Privacy and Cookies Policy

INTRODUCTION

Effective Date: 25 October 2024

This Privacy Policy describes the information we collect about you when you interact with us in our stores, our events (such as pop-ups), through customer service, our member/loyalty program, our mobile app (where available) or our corporate website (gabbia.co.za) (collectively our “Platforms”).

By submitting information through, or otherwise using, our Platforms, you acknowledge that we may collect, use and disclose information in accordance with this Privacy Policy, the privacy preferences you have made known to us, and as permitted or required by law. As used in this Privacy Policy, “GABBIA”, “our”, “us”, and “we” means Good Street Pty. Ltd., a company headquartered in the SOUTH AFRICA, (unless a different legal entity is applicable to your location as described in the "SUPPLEMENTAL NOTICES" section below).

YOUR PERSONAL INFORMATION

How We Collect, Use, and Share Your Personal Information

We collect data when you interact with us at different touchpoints, including information that can directly or indirectly identify you (your “Personal Information”). As a consumer goods company, we use Personal Information for a variety of business purposes including sharing it and combining it with other information we might receive from our wholesale partners, technologies, and other third parties. This section details the kinds of information we collect, how we use it, and describes the third parties with whom we share information. See "OTHER SUPPLEMENTAL NOTICES" below for additional information that may apply to you based on your location.

CONTACT INFORMATION:

This includes identifying information like names, email addresses, phone numbers, shipping/billing/physical addresses, online identifiers you share in a public forum (like your social media handles), or nicknames.

How we collect this information:

Directly from you when you register an account, join a member (loyalty) program (where available), sign up for emails, sign up for or attend an event, order products from us online or purchase products in-store
From third parties including our franchisees or others that manage locations or product fulfillment or marketing list providers (where permitted under applicable laws)

Why we collect it:

To contact you, for example to send you relationship, transactional and commercial communications and other marketing and advertising (subject to choices you may make to opt in or opt out)
To administer sweepstakes, surveys, or contests

We share it with:

Third party social media platforms (including for advertising through platforms such as Meta or Amazon using pixels or custom audiences) (subject to choices you may make to opt in or opt out)
Marketing and advertising providers

FINANCIAL INFORMATION:

We do not collect any financial information from you, instead a 3rd part payment gateway is used to complete purchases. For more information regarding the policies of the payment gateway(Paystack) please visit their terms webpage: paystack.com/terms

OTHER IDENTIFYING INFORMATION

This includes information that might reasonably be used to identify you, either by itself or when combined with other data such as general or specific demographic data, physical description such as your preferred clothing sizes, information you share in a public open forum including social media, or other information we collect from you after obtaining your prior consent.

How we collect this information:

Directly from you when you create an account online or join our member (loyalty) program (where available), use an offered mobile app, or through our in-store experience/purchases
As described in a separate notice or consent, such as a pop up notice for a special feature in our mobile app or sign-up terms for a special event
From third parties including social media platforms, business partners and advertising service providers

Why we collect it:

To offer and administer special offers, contests, surveys, and sweepstakes
To send you relationship, transactional and commercial communications and other marketing and advertising (subject to choices you may make to opt in or opt out)

We share it with:

Marketing and Advertising providers
Customer Service providers

INFORMATION FROM OUR BUSINESS RELATIONSHIP:

This includes information you share on our website, in our apps, with Customer Service, in-store stylists, or other representatives, including purchase and return data, survey responses, customization services, feedback, communications or information you share in a public forum like social media, choices you make with respect to communications we send to you or how we use your data (e.g., to opt in or opt out), account or member (loyalty) program information including credentials or information you populate in your account, size, fit and product preferences, exchanges with our AI powered chatbot, the stores you visit and associated inferred data such as buying trends and preferences.

