications from
us, we are operating under consent instead of legitimate interest.


To ensure the Website and the services we offer you operate properly (Legitimate
Interest/Consent)

 * We use cookies and other similar technologies to keep track of your
   preferences when using our site.

 * We use other cookies and similar technologies to help us understand how you
   use the site, this allows us to optimise your shopping experience and
   continually improve our site.

 * We gather information about the devices you use to access our sites (desktop
   and mobile) for example your IP address and device type, to ensure the site
   is secure and works across multiple platforms.

 * We use information for logistics planning, demand forecasting, management
   information, dealing with errors on our site, and general research and
   development.


To develop and improve our products, range and services (Legitimate Interest)

 * We share insights about our customers (in an anonymised and aggregated
   format) with the companies whose products we sell. This helps them better
   understand the different profiles of our customers, focusing on those who buy
   their products or are interested in them.

 * We may contact you to take part in customer satisfaction surveys, if you
   respond we collect your feedback and contributions (customer feedback). We
   use this information to develop the services we offer.

 * We work with information providers that specialise in consumer profiling,
   such as Experian and Merkle. These organisations provide demographic or other
   data to help better understand customers' demographics, lifestyles or
   shopping behaviours, usually linked to the areas where people live.

 * We use information about how you browse and engage with our website to
   improve our websites.

 * We use all information, including third party data in the development of new
   products, services and systems to ensure they work as expected and will be
   useful to our customers.


To prevent and detect crime and other incidents (Legitimate interest/Legal
obligation)

 * We use your account information, order history and payment history to assist
   in monitoring for fraudulent transactions or suspected money laundering.

 * When you shop in our stores we use CCTV for security monitoring, for
   operational efficiency purposes or for the protection of our staff, customers
   and products. This includes for the investigation of accidents, incidents,
   criminal activities and breaches of our policies.

 * Our employees may wear body-worn devices to protect themselves in limited
   circumstances. These devices record both audio and video and are only
   activated in high risk situations such as aggressive behaviour and/or when
   there is a threat of violence.

 * When you register an account, apply for credit or contact our call centres we
   use your account, application and purchase history information to confirm
   your identity.

 * We use device identifiers and IP addresses in fraud prevention and
   investigation, and to maintain network and data security.

 * We maintain a record of any health and safety incidents that occur in our
   stores or in our premises.


To fulfil our legal obligations (Legal obligation)

 * We use your data to ensure we comply with any requirements imposed on us by
   law or court order, including disclosure to law or tax enforcement agencies
   and authorities or pursuant to legal proceedings.

 * We will share data with regulatory and other official bodies if they make
   formal requests.

 * We will maintain records to meet regulatory and tax requirements.

 * We will use your account information to contact you in connection with
   product recalls or other similar product quality issues and to comply with
   our legal obligations in connection with the sale of age restricted products.

Cookie Policy

What are cookies?


Cookies are small text files that are stored on your computer, mobile device or
other web enabled device when you visit the NEXT website or app. Cookies allow
us to “remember” your actions or preferences over a period of time, or they may
contain data related to the function or delivery of our websites. We also use
the term “cookie” to describe similar technologies such as pixels or tags.


What do we use cookies for?


Some cookies are required by our site to enable you to transact whilst other
cookies enable us to give you an enhanced, personalised web experience. We use
cookies for the following purposes:

 * To allow you to securely sign in to your NEXT account, so that you can use
   "My Account" features such as order information, making payments and viewing
   statements.

 * To store the content of your online shopping bag whilst you browse the site
   and to complete an order.

 * To record the areas of the website that you have visited, products you have
   viewed and time spent browsing, as well as the products you purchased. NEXT
   uses this information to help make the website more user friendly, develop
   our website design and to continuously improve the quality of the service we
   provide.

 * To distribute visitors to our website evenly across platforms to ensure the
   content is served at the fastest possible speed.

 * Provide relevant products and services to you when you come to the website
   and ensure that relevant marketing material is provided to you.

 * Detect and prevent fraud and other crimes.

We also offer you the facility to share your experience on our website through
social sites such as facebook and twitter. More information about how these
providers use cookies can be found on their websites.


What cookies do we use?


NEXT uses the following cookies on our website and apps:

 * Strictly necessary Cookies - These cookies are necessary for the website to
   function and cannot be switched off. They are used, for example, to make sure
   your transaction is secure, to enable you to log in to the secure areas of
   your account, such as your order history and to add items to your basket.
   Blocking these cookies through your browser will mean that some parts of our
   website won’t work.

