PRIVACY POLICY

Last Updated: July 1, 2023

Overview

This privacy policy governs the manner in which Tommie Copper, Inc. ("we," "us" or "our") collects, uses, maintains and discloses information collected from users (each, a "User" or "you") of the www.tommiecopper.com Website (the "Website") or in connection with Users' ordering, accessing, using or purchasing any of our Products (collectively, the "Products") or otherwise in any transaction with us, irrespective of where the User is located. This privacy policy applies to the Website and all Products and services offered by Tommie Copper. It also applies to all information we collect in email, text and other electronic messages between you and our Website or any other communications with us. Please note that the Website may contain links to other third-party websites that are not controlled or operated by Tommie Copper. This Privacy Policy does not apply to such third-party websites, and Tommie Copper is not responsible for the content of such third-party websites or the privacy practices of such parties.

Personal identification information

We may collect personal identification information ("personal information") from Users in a variety of ways including in the course of the following activities:

• Visiting our Website.
• Registering on the Website.
• Placing an order on the Website.
• Subscribing to the newsletter.
• Providing Product feedback.
• Participating in consumer contests, sweepstakes, or other promotions.
• Responding to a survey or requests for user's opinions, concerns, and preferences regarding Tommie Copper Products.
• Communicating with Tommie Copper via text message, email, telephone, or any other form of electronic communication.
• Filling out a form. This includes information you may provide when you request additional information about Tommie Copper Products or services.
• Using any other features of the Website that may be offered from time to time and may require such information in order to utilize the feature.

Users may be asked for, as appropriate, name, email address, mailing address, phone number, credit card information, and any other information you may choose to provide. If you provide us with your phone number and consent to text marketing, you agree to receive text messages to that number from Tommie Copper. If you submit your email address in connection with an order or request, you agree that Tommie Copper and its third-party service providers may use your email address to contact you about the status of your order or request and for other administrative purposes.

We will collect personal information from Users only if they voluntarily submit such information. Users can always refuse to supply personal identification information, except that it may prevent them from engaging in certain Website related activities. If at any time, you do not wish to receive communications from Tommie Copper, you can unsubscribe from such communications by using the unsubscribe function located on every promotional email or by contacting us at info@tommiecopper.com.

Financial Information

Tommie Copper may require billing and payment information such as credit and debit card information when you create your account. However, all payment transactions entered into on the Tommie Copper Website are processed by third party payment processors, including Braintree Payments, PayPal, Google Pay, Apple Pay and Affirm (each individually a "payment processor"). At checkout, you will provide your payment information to the payment processor, and that payment processor's Privacy Policy and Terms and Conditions of Use will govern use and disclosure of that information. We encourage you to read carefully the payment processor's Privacy Policy and Terms and Conditions of Use which can be accessed from its website. Tommie Copper does not use or store your financial information.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Website. Non-personal identification information may include, but is not limited to, demographic information, precise location information from GPS, cell tower proximity, browser information, type of computer and technical information about Users' means of connection to our Website, such as the operating system and the Internet service providers utilized and other similar information. This non-personal information is aggregated by using certain tools and mechanisms such as the use of cookies and web beacons, including pixels and GIFs, or collection of IP addresses and is kept and used in aggregate form, unless stated otherwise.

We do not knowingly collect or solicit personal information from users under 18. Please see our Terms of Use https://www.tommiecopper.com/terms-of-use/.

Web browser cookies and Web beacons

Our Website may use "cookies" to enhance User experience. Cookies are alphanumeric identifiers that we transfer to or access from your computer or device through your web browser for record-keeping purposes, to track information about you, and to enable and improve the accessibility and functionality of the Website. Some cookies allow us to make it easier for you to navigate our Website, while others allow us to track your activities at our Website.

User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Website may not function properly.

In addition, our Website may use web beacons, also known as pixel tags, web bugs, or GIFs. A web beacon is a tiny graphic image of one pixel that can be delivered to your computer; pixels can be used to retrieve information from your device, like your device type or operating system or IP address and time of visit. They are also used to serve and read cookies in your browser.

