SHEIN PRIVACY POLICY FOR THE EUROPEAN UNION

Effective Date: July 1, 2021
Introduction and Overview
This Privacy Policy ( “Policy” ) explains how your personal information is collected, used, shared and processed when accessing this website or using other services provided by its operator, including any written, electronic, and oral communications, online or offline, and purchases performed (collectively, the “Services” ) as well as the rights and choices you have associated with that information.
The Services include any services provided via this website, located at SHEIN.com (the “Site,” which includes local versions of the Site, such as fr.shein.com or de.shein.com), our mobile applications (the “Apps” ), our accounts and fan pages on social media platforms (the “Social Media Accounts” ), any other written, electronic, and oral communications with the Company and its affiliated entities, and any other websites, pages, features, or content owned and operated by the Company that hyperlink to this Policy.
The company selling the products via the Site and Apps and providing the Services (and therefore, the payment collection entity) varies depending on your location when accessing and using the Services. Therefore, the terms “Company”, “we”, “us” or “our” refer to different entities. Accordingly, please read this Policy as follows: If you are located in the European Union , these terms refer to Infinite Styles Ecommerce Co., Ltd., 1-2 Victoria Building, Haddington Road, Dublin 4, Ireland, acting as joint controller together with Roadget Business Pte. Ltd., 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore (038987), privacy center .
Please read our Terms and Conditions and this Policy before accessing or using our Services. If you cannot agree with this Policy or the Terms and Conditions, please do not access or use our Services. If you are located in a jurisdiction outside the European Economic Area, the United Kingdom or Switzerland, then by using our Services, you accept the Terms and Conditions and Privacy Policy on the site you are using.
Right to modify this Policy: We may modify this Policy at any time, without prior notice, and changes may apply to any personal information that we already hold about you, as well as any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the effective date or last modified date at the top of this Policy. We will provide you with advanced notice if we make any material changes to how we collect, use or disclose your personal information that impact your rights under this Policy. If you are located in a jurisdiction other than the European Economic Area, the United Kingdom or Switzerland (collectively “European Countries” ), your continued access or use of our Services after receiving the notice of changes, constitutes your acknowledgement that you accept the updated Policy.
Instant information: In addition, we may provide you with real time disclosures or additional information about the personal information handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.
CONTENTS
Click on the links below to go to a specific section of this Policy.
1. Personal Information We Collect
We respect the privacy of the visitors to our digital properties and the users of our products and Services, and we are committed to protecting it through our compliance with this Policy. We collect personal information when you use our Services.
“Personal information” is any information that, alone or in combination with other information, identifies or makes an individual identifiable. The definition of personal information (used interchangeably in this Policy with the term “personal data” ) depends on the applicable law based on your physical location. If we provide location specific information below, only the definition that applies to your physical location will apply to you under this Policy. Personal Information does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify you.
The types of personal information that we may collect about you include:
  • A. Information You Directly and Voluntarily Provide to Us to Execute the Purchase or Services Contract. We collect your personal information you give us when you use our Services, such as through creation of a customer account or submission of an online form. For example, if you visit our Site or App and use the offered functionalities, such as granting us access to your device’s camera for the scanning of a product, or if you place an order, we collect information that you provide to us during the ordering process. This information may include your first and last name, mailing address, email address, phone number, payment account or credit card information. In some regions, passport information and tax number may also be needed for customer clearance. We may also collect personal information when you communicate with any of our departments such as customer service, or when you complete online forms or surveys provided on the Services. You may also choose to provide your email address to us if you would like to receive information about the products and services that we offer.
  • B. Information You Provide to Us for Personalization. You may voluntarily provide us with your height, age, weight, measurements and your preference. For example, this information may be used by us to recommend clothing sizes or styles, or to provide fit prediction services for you.
  • C. Information You Post on the Site. If you post information on public areas of the Services, for example a customer review that information (including any photos you upload) may be publicly displayed, collected and used by us, other users of the Services, and the public generally. We strongly recommend that you do not post any information through the Site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
  • D. Information You Provide through our Live Chat or Other Customer Service Interactions. You may provide personal information through our Live Chat which is available 24 hours a day. We strongly recommend that you do not post any information through the Live Chat that you are not comfortable sharing with a chat employee.
  • E. Information You Provide to Participate in Promotions. From time to time, we may ask you to complete a survey and/or offer you an opportunity to participate in promotions or programs (such as the SHEIN VIP program) (collectively, “Promotions”) via the Services or through a third-party platform. If you choose to participate in a Promotion, we will collect and store the personal information you provide in connection with your participation in the Promotion, including, but not limited to, your name, email address, and/or phone number. Such information shall be subject to this Policy unless otherwise stated in the official rules or guidelines of the Promotion or in another privacy policy governing the Promotion.