How we collect this information:

Directly from you
From third parties including social media platforms, business partners and advertising service providers

Why we collect it:

To administer, support, and improve our online and in-store presence and experience
To help us understand your interests, personalize our interactions with you, and develop our business relationship
To offer and administer special offers, contests, surveys, and sweepstakes
To send you relationship, transactional, and commercial communications, and other marketing and advertising (subject to choices you may make to opt in or opt out)

We share it with:

Marketing and Advertising providers

AUDIO, VISUAL, SENSORY, AND BIOMETRIC INFORMATION

This includes data such as audio recordings, visual film or still images, physical and behavioral characteristics, or patterns. In some locations, biometric information is considered sensitive Personal Information and subject to additional protection.

How we collect this information:

Directly from you if you make a telephone call to our customer service number that is recorded, if you publicly post images or audio/video where you post and tag us or our brands, if you choose to interact with optional features on our platforms such as taking and submitting a selfie or body scan for digital fit assessments or virtual try-on, or if you use voice-command features
By CCTV cameras in our locations
As described in a separate notice or consent, such as a pop up notice for a special feature in our mobile app or sign-up terms for a special event

ONLINE AND TECHNICAL INFORMATION:

This includes browsing data, data about how you interact with our Platforms and tools (including online ads, text messages and emails) and similar network activity, your IP address, and device identifiers (for example, advertising ID’s, device model, operating system, device locale, mobile platform, session time, developer ID and the like) and reproductions and recordings of interactions with the website captured during browsing sessions.

How we collect this information:

From your computer or device when you interact with our Platforms, for example, when you visit our website our server logs record your IP address and collect information on how you navigate through the site

Through cookies, web beacons, pixels, clear gifs, and similar tracking technologies (where you have opted in, if required by applicable law, unless collection is via strictly necessary cookies)

From actions you take in response to marketing emails, including whether you open an email, unsubscribe or purchase a product promoted in that email

From third parties including collaboration partners helping to develop new solutions like virtual try on

Why we collect it:

To make your interaction with us more convenient, for example, recognizing you and your devices, or allowing us to hold your shopping cart selections when you navigate away and then return to the order page

To send you relationship, transactional and commercial communications and other marketing and advertising including through behavioral advertising and cross-device tracking. Cross-device tracking refers to when data is used to make the inference that a user of one device, such as a computer, is the same person using another device, such as a mobile phone. We may then serve advertising on the browsers of both devices. These uses are subject to choices you make to opt in or opt out.

We share it with:

Marketing and Advertising providers

GEOLOCATION DATA

This includes data such as GPS latitude and longitude (where you have agreed to it) such as by using a mobile app where you opted in to location sharing, or through using a mapping service such as Google Maps to find a store location, approximate location (such as your zip code/postal code or state/province/territory) and, in some cases, store locations you have visited.

How we collect this information:

Directly from you
Through technologies, such as an IP address
As described in a separate notice or consent, such as a pop up notice for a special feature in our mobile app or sign-up terms for a special event

Why we collect it:

To enable you to locate nearby stores
To send you relationship, transactional and commercial communications and other marketing and advertising (subject to choices you may make to opt in or opt out)

We share it with:

Marketing and Advertising providers

Note: The Google Maps service is governed by the Google privacy policy located at www.google.com/policies/privacy.

INFERRED AND DERIVED INFORMATION

This includes profiles based on buying trends, transaction patterns and preferences, characteristics, predispositions, behavior or attitudes.

How we collect this information:

Directly from you
Through technologies, such as an IP address
Creating summaries, profiles and segments using information collected from a variety of sources that are described in this Privacy Policy
From third parties including business partners and advertising service providers

Why we collect it:

To send you relationship, transactional and commercial communications, for special offers and other marketing and advertising (subject to choices you may make to opt in or opt out) including through interest-based advertising and using cross-device tracking

We share it with:

Marketing and Advertising providers
Social Media platforms

CHILDREN AND MINORS’ INFORMATION

We do not knowingly collect Personal Information of any user under 13 years of age on our Platforms. These offerings are intended for users who are 13 years old or older. If a user or their parent or legal guardian believes we have collected any Personal Information of a minor (under the age of 18), please contact us at [email protected] for removal of that data.

BUSINESS PURPOSE AND SHARING FOR ALL DATA TYPES

In addition to the above, we may use any or all of the Personal Information described in this Privacy Policy for the following business purposes. Additionally, our business operations require that we share Personal Information with certain categories of third parties as are identified below.