We may also allow third-party advertising companies to target and show you advertisements when you visit the Website. These third-party advertisers may send "cookies" to your computer or other device to gather information about your preferences to provide you with advertising that is more likely to relate to your interests. On occasion, Tommie Copper may permit third-party advertisers and ad networks to place their own cookies on our Website to track Users' activities on the Website. This enables such companies to recognize Users so that when those Users visit a third-party's website, advertising can be delivered that is tailored to the visitor's individual interests (whether for Tommie Copper's Products or for the Products or services of others), based on what has been learned from the Users' activity on our Website or elsewhere. This practice is called "interest-based advertising," and the practices of these third-parties are not covered by this Privacy Policy. Tommie Copper offers you choices about the collection of information on our Website. Tommie Copper adheres to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising. If you decide you do not want to receive personalized ads from third-party advertisers and ad networks please visit www.AboutAds.info/choices, where you can learn more about opting out from receiving interest-based advertising. You can also learn more about your opt-out choices by visiting www.networkadvertising.org. Please be aware that opt-out tools are device and browser specific, so you must repeat any opt-outs you select for each of your browsers and devices.

Tommie Copper uses cookies to collect information around abandoned shopping carts. A cart is considered abandoned after one hour of inactivity/lack of purchase. Once the timer has expired an email message will be sent as a reminder.

Granting us permission to use cookies

Our Website utilizes the following types of cookies:

• Essential: these cookies are essential for our Website and any requested services to work, but do not perform any additional or secondary function;
• Functional: these cookies enable enhanced functionality, such as videos and live chat;
• Analytics: these cookies provide statistical information on Website usage in order to improve our Website over time; and
• Targeted Advertising cookies: these cookies are used to create profiles or personalize content to enhance your shopping experience.

By clicking the "I agree" button on the cookie banner on our homepage or by continuing to use our Website after you have received this cookie notification, you give us your permission to use cookies. However, removing or changing settings may limit the accessibility and functionality of our Website, which means that it may not work as you would expect.

For more detailed information about cookies, including the specific types of cookies our Website utilizes and how to disable cookies, visit www.allaboutcookies.org.

How we use collected information

Tommie Copper collects and uses Users' personal information for the following purposes:

• To improve our Website: We continually strive to improve our Website offerings based on the information and feedback we receive from you. We also use applications provided by third parties, such as Google Analytics, to evaluate the usage of our Website. These tools help us improve the user experience and performance of our Website.
• To improve customer service: Your information helps us to more effectively respond to your customer service requests and support needs.
• To provide you with marketing and promotional material mailings once you order from us through our Website. If at any time a User no longer wants to receive promotional mailings from us, you can contact us by email at info@tommiecopper.com or call us at toll free number 1-855-692-8291. You can also opt-out by using the unsubscribe link in any of our promotional emails. It may take up to 10 business days to be removed from our mailings.
• To process transactions: We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.
• To send periodic emails: The email address Users provide for order processing will be used to send them information and updates pertaining to their order. It may also be used to respond to their inquiries, and/or other requests or questions. If Users decide to opt-in to our mailing list, they will receive emails that may include company news, updates, related Product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions in each email we send you.
• To process transactions and purchases that you make on the Website, or through the Website.
• To protect our rights or comply with law - We may disclose personal information to enforce our rights arising from any contracts entered into between you and Tommie Copper; to comply with any court order, legal process, or respond to any governmental or regulatory request; or to protect Tommie Copper's rights or property or the safety of Tommie Copper, our customers, employees, or others.
• Sale or merger - We also may disclose personal information to a buyer or other successor in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of Tommie Copper's assets.

How we protect your information

We adopt appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Website. Sensitive and private data exchange between the Website and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. While we use security measures to protect sensitive and personal information transmitted online, please be aware that no security measures are perfect or impenetrable. If you have any questions about the security of personal information collected by Tommie Copper, please contact: info@tommiecopper.com.

Sharing your personal information

Tommie Copper may disclose your personal information to its subsidiaries and affiliates and to third parties whom Tommie Copper hires to provide services on Tommie Copper's behalf, including but not limited to, support services, Website services, delivering promotional materials, contests and answering customer questions about Products. Tommie Copper will only provide those third parties with the personal information that they need to deliver the services to Tommie Copper and/or on Tommie Copper's behalf. We share your payment information, including your credit or debit card number, card expiration date, CVV code, and billing address with payment service providers to process payments; prevent, detect and investigate fraud or other prohibited activities; or for other purposes associated with the use of credit or debit cards.