 * Performance Cookies or analytical Cookies -These cookies allow us to monitor
   visitors to our website and ensure it is performing correctly. We use this
   information to measure overall performance, improve your website experience
   and improve the design of our website. These cookies don’t collect any
   information that could identify you - all information collected by these
   cookies is anonymous.

 * Functionality Cookies -These cookies enable enhanced functionality on our
   website, such as allowing you to add to favourites or remember your language
   preferences.

 * Onsite Targeting: Marketing and Personalisation Cookies - These cookies are
   placed by NEXT and are used to help us to build an understanding of your
   interests (for example by understanding what products you have browsed on our
   website) and show you products, services and advertisements relevant to you
   whilst you are on the NEXT website. These cookies make it possible for us to
   personalise your experience on this website and (if you are subscribed) in
   our email marketing.

 * Off Site Targeting: Marketing and Personalisation Cookies -These cookies are
   placed by our trusted advertising and marketing partners (including social
   networks). These help us to build an understanding of your interests (for
   example by understanding what products you have browsed on our website) and
   show you products, services and advertisements relevant to you. These cookies
   make it possible for us to ensure that you don’t see irrelevant, duplicate or
   multiple ads from us in a short period of time. We do want to prevent ads
   continuously re-appearing and annoying you.


For more detailed information and a full list of cookies used on our website
please select “Manually Manage Cookies” at the bottom of the page then click
“Cookies Detail”.


Can I turn off or block cookies?


NEXT uses cookies to ensure that we provide the best possible standard of
service to our online customers. You can change your cookie preferences at any
time by clicking on “Manually Manage Cookies” at the bottom of the page. You can
then adjust the available sliders to on or off, then click “Confirm my choices”.
If you choose not to consent to the use of cookies your experience of our
website may be impaired and many integral aspects of the website, including (but
not limited to) adding items to your shopping bag and accessing your account,
will not work.


Alternatively, most web browsers allow some control of most cookies through the
browser settings. To find out more about how to manage cookies, including how to
delete cookies, visit https://www.allaboutcookies.org/



How long we keep your data for

We keep your personal information as long as you are a customer of ours and
generally for 7 years afterwards to comply with legal requirements. During that
time we take steps to remove any personal data as soon as we no longer need it.


We consider you a customer:

 * as long as you hold an open credit account,

 * for 2 years from the point you last made a purchase from our website using a
   non-credit account, or

 * during any time we are managing a customer service request from you.

We keep CCTV footage on our systems for up to 30 days, it is then deleted. Where
accidents, incidents, criminal activities or breaches of our policies are
recorded CCTV footage may be kept for a longer period of time.

Third Parties we share data with and receive data from

We work with a number of trusted third parties to provide you high quality goods
and services. Anybody we work with is subject to stringent security and data
privacy assessments before we begin to do business with them and on an ongoing
basis.


We always make efforts to anonymise data and only pass over personal information
that is absolutely necessary for the purposes it is being processed. We always
do so securely.


We have contracts in place with all suppliers that help us to ensure security
and privacy of your personal information, these are reviewed and updated
regularly and always in line with data protection laws.

 * NEXT Group companies –We will share your personal information, in certain
   circumstances with the other companies within the NEXT Group. This is so that
   we can provide personalised services across our Group.

 * Delivery Partners – Helping us to deliver the goods you order to you
   including our brand partners that dispatch and deliver goods to you directly.

 * IT Companies – Supporting us in maintaining our website and other business
   systems including; providing phone lines, data storage facilities, and
   providing and supporting Cloud based infrastructure used in providing our
   products and services.

 * Marketing Companies and Online Advertising - Helping us to manage our
   electronic communications to you and to help us show you the advertising you
   are most likely to be interested in, Companies that provide marketing and
   advertising assistance (including management of email marketing operations,
   mobile messaging services such as SMS, and services that deploy advertising
   on the internet or social media platforms, such as Facebook and Google) as
   well as analysis of the effectiveness of our advertising and communications
   campaigns.

 * We use technologies such as cookies, pixels, and device IDs within digital
   marketing networks, ad exchanges and social media networks such as Facebook’s
   Custom Audience to get relevant marketing messages across to you.

 * Consumer profiling organisations - These organisations provide demographic or
   other data to help better understand customers' demographics, lifestyles or
   shopping.

 * Payment processors - Payment card processors to process credit and debit card
   payments and store payment information; for example Worldpay and Paypal.

 * Credit Reference Agencies (CRAs) - We share your personal information with
   CRAs on an ongoing basis, including details of settled accounts and any debts
   not fully repaid on time. CRAs will share your information with other
   organisations.