We may use or share the Personal Information that we collect to:

Maintain the safety, security, functionality, and integrity of our Platforms and other assets or business
Prevent investigate, or take action regarding unlawful activity including but not limited to engaging third parties to screen transactions for suspected fraud or identity theft
Perform testing, research, analytics, and product development
Administer, support, and improve our online presence, whether on our website or mobile app, including troubleshooting technical problems when they arise
Understand, improve, and provide customized and streamlined experiences with our Platforms, including by offering member (loyalty) program, personalized recommendations, fit suggestions, and the like
Provide services in-store, on the website or mobile app, including processing requested purchases, returns and exchanges, payments, orders, shipping products, and providing Customer Service
Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other 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 is among the assets transferred
Conduct other business initiatives as described to you when collecting your Personal Information, with your consent or as otherwise permitted by law
Comply with law or a legally binding process, such as pursuant to subpoenas, court orders, to enforce our legal rights, or to protect you, us, or others against injury or harm including for security and loss prevention
To administer surveys and questionnaires, such as for consumer satisfaction purposes

We share your Personal Information with:

Service Providers, including operations outsourcing, such as for unique services or points of presence in a country, cloud service and technology providers, credit card processing, marketing and advertising, shipping and logistics, dispute resolution, fraud detection and prevention providers, data management, analytics providers and other third parties with whom we have contractual relationships,
Auditors, consultants, lawyers, and other entities who use the data to provide us with professional services,
Government agencies, law enforcement, regulators, and courts where we are required to comply with applicable laws, regulations or rules, requests of law enforcement, regulators and other government agencies or a legally binding process, such as pursuant to subpoenas, court orders, to enforce our legal rights, or to protect you, us, or others against injury or harm
Business Transfers, if (i) we or our Affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer Personal Information to a potential or actual third party purchaser or other relevant third party.

We may also anonymize, aggregate or otherwise strip any Personal Information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purpose we deem appropriate.

YOUR CHOICES

We believe in giving you choices about how your Personal Information is used. Below are some ways that you may exercise these choices, including how to change or correct your Personal Information and how to unsubscribe from marketing.

We encourage you to review this entire Privacy Policy to fully understand the choices you may have, such as allowing or blocking cookies, online behavioral tracking and advertising, asking for your Personal Information to be deleted, or asking what Personal Information we have collected from you. See "OTHER SUPPLEMENTAL NOTICES" for additional information that may apply to you based on your location.

When you set up an account, sign in or log in on one of our Platforms, you can access, correct, or update your choices and settings. If you receive email marketing communications from us on behalf of any of our brands and want to opt out of receiving such communications in the future from that brand, you can opt out by clicking the “Unsubscribe” link at the bottom of the promotional email. Similarly, if you receive direct mail from us and wish to unsubscribe, you can opt out by e-mailing us at [email protected] Please be sure to include your full name, mailing address and e-mail address along with the types of information you do not want to receive. It may take up to 8 weeks to process an opt-out from direct mail.

Some services will allow you to accept or reject use of geolocation technologies but, if you don’t accept, you may not be able to enjoy certain features on our Platforms (such as the full “find a store” option). Unless otherwise explained to you in advance, you are not obligated to provide your Personal Information to us. If you decide not to provide your Personal Information, we might, in some instances, not be able to provide you with a product or service. Additionally, if you have opted out of certain services, such as marketing communications, you may still hear from us for other purposes such as needed to fulfill your orders or responding to customer service inquiries.

SECURITY

Safeguarding Your Personal Information

We care about protecting your Personal Information, so we employ reasonable physical, technical, and administrative safeguards designed to help keep it safe, including encryption and in some cases techniques to reduce the ability to identify an individual. Personal Information may be accessed by persons within our organization, our third party service providers, or the other persons described in this Privacy Policy who require such access to carry out the purposes described in this Privacy Policy or that are otherwise permitted or required by applicable law.