  • Information we collect in connection with a Promotion will be used to administer the Promotion, such as by notifying winners and distributing prizes. As permitted by applicable law, your information may also be used by SHEIN or the Promotion sponsor for marketing purposes. Your entry into the Promotion may result in the addition of your information to our mailing list as well as to the mailing list of our promotional partners, both as permitted by applicable law. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Site or App, such as on a winners’ page.
  • F. Information Automatically Collected Through the Services. We may automatically collect personal information about you when you use the Services. For example, if you access the Site through a computer, we will automatically collect information such as your browser type and version, computer and connection information, Internet Protocol (“IP”) address and standard web log information. If you access the Site or App through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.
  • G. Combination and automated information. We may also combine the information we collect among our services and across your devices and use different technologies to process your information for the purposes described above. For example, we use automated systems that analyze your account status and payment information to detect and prevent unsafe and unsecured payment. We also use automated systems to assess the security of your account and to provide you suggestions to improve the security of your account.
  • H. Information from Third Parties. When you interact with our Services, in particular with our Social Media Accounts, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service, or that may be collected by the social media service provider about your use of the Service.
  • The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms. When you access our Services through social media channels or when you connect our Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Policy.
Please note: When communicating with us by email or through forms on our Services, or when you publicly share content through our Services, we ask that you please do not send us any sensitive information pertaining to yourself or to others . The Company does not collect or store sensitive information or special categories of information.
2. How We Use Your Personal Information
We will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place.
  • A. To Provide You Our Services. We will use your personal information to provide information or perform services that you request, including managing your request as a registered user of our Services. This includes your use of any kind of functionality provided by us through our Services. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. All third parties that we work with are contractually obligated to protect your information as disclosed in this Policy.
  • B. For Internal Use. We use your personal information for the purposes of furthering our business, including improving our Services’ content and functionality by analyzing where, on which types of devices and how our Services are used, how many visitors we receive, and where they click through to the Site or App from. We also use your personal information for accumulating and reporting aggregate, statistical information in connection with the Services, including determining which features and services users like best to help us operate, enhance, and improve our Services.
  • C. To Provide You with Service-Related Communications. We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about Privacy Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
  • D. To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
  • E. To Ensure the Security of the Services. We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
  • F. To Enforce Compliance with Our Terms and Agreements or Policies. When you access or use our Services, you are bound by our applicable Terms and Conditions . To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. Subject to the applicable law, we may also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies and enforce our agreements with third parties and business partners.
  • G. To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
  • H. For Customization. We use your information to save your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); to track your return visits to and use of the Services; to tailor your experience on the Services; and/or otherwise to customize what you see when you visit and use the Services.
  • I. Other Purposes. We may use your information for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.
3. Sharing Your Personal Information
Other than sharing your personal information so that you can use our Services, or as required or permitted by law, we do not share personal information about you with non-affiliated third parties. We may disclose your personal information as described below.
  • A. Within Our Corporate Organization. The Company is a part of a corporate organization that has several legal entities, business processes, management structures and technical systems. We may share your personal information within our organization for business maintenance and personalization continuity purposes, for instance so that you may enjoy a personalized user experience across our digital properties, to provide you with the Services or take actions based on your request.
  • B. Service Providers and Partners. We may share your personal information with group companies or third-party partners and service providers, e.g. acting on our behalf, that help us operate our Services. Service providers and vendors provide us with several kinds of services, including but not limited to support services such as credit card processing, website hosting, email and postal delivery, analytics services, conducting surveys and research, order fulfillment, payment gateways, customer relationship management, and performing network maintenance. These third parties can only use your data for the purposes they were provided to them and to the extent necessary for such purposes, in accordance with our written instructions (where they act as our processors), and must comply with the information security protections we have put in place.
  • C. To Maintain Legal and Regulatory Compliance. We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property or safety of the Company or our customers.
  • D. Third Party Advertisers. In certain circumstances, and subject to the applicable law, we may share your personal information with third parties to market their products or services to you.
  • E. Co-Branded Services and Features. Portions of our Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner's privacy policy. Use of your personal information by a co-branded partner will be subject to a co-branded partner’s privacy policy. If you wish to opt-out of a co-branded partner’s future use of your personal information, you will need to contact the co-branded partner directly.
