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Cookie Policy

In common with other websites we use cookies to ensure that you get the most out of our website: (“Site”), and to improve the service we offer. A cookie is a text file containing small amounts of information which is downloaded to your device when you access a website. The text file is then sent back to the server each time your browser requests a page from the server. This enables the web server to identify and track the web browser you are using.


1. Strictly necessary cookies. These are cookies that are required for the administration and operation of our Site. Some cookies that we use are necessary for our Site to function properly and to enable you to move around the Site and use its features. They include, for example, cookies that enable you to log into secure areas of our Site].

2. Analytical/performance cookies. We may also use an analytics service provider (including Google Analytics) for website traffic analysis and reporting. Analytics service providers generate statistical and other information about the use of the Site by using cookies, which are stored on users’ computers. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. The information generated relating to the Site may be used to create reports about the use of the Site and the analytics service provider will also store this information].

3. Functionality cookies. In addition, we may also use functional cookies that allow our Site to remember choices you have made in relation to the Site to provide a more personalised by remembering your preferences (for example, remembering your password) and enhanced user experience by delivering content specific to your interests].

4. Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site more relevant to your interests. We may also share this information with third parties for this purpose].

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Except for essential cookies, all cookies will expire after 2 years.

If you do not wish us to install cookies on your computer for these purposes, you may change the settings on your internet browser to reject cookies. For more information please consult the “Help” section of your browser. Please note that if you do set your browser to reject cookies, you may not be able to use all the features of our Site. To indicate your acceptance of our use of cookies in accordance with this Cookie Policy you can click accept in the appropriate place on the banner that appears on our Site. However, please note that if you do not click accept but you continue to browse the Site you will be deemed to have accepted our use of cookies in accordance with this Cookie Policy.

Privacy Policy

Cleverly Group Limited (us or we) is the “data controller” in respect of any personal data that you submit to us or that we collect from you when you use our website (Site). This privacy policy sets out the basis on which we will process any personal data that we collect from you or that you provide to us when you use our Site.

Please read the following privacy policy carefully to understand how we use and protect the personal information that you provide to us.


1.1 We are a company registered in England with registered company no. 10009054 with registered offices at Fleming Court Leigh Road, Eastleigh, Southampton, Hampshire, United Kingdom, SO50 9PD.

1.2 If you have any other queries or complaints in relation to this privacy policy, or our Site, our contact details are as follows:


2.1 We will collect any information that you provide to us when you contact us via phone, email, or through our Site. This information may include your name, email address, password, billing and delivery addresses, payment information and phone number, which will be used for providing the services to you, processing any order you place with us, contacting you with further information about our services or improving the Site, and any such feedback may be introduced in any of Cleverly Group Limited’s Site(s).

2.2 We will collect any information contained in any correspondence between you and us. For example, if you contact us, we may keep a record of that correspondence. We may also ask you for information when you report a problem with our Site.

2.3 We may collect certain information about your visits to our Site and how you use it. This may include your geographical location, IP address, device information, browser type, referral source, length of visit and number of page views, operating system, which products you have viewed or searched for on our site, what purchases you have made and similar information. We may use this information for several purposes including Site administration, optimising the use and performance of the Site, disclosing to third party contributors or for security purposes. Individual users will not be identifiable from this information. This information may be collected by a third-party Site analytics service provider on our behalf and may be collected using cookies. For more information on our use of cookies please refer to our Cookie Policy.

2.4 We may collect information about you from third parties that we work closely with for the purposes of delivering to you the services that you request from us. We may also engage third parties to operate websites on our behalf; these entities may collect information directly from you about your visits to the site on our behalf.

2.5 We may also receive information about you from third parties for specific purposes. For example, we might receive information about you from third parties if you have indicated to that third party that you would like to hear from us, with more information about our products and other services.