No data collection, storage, or transmission, including over the Internet or other network can be guaranteed to be 100% secure, so despite our efforts we cannot and do not guarantee the security of any data you transmit to us, including on, or through, our Platforms. When you communicate with customer service via email or chat, we ask that you not share sensitive Personal Information via these communication channels. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

When you register on one of our Platforms, you will need to set up a password to access your information on our site. If you want to cancel your password or change it, click on “Log In” from any page on the website, and you can access, correct, or update your choices and settings from within your account. Note that we don’t ask customers to confirm account or credit card details by email – if you receive an email claiming to be from us and asking for this information, don’t respond.

We store your Personal Information on the basis of applicable law and as required to satisfy the purpose for which the data is processed, unless a longer period is required for purposes such as complying with retention obligations, record keeping or other commercial requirements.

COOKIES, TRACKING AND ADVERTISING

Cookies, Tracking Technologies and Interest-Based Advertising

ABOUT COOKIES:

We may place, or allow to be placed, cookies, web beacons and similar technologies on our Platforms to give you the best experience, perform analytics, analyze traffic, personalize content, offer a range of features and functionality and offer ads that match your interest (as discussed above). These technologies include Google Analytics and similar providers. You can learn more about how Google uses the information collected through this service at: www.google.com/policies/privacy/partners/

Cookies and web beacons are the technologies generally driving collection of browsing information. A "cookie" is a computer file that acts as an identification card for your computer. When you visit a site, unique cookies are placed on your browser. The purpose of the cookie is to distinguish your browser, and associated activities, from all other browsers. “Web beacons” interact with cookies to “read” the information contained on them. When you visit a site, web beacons recognize specific cookies that have been placed on your browser. By recognizing your browser, the site owner can serve you better. While we may recognize your browser through cookies we place, that does not mean that we can identify you by reference to your name, email or other specifically identifiable Personal Information.

We and our partners use cookies, web beacons, device identifiers and other technologies to collect information when you use our websites and mobile app such as your IP address, web browser, mobile network information, browsing and conversion information help to create an improved shopping experience – for example, allowing us to hold your shopping cart selections when you navigate away and then return to the order page, or save an item for later when you’re not quite ready to buy. Cookies also allow us to recognize you as an account holder when you return to our sites. We consider these types of cookies to be necessary for the successful operation of our business. Our use of cookies changes regularly depending on our business needs and operations.

Most browsers accept cookies automatically, but you can block or delete cookies at any time to prevent the collection of your browsing information for purposes of delivering interest-based ads and tracking visitor behavior. Please be aware that blocking or deleting cookies may also disable or interfere with shopping features on our sites and other sites that you may visit.

BEHAVIORAL OR INTEREST BASED ADVERTISING:

We permit our trusted business partners and third party advertising companies (including ad servers, ad agencies, technology vendors, or providers of sponsored content) to collect your browsing information and numerical identifiers associated with your browser or device in order to provide ads on our behalf that are tailored to your interests. These ads may appear on our website, and on other third party websites. Using tracking technologies, advertising technology companies collect data from a particular browser or device about a user’s web viewing behaviors over time, across unrelated websites, and in some cases combine such data with data collected from other browsers or devices associated with the same user or household, and use such data to predict user preferences and to deliver advertisements to that user which are calculated to target that user’s predicted preferences across devices. If you take steps to block advertising cookies or opt out of interest-based advertising, note that this does not mean that you will no longer receive ads from GABBIA, as these ads are only one form of digital advertising.

DO NOT TRACK:

Our systems do not recognize browser “Do Not Track” signals, but several of the third party advertising companies that utilize cookies on our websites to provide interest-based advertising enable you to opt out of those practices.

OPTING IN/OPTING OUT/BLOCKING COOKIES:

You can block or opt out of cookies or collection of data for interest-based advertising by adjusting settings within your browser. For instructions, check your browser’s technical information. If you are using a mobile device, your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. If you block cookies at a browser level or use a different computer or browser to access our platforms, you should review your cookie settings again.

The placement of cookies, pixels, gifs or web beacons may be subject to additional requirements by law depending on where you are located. These may include requiring us to share specific technical information, requiring you to opt in to their use, or supporting specific mechanisms for you to opt out. Additional specific information relevant to your location, where applicable, can be found in our SUPPLEMENTAL NOTICES.