  • F. Consent. We may disclose your personal information for any purpose with your consent.
  • G. Corporate Transactions. We may disclose personal information—including account information, Wallet balance or points information—to a buyer, prospective buyer, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which personal information held by us about our Services users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.
Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.
4. Cookies and Other Tracking Technologies
We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. These tracking technologies allow our technology partners to collect information including your computer’s IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags, and to analyze usage patterns on our Site. Cookies or tags are bits of code that allow our technology partners to collect information including your computer’s IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags.
If required by law, we will request for your consent before using cookies or other tracking technologies.
  • A. Cookies. Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.
  • Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
  • We use the following types of cookies on our Services:
    • Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
    • Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
    • Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.
    • Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
  • B. Other Tracking Technologies. To see how successfully our marketing campaigns or other goals of the Services are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.
  • C. Analytics. If you are not located in the European Countries, we may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .
  • If you are located in the European Countries, and Google Analytics is structured to collect personal data and you have not activated the Google Analytics Opt-out Browser Add-on, the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. We have implemented Google Analytics with the “AnonymizeIP” function, which makes sure that your IP address will be shortened before it is sent to servers in the U.S. Exceptionally, the shortening may take place after such transfer to the U.S. Google uses this data to evaluate your use of our Services, to compile reports on activities on our online services and to provide us with other services related to Site, App and internet use.
  • D. Behavioral Remarketing. We also use remarketing services to advertise on third-party websites to you after you visited our Site or Services. For this purpose, visitors are grouped by certain actions on our Services, e.g., by duration of a visit. This enables us to understand your preferences and to show you personalized advertising even if you are currently surfing on another website that also participates in the Google advertising network. If you are not located in the European Countries, we and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
  • We use the following tools and services for these purposes:
    • Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: http://www.google.com/settings/ads .
    • If you are located in the European Countries, and Google Ads is structured to collect personal data, the data controller will be Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. For further information on Google please refer to the European Countries paragraph under section 4.D above.
    • Bing Ads is a service operated by Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052, USA, or if you are located in the European Countries, by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Please read Microsoft’s privacy statement for more information on how Microsoft processes your information https://privacy.microsoft.com/en-US/ . When you access our Site via advertisements on Bing Ads, a cookie is set on your computer. In addition, an Universal Event Tracking tag is integrated on our Site. This is a code that, in combination with the cookie, stores data about the use of the Site, e.g. length of time spent on the Site, areas accessed, and ads used to reach the Site. In addition, Microsoft may track your usage patterns across multiple of your electronic devices through so-called cross-device tracking. The information collected is transferred to a Microsoft server in the United States. If you are located in the European Countries, and Bing Ads is structured to collect personal data, the cookie banner on our Services will provide you the opportunity to consent to Bing Ads.
    • Facebook Ads. Using Facebook Business Tools , we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences in addition to the Your Choices section below. We do not share any of your personal information with Facebook. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the “lookalike” audience, unless they choose to click on one of our advertisements.
  • E. Other Tracking Technologies. We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
  • Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
  • F. Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
  • G. Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. See your device settings for more information.
  • H. Your Choices. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Services by taking the steps outlined below.
    • First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org .
    • Third-Party Cookies. If you are not located in the European Countries, to opt-out of third-party advertising networks and similar entities that use advertising cookies, please click the “Manage Cookies” link in our website footer or visit http://www.aboutads.info/choices. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers .
    • For European Countries visitors, you may opt-in to first- and third-party cookies using the cookie banner or consent manager found on our Services. You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the Site footer or within the App menu.
    • Mobile Applications. To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the Digital Advertising Alliance’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices .
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here: Google Chrome , Internet Explorer , Mozilla Firefox , Safari (Desktop) , Safari (Mobile) , Android Browser , Opera (Mobile) .
5. Security Precautions
We maintain physical, electronic, and procedural safeguards designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. We restrict access to your non-public personal information to those employees and third parties who need such information to provide products or Services.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
If you believe that any of your personal information held by us has possibly been compromised, please contact us immediately at privacy center . We ask you to be responsible for safeguarding your password, secret questions and answers and other authentication information you use to access our Services. We also ask you to not use the same password for our Site that you use for other sites and platforms.
6. Your Rights
We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. You have the right to access, correct, or delete the personal information that we collect, subject to certain exceptions. To protect the privacy and the security of your personal information, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. To exercise your rights, you may make updates within your customer account on the Site or App, or you may contact us at privacy center . We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
7. Retention
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
If you send us correspondence, including emails, we retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from us to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records as permitted by law.