We may share or disclose non-personal, generic aggregated demographic information not linked to any personal information regarding Users with our business partners, trusted affiliates and advertisers for the purposes outlined above. Tommie Copper will only provide those third parties with the information that they need to deliver services to Tommie Copper and on Tommie Copper's behalf. We may disclose your information to third parties in connection with business transfers if we are acquired by, merged with or invested in by another company or if any of our assets are or may be transferred to another company, whether a part of a bankruptcy or insolvency proceeding or otherwise. As part of the business transfer process, we may share certain of your personal information with lenders, auditors and third-party advisors, including attorneys in consultants. Notwithstanding anything to the contrary in this Privacy Policy, we may disclose your information if we believe it is reasonably necessary to comply with a law, regulation, legal process or government request; to protect the safety of any individual; to address fraud, security or technical issues; to protect our or other users' rights or property.

Targeted Advertising Partners

We disclose certain personal information (e.g. identifiers, commercial information, contact preference information, geolocation information, internet or other electronic network activity information and inferences) to and work with third-party companies that support our advertising and marketing efforts, including to serve interest-based advertisements across the internet and to track and categorize your activity, interests and device(s) used over time on our Website and on third-party websites. The advertising networks and related providers gather this information to create individual profiles that are disclosed to us, which allows us the ability to match those individual customer profiles with advertisements we believe may be most relevant to a particular customer. You may opt-out of targeted advertising by using the menu options on our Do Not Sell or Share My Personal Information page https://www.tommiecopper.com/privacy-rights-request-form or by emailing us at info@tommiecopper.com or calling us at our toll-free number at 1-855-692-8291.

Accessing your personal information

You may log in to Tommie Copper to update your registration information.

Your State-Specific Privacy Rights and Choices

For Users residing in California and certain other states, applicable state laws may grant you additional rights. For more information on the specific rights granted for each state and when those are effective, see our U.S. State-Specific Privacy Disclosures here.

Do Not Track Signals

Certain web browsers provide users with an option by which you may have your browser send a "Do Not Track" signal to websites that you are visiting, advising the recipient websites that you do not want to have your online activity tracked. However, the way browsers communicate such "Do Not Track" signals are not yet uniform and, accordingly, our Website does not take any action in response to such signals. In the event a final standard is developed and accepted, we may reassess how we should respond to such signals.

Children's information

Our Website is not directed to children under the age of 18, and our Terms prohibit children under 18 from using our Website. We do not knowingly collect any information from children under 18. Please contact info@tommiecopper.com if you believe your child under age 18 has submitted personal information to Tommie Copper without prior parental or legal guardian consent so that we may take steps to delete the information.

U.S. Website Data Protection Rights

Tommie Copper operates in the United States of America under U.S. law. Any information you choose to send to this Website or Tommie Copper will be subject to the laws of the United States. If you do not wish your information to be subject to U.S. law, please do not send it to Tommie Copper. If you choose to use our Website from the outside the United States, you consent the transmission to and use in the United States of any information collected or provided from you consistent with his Privacy Policy.

To the extent any personal information is received from non-U.S. residents, Tommie Copper will protect the personal information of non-U.S. Users in the same way as it does U.S. Users and will comply with applicable laws.

Subject to applicable law (for example, if you are located in the European Union with rights under the General Data Protection Regulation), you may have one or more of the following rights with respect to personal information: the right to request access to such information; the right to request correction of such information; the right to request deletion or erasure of such information; the right to request restrictions on our processing or use of such information; the right to object to our use under certain circumstances; the right to withdraw consent under circumstances when consent is required for any use of such information; and the right to obtain such information in portable form.

In certain circumstances in any European Union member state, you may have the right to lodge a complaint regarding our privacy practices with the applicable data protection authority.

To exercise any rights under the GDPR or for further information, please contact us at info@tommiecopper.com.

Tommie Copper does not intend to offer its Products or services in any jurisdiction where the offering of such Products or services would be contrary to applicable local law, and any such offer of Products or services is void if illegal under applicable law.

Changes to this privacy policy

Tommie Copper has the discretion to update this privacy policy at any time. The most current version of the policy will govern our use of your information and will always be at https://www.tommiecopper.com/privacy-policy. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Website, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Website. Your continued use of the Website following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, please contact us at:

Tommie Copper
www.tommiecopper.com
74 S. Moger Ave.
Mount Kisco, NY 10549
1-855-692-8291
info@tommiecopper.com