THIRD PARTY LINKS & FEATURES

Social Media and Third Party Links

Social media provides tools that many of our consumers use and enjoy, and we include links to various social media platforms as part of our digital offerings. For your convenience and information, we may provide links to other sites, or add on features powered by third parties to our website or app, which may have privacy policies that differ from our own. We identify features and links that are provided by third parties, but are not responsible for the content or practices of any linked site. We recommend that you review the privacy policy of any site or feature that you access through our platforms before sharing your Personal Information and understand your privacy settings which will determine the degree to which your Personal Information is used, shared, or made public.

SUPPLEMENTAL NOTICES

Additional data protection and privacy terms may be applicable depending on your location. These terms (our “Supplemental Notices”) are incorporated into, and should be read in conjunction with, this Privacy Policy by reference based on the applicable jurisdiction. They are updated from time to time to meet specific legal requirements and we encourage you to check the Supplemental Notices page for a description of practices and your privacy rights if you are doing business with us in one of these locations. Unless otherwise indicated, the Supplemental Notices have the same effective date as the GABBIA Privacy Notice.

CONTACT US

If you have any questions, complaints or concerns about the Good Street Pty. Ltd. Privacy Policy or our data protection practices, or if you wish to exercise your data subject rights, please send an email to [email protected], call us at +27665904185

NOTICE FOR INDIVIDUALS IN SOUTH AFRICA

If your Personal Information is subject to South African laws, the following clarifications shall apply. In the event of a conflict between the other sections of this Policy and this Supplemental Notice for South Africa, the provisions of this Supplemental Notice will apply to the extent of such inconsistency or conflict.

This Notice applies to the processing of Personal Information entered into a record by a data controller within the Republic of South Africa. For purposes of this Supplemental Notice and where the processing of Personal Information is subject to South African laws, references to the following terms, shall have the corresponding meaning as applicable in the Protection of Personal Information Act, 2013, as amended or replaced from time to time ("POPIA"):

"data controller" shall include a "responsible party" as defined in POPIA;

"data subject" shall include a "data subject" as defined in POPIA, which shall include living natural persons and existing juristic persons;

"data processor" shall include an "operator" as defined in POPIA;

“Information Regulator” shall mean the data protection supervisory authority in South Africa, as established under POPIA;

"personal information" shall be as defined in POPIA, which shall include personal information in relation to living natural persons and existing juristic persons;

"process" or "processing" shall be as defined in POPIA; and

"sensitive data" shall include "special personal information" and personal information relating to children as defined in POPIA.

CONTROLLER RESPONSIBLE FOR PROCESSING PERSONAL INFORMATION

The local entity acting as “data controller” for Personal Information collected in South Africa is Good Street Pty. Ltd., which has its registered address at Illovo Point, 4, 68 Melville Rd, Illovo, Sandton, 2196 .

When we refer to “GABBIA” or “we” in this Supplemental Notice, we refer such GABBIA entity acting as “data controller” for your Personal Information.

RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with the South African Information Regulator. You may contact the office at: [email protected] and at +27 (0) 10 023 5200 or 33 Hoofd Street Forum III, 3rd Floor Braampark, South Africa, Braamfontein, Johannesburg.

PURPOSE(S) AND LEGAL BASIS FOR PROCESSING

Our collection, use, disclosure and other processing of personal information is necessary for the following legal bases:

where applicable, with your consent in respect of the processing of your Personal Information, (for example, where we are required to obtain your prior consent in order to send you direct marketing communications by electronic means);
performance of the contract between us to provide you with products and services including sending you transactional communications, verifying your identity, assisting you in-store, on the sites, processing payments, returns, exchanges, orders, shipping products, and providing customer service;
for purposes we consider to be necessary for pursuing our legitimate interests or the legitimate interests of third parties to whom we disclose your personal Information to including improving the functionality and integrity of our platforms and stores, keeping consumers up to date with information about our products and services, completing corporate transactions, understanding consumer preferences, personalizing our interactions and developing our business relationship, as these functions help sustain and grow our business;
to protect your legitimate interests (e.g. where we use the Personal Information provided to us to give effect to your benefit);
to comply with a legal obligation to which we may be subject, such as complying with orders from government or other legal authorities, detecting and preventing illegal conduct, abuse, spam, fraud (e.g. account takeovers or payment related fraud), security incidents and other harmful activities.