We will also retain Services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods.
8. Third-Party Websites
Our Apps or Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.
9. Children
Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16. If you are under 16, please do not attempt to fill out our forms or send any personal information about yourself to us. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information from our files. Please do not upload photographs showing other people, in particular if they are under 16 years old.
10. Notice to Individuals in the European Union
This section only applies to individuals using or accessing our Services while located in the European Union (collectively, the “European Countries” ) at the time of data collection. This section applies in addition to the remainder of the Policy and prevails in case of conflicts.
Pursuant to the EU General Data Protection Regulation ( “GDPR” ), personal information is referred to as personal data. For the sake of clarity references to personal information in this Policy concern personal data in the sense of the GDPR.
We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the European Countries.
  • A. Our Relationship to You. As explained to you in the “Overview” section above, the provider of Services varies depending on your location when accessing and using the Services. Accordingly, the terms “Company”, “we”, “us” or “our” in this section 11. refer to Infinite Styles Ecommerce Co., Ltd., 1-2 Victoria Building, Haddington Road, Dublin 4, Ireland , together with Roadget Business Pte. Ltd., 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore (038987), acting as joint controllers, if you are located in any country of the European Union.
  • Note: The use of the singular form shall include both joint controllers and shall be interchangeably used with the plural form in this Section 11 of the Policy.
  • The Company is operating the Services and the sale of SHEIN brand products, and therefore, is the Controller of your personal data. This means that we are responsible for processing and protecting your personal data.
  • The joint controllers have entered into a joint controller agreement, allocating the essential responsibilities as follows: Roadget Business Pte. Ltd. will be responsible for operating the Site and providing for its security. Infinite Styles Ecommerce Co., Ltd, will be responsible for using the Site in its respective territory to sell products to customers, collecting payment and processing returns.
  • B. Legal Bases for Processing Your Personal Data. We rely on the following legal bases under the GDPR in processing your personal data.
  • Our legal basis to process personal data for the following sections of this Policy is your consent.
    • Section 4 In relation to (mobile) advertising and third-party advertising, analytics and not strictly necessary functional cookies, that collect your personal information, as described in that Section.
    • Section 3(D) to share your personal data with third party advertisers
    • Section 3(F) to share your personal data with other parties with your consent
  • Our legal basis to process personal data for the following sections of this Policy is to provide our Services to you. Our processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.
    • Section 2(A) to provide you our services
    • Section 2(C) to provide you with service-related communications
    • Section 2(D) to provide customer support or respond to you
    • Section 3(A) to share your personal data within our corporate organization (where this is necessary to provide our Services to you)
    • Section 3(B) to share your personal data with service providers and partners (where this is necessary to provide our Services to you)
    • Section 3(E) to share your personal data with co-branded services or features (where this is necessary to provide our Services to you)
  • Our legal basis to process personal data for the following sections of this Policy is our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services.
    • Section 2(B) for internal use, this may include but is not limited to situations pursuant to
      • Section 3(A) to share your personal data within our corporate organization (to the extent this is not necessary to provide our Services to you)
      • Section 3(B) to share your personal data with service providers (to the extent this is not necessary to provide our Services to you)
    • Section 2(F) to enforce compliance with our terms and agreements or policies
    • Section 2(E) to ensure the security of the Services
  • Our legal basis to process personal data for the following sections of this Policy is to comply with our legal obligations, or your vital interests.
    • Section 2(G) to maintain legal and regulatory compliance
    • Section 3(C) to maintain legal and regulatory compliance
  • C. Social Media Accounts. We operate accounts and fan pages on different social media platforms (the “Social Media Accounts” ).
  • If you visit one of our Social Media Accounts you initiate a variety of data processing operations. Below we give you an overview of which of your personal data we collect, use and store when you visit one of our Social Media Accounts. If you do not provide us with your personal data, certain functionalities of the social networking platforms requiring such data will not be available to you or only to a limited extent.
  • As the owner of a Social Media Account, we can usually only see information stored in your public profile on such social media platform, and only insofar as you are logged in to your profile while visiting our Social Media Account. In addition, we may process data that you provide to us when you contact us through one of our Social Media Accounts (for example: if you create a post, or send us a private message via Facebook). If you visit one of our Social Media Accounts, the operator of the respective social network also processes your data, regardless of whether you yourself have a profile in the respective social network. The individual data processing operations and their scope differ depending on the operator.