The identities of the CRAs, and the ways in which they use and share personal
information, are explained in more detail at:

 * Experian Credit Reference Agency Information Notice

 * TransUnion Credit Reference Agency Information Notice

 * Equifax Credit Reference Agency Information Notice


We also take information from CRAs to allow us to make decisions about your
credit account and credit facility.

 * Fraud prevention services -Before we provide goods and services to you, we
   use third parties to undertake fraud and money laundering checks and verify
   your identity. These organisations will report to us on industry fraud
   indicators and if they have reason to believe an identity is fraudulent. If
   we have reason to suspect fraud or other criminal offences we will pass your
   personal information to fraud prevention agencies (such as CIFAS) or law
   enforcement agencies for the detection, investigation and prevention of
   crime. If we think there is a risk of fraud, we may suspend activity on your
   account or refuse access to your account and/or cancel an order. If we do
   this we will inform you by email or SMS and ask you to contact us.

 * Debt collection agencies (DCAs) - If you default on repayments to your credit
   account we may share your data with DCAs to allow them to collect the
   outstanding debts from you.

 * Debt purchase companies – Where appropriate will share certain information on
   defaulted accounts with prospective debt purchasers as part of the
   negotiations for sale of the debt.

 * Debt management companies – Where we have received appropriate instruction we
   will share information about your credit account with debt management
   companies to allow them to assist you with managing your debts

 * Research and analytics companies – We may share personal details to allow
   research companies and feedback providers to contact you directly on our
   behalf in order to capture your opinions on our products, services, websites
   and apps. We may ask these research companies to analyse the results so that
   we can better understand your online experience, which will help us to
   improve our services. We only provide them with the information they need to
   perform their function. This may take the form of a survey, where you may be
   asked to review a product or service you’ve bought or provide general
   feedback on our products and services. You will always have the choice about
   whether to take part in our market research or surveys. We may share
   information with specialist companies to analyse customer information to help
   us better understand how you use our services and to tailor products,
   services and offers that may be relevant for you. We utilise companies that
   help us track and record the way you navigate our website, so that we can
   understand your online experience and use it to improve our services and
   offer a more personalised experience.

 * Product technicians – We use professional third party companies to assist us
   in independently reviewing issues and complaints with our products. We will
   share information with these technicians to allow them to review the product
   and return it to you or to review the product in your home.

 * General service companies -Such as insurance companies, printers and mailing
   houses that assist us in providing our products and services.

 * Regulators and the Police - We will share data with regulators and other
   official bodies (including law enforcement) if they make formal requests or
   pursuant to legal proceedings.

Sending information outside the United Kingdom

Our main operations are based in the UK and your personal information is
generally processed, stored and used within the UK . In some instances your
personal information may be processed outside the European Economic Area. For
example, NEXT operates a call centre in Pune, India. Operatives in this location
will have access to your account information in order to assist you with your
query. We also work with suppliers and partners who may make use of Cloud and
/or hosted technologies across multiple geographies.


If and when this is the case we take steps to ensure there is an appropriate
level of security so your personal information is protected in the same way as
if it was being used within the UK.


If you place an order with us and you are outside of the UK we will transfer the
data that we hold on you to NEXT Plc in the UK to facilitate your order.


Where we need to transfer your data outside the UK we will use one of the
following safeguards:

 * The use of European Commission approved standard contractual clauses in
   contracts for the transfer of personal data to third countries.

 * The International Data Transfer Agreement and Addendum for the transfer of
   personal information to third countries.

 * Transfers to a non-UK country with privacy laws that give the same protection
   as the UK.

Keeping your personal data secure

We always ensure that personal data is secure by continuously developing our
security systems and training for our employees. We have implemented appropriate
technical and organisational security measures designed to protect your personal
information against accidental or unlawful destruction, loss, alteration,
unauthorised disclosure, unauthorised access, and other unlawful or unauthorised
forms of processing, in accordance with applicable law.

Third-party apps, websites and services

If you use any third party apps, websites or services to access our services,
your usage is subject to the relevant third party's terms and conditions,
cookies policy, and privacy policy. For example, if you interact with us on
social media, your use is subject to the terms and conditions and privacy
policies of the relevant social media platform (Facebook, Twitter etc.). The
same applies if you use third party services, like Amazon's Alexa. In certain
cases we may be required to share your personal information, in relation to
transactions and usage of the services, with the relevant third party.

How you can get in touch

Write to:

Data Protection Officer

NEXT Group Plc

Desford Road,

Enderby, Leicester,

LE19 4AT


or you can email: dataprotection@next.co.uk





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