Before collecting and/or using any Special Personal Information (including photographs and video images) or Personal Information relating to children, we will establish a lawful justification to use that information. This justification will typically be:

your consent or the consent of a competent person in relation to a child, if applicable;
the establishment, exercise or defence by us of a right or obligation in law, or to comply with an international public law obligation;
for historical, statistical or research purposes to the extent that: (i) the purpose serves a public interest and the processing is necessary for the purpose concerned; or (ii) it appears to be impossible or would involve a disproportionate effort to ask for your consent, and sufficient guarantees are provided to ensure that the processing does not adversely affect your privacy to a disproportionate extent;
you have deliberately made the personal information public; or
a context specific exemption provided for under South African local laws in relation to the processing of Special Personal Information or information relating to children, such as to identify you when it is essential for that purpose and to comply with laws and other measures designed to protect or advance persons, or categories of persons, disadvantaged by unfair discrimination.

Transfers and processing

Please be aware that your Personal Information may be transferred to and maintained on servers or databases located outside of South Africa, including to countries and organizations which have not been determined by the South African Information Regulator to have an adequate level of data protection as provided for under POPIA.

When we do transfer your Personal Information, we use a variety of legal mechanisms to help ensure your rights and protections travel with your data:

we ensure transfers within the GABBIA entities are covered by agreements based on the EU Commission's standard contractual clauses as amended for compliance with South African local laws, which contractually oblige each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it resides within the GABBIA entities;
where we transfer your Personal Information outside GABBIA entities or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your Personal Information based on the standard contractual clauses as amended for compliance with South African local laws; and
where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

In addition, if we transfer any Special Personal Information or Personal Information relating to children to third parties including other GABBIA entities in countries that do not have adequate data protection laws with data protection principles similar to POPIA, we shall do so only with the requisite prior authorization of the Information Regulator, in circumstances where required.

DIRECT MARKETING

We will use your Personal Information to send you direct marketing about other products and services that we feel may be of interest to you. We will give you the opportunity to consent to the receipt of direct marketing by unsolicited electronic communications at the point that you apply or register to receive the products and services. Should you already be considered our existing customer who receives direct marketing by unsolicited electronic communications from us in relation to the same or similar products and services, we will give you the opportunity to opt out of receiving direct marketing by unsolicited electronic communications on each occasion thereafter that you receive direct marketing communications from us. You can also change your marketing preferences at any stage by contacting us.

YOUR DATA SUBJECT RIGHTS

You may have the following rights with respect to your Personal Information under applicable laws:

Access to and information on the processing of your Personal Information. We may and where applicable, must, refuse access to information in terms of the grounds for refusal of access to records set out in the applicable laws, including the Promotion of Access to Information Act, 2000;
Correction of your Personal Information where it is inaccurate, irrelevant, excessive, incomplete, misleading or out of date;
Deletion or destruction of your Personal Information where it is inaccurate, irrelevant, excessive, incomplete, misleading or unlawfully obtained; and
Objection to processing of Personal Information but only where the justification for that processing is that it is necessary for pursuing our legitimate interests or that of a third party to whom it is disclosed, or is for the protection of your legitimate interests, or where the processing is in the context of the processing of Personal Information for the purposes of direct marketing other than by unsolicited electronic communications. If you raise an objection, such objection should be based on reasonable grounds relating to your particular situation, unless legislation provides for such processing.

CHILDREN AND MINORS

Our Sites offered in the Republic of South Africa are not intended to address anyone under the age of 18 (“Children”). We do not knowingly collect personal information from Children. If you are a parent or guardian and you are aware that your child has provided us with personal information without your consent, please contact us using information in the “CONTACT US” section and we will take steps to remove that information.