3.1 We will only use the personal information that we collect from you in accordance with this privacy policy.

3.2 In addition to the specific uses set out in section 3 above, we may use your information for the following purposes:

3.2.1 to ensure that content from our Site is presented in the most effective manner;

3.2.2 to send you general (non-marketing) commercial communications, such as information about the Site and services provided to you by us at that time;

3.2.3 to provide customer service in relation to your use of the Site, to contact you, to deal with enquiries and complaints relating to the use of the Site and to notify you about changes to our services;

3.2.4 to develop, improve the Site to improve your browsing and viewing experience;

3.2.5 to provide third parties with statistical information about our users but this information will not be able to be used to identify any individual user;

3.2.6 to provide you with marketing communications by electronic means (such as email, SMS and/or MMS) about our products, services, events; and

3.2.7 to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees, and for security purposes.


4.1 We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

4.1.1 Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by notifying us in writing or clicking on the “unsubscribe” link at the bottom of any marketing emails we send you.

4.1.2 Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.

4.1.3 Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product/services from us and we need to use your contact details and payment information in order to process your order.

4.1.4 Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.


5.1 We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

5.2 Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.


6.1 Other than as expressly set out in this privacy policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent.

6.2 We may disclose your personal information to our suppliers, business partners and service providers, where they are helping us to market and advertise our services as well as providing our services to you.

6.3 We may disclosure your personal information to other third parties in the following cases:

6.3.1 for the purpose of research, evaluation and analysis;

6.3.2 for marketing purposes, so that they can provide you with marketing communications by post and/or electronic means (such as email, SMS and/or MMS) about their own products, services, events, special discounts and offers, which you have requested to be sent, or which may be of interest to you where you have expressly consented to be contacted for such purposes;

6.3.3 to any affiliate or third party to whom disclosure is necessary to enable us to provide you with any services or products that you have requested through the site which may be provided by such affiliates or third parties such as Ruby Has Fullfilment, 5 Inez Drive, Bayshore, NY, 11706;

6.3.4 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

6.3.5 if we or substantially all our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

6.3.6 if we are under a duty to disclosure or share your personal information in order to comply with any legal or regulatory obligation or request; and

6.3.7 to protect the rights, property or safety of us or our employees or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).


7.1 Our Site may, from time to time, contain content and links to other websites and microsites that are operated by third parties. In addition, advertisements contained on our Site may operate as links to that advertiser’s website, and such advertisers and third parties may also use and place cookies on your computer.

7.2 We do not control these third-party websites, advertisements and cookies and this privacy policy does not apply to them. Any information such third parties collect by you clicking on a third-party link on our Site will be collected and used in accordance with the privacy policy of that third party. Please therefore consult the terms and conditions and privacy policy of those third-party websites and microsites to find out how they collect and use your personal data and to establish whether and for what purpose they use cookies.


8.1 We employ appropriate technological and operational security measures to protect against any unauthorised access to or any unlawful processing of any personal information about you that we hold. We will retain your information for as long as necessary to provide any services to you or for a reasonable period or as long as the law otherwise permits.

8.2 Data transmission over the internet is inherently insecure, and although we employ appropriate technological and organisational security measures to protect your data from unauthorised access we cannot guarantee the security of any data sent over the internet.


9.1 Our main office is in Australia, your information may be processed in United Kingdom and other locations globally, including the USA where it may be subject to access requests from governments, courts or law enforcement in the United States. Therefore, data that we collect from you may be transferred to, and stored in a destination outside the EEA or the UK, including some countries which have less strict or no data protection laws, when compared to those in the EEA or the UK.

9.2 Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.


10.1 You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

10.2 We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemption. If you would like to exercise any of these rights, please contact us using the contact information provided in section 1 above.

10.3 You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have any such concerns we request that you initially contact use using the contact details in section 1 above) so that we can investigate, and hopefully resolve, your concerns.


11.1 We reserve the right to make changes to this privacy policy from time to time. Any such changes to our privacy policy will be posted to our Site and if we consider it to be appropriate we will notify you of any material changes by e-mail.

This privacy policy was last updated in April 2022.

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