  • In addition, the respective operator of the social network provides us with anonymous usage statistics, which we use to improve the user experience. We do not have access to the usage data that the operator of the social network collects to create these statistics. Facebook, for example, has committed to us to assume primary responsibility under the GDPR for the processing of this data, to comply with all obligations under the GDPR in this regard, and to provide visitors to our profile with the essence of this commitment. These data processing operations serve our legitimate interest in improving the user experience when visiting our profile in line with the target group. In addition, some operators of social networks (e.g. Facebook) use cookies that are stored on your terminal device when you visit our Social Media Account, even if you do not have your own profile in the network or are not logged in These cookies enable the respective operator to create user profiles based on your preferences and interests and to show you advertising tailored to these (within and outside of the respective social network).
  • For details about the collection and storage of your data as well as the type, scope and purpose of their use by the operator of the social network, please refer to the privacy policy of the respective operator:
  • D. Marketing. If you are located in the European Countries, we will only contact you by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or your consent. If you do not want us to use your personal data in this way, please click the unsubscribe link at the bottom of any of our email messages to you or contact us at privacy center . You can object to direct marketing and withdraw your consent at any time with future effect and free of charge.
  • E. Individual Rights. We provide you with the rights described below when you use our Services. We may limit your individual rights requests where denial of access is required or authorized by law, e.g. (a) when granting access would have a negative impact on other’s privacy; (b) to protect our rights and properties; or (c) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable law, please contact us at privacy center .
    • Access; Deletion: You can request access or deletion of your personal data, subject to certain exceptions. Deletion may result in the deletion of your account, including all related information and benefits.
    • Rectification; Objection; Restriction; Data Portability: You can correct or update your personal data, object to processing of your personal data, ask us to restrict processing your personal data or request portability of your personal data.
    • Withdrawal of Consent: If we collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
    • Complaint: You have the right to complain to the competent data protection authority about our collection and use of your personal data. You can find list of local authorities responsible for data protection across the EU and their contact details at: https://edpb.europa.eu/about-edpb/board/members_en . The United Kingdom Information Commissioner’s Office may be reached at https://ico.org.uk/global/privacy-notice/how-you-can-contact-us/ , and the Swiss supervisory authority may be reached at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html .
  • If you believe we have infringed or violated your privacy rights, please contact us at privacy center so that we may resolve your dispute directly.
  • F. Transfer of Your Personal Data. When you access or use our Services, your personal data may be processed or transferred outside the European Union, including to the United States, China and/or Singapore . Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. For these transfers we rely on appropriate safeguards as permitted under the GDPR such as Standard Contractual Clauses, and/or we transfer the personal information pursuant to Article 49 (1) (b) of the GDPR to provide our Services pursuant to the Terms & Conditions. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services. For further details about these transfers and the safeguards that we use to facilitate such transfers, contact us at privacy center .
  • G. Opt-In to Use of Cookies and Other Tracking Technologies. We will not use cookies or similar tracking technologies that process your personal data, unless they are Strictly Necessary Cookies pursuant to Section 4 (A) above, or you opt-in, i.e. consent, by using the cookie banner or consent manager found on our Site. You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the website footer.
  • H. Recipients. We share your data as described in this Policy with the following recipients and categories of recipients:
    • Hosting providers (e.g. Amazon Web Services)
    • Customer relations services providers (e.g. Zendesk, Inc.)
    • Social network providers (e.g. Google, Facebook Inc./Facebook Ireland Limited)
    • Newsletter service providers (e.g. Emarsys Limited, Splio Asia Limited, Aceville Pte Limited, Bothub AI Limited)
    • Payment service providers (e.g. PayPal Inc., Worldpay Ltd., CKO Technology Services Ltd, Adyen N.V.)
    • Cookie consent management service provider OneTrust LLC
    • Solvency check services providers (CyberSource Corporation)
    • Delivery services providers (e.g. Hermes Parcelnet Limited)
11. Communications Preferences
In order to provide services to you, we may send you communications related to your transactions, security, or the administration of this Site. From time to time, we may also send you other messages or updates about our Company, our Services, and our other products and offerings. If you do not wish to receive non-transaction or security-related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us at privacy center . Please note that if you opt out of receiving communications from us, we may still send you service communications such as emails about your account.
Please note as well that "opt-out" and "unsubscribe" requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings.
By downloading and using our mobile applications, you may receive messages, reminders, offers, news, and information from us within the mobile application itself. These “in app” messages are part of our mobile application’s functionality but can be adjusted using your device or app settings.
12. Contact Us
If you have questions or concerns regarding any information in this Privacy Policy, please contact us by email at privacy center . You can also contact us via our customer service Platform on our Site.