(A) This Notice
Summary - This Notice.
This Notice explains how we Process Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.
This Notice is issued by each of the Controller entities listed in Section (R) below (together, “Oasis”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (S) below.
This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.
(B) Collection of Personal Data
Summary – Collection of Personal Data
We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, products, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:
(C) Creation of Personal Data
Summary – Creation of Personal Data
We create Personal Data about you (e.g., records of your interactions with us).
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, products, or services, including where those data are collected from different devices.
(D) Categories of Personal Data We Process
Summary – Categories of Personal Data We Process
We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We Process the following categories of Personal Data about you:
(E) Sensitive Personal Data
Summary – Sensitive Personal Data
We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.
(F) Purposes of Processing and legal bases for Processing
Summary – Purposes of Processing and legal bases for Processing
We Process Personal Data for the following purposes: providing our Sites, Apps, products, and services to you; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, products, and services; fraud prevention; and recruitment and job applications.
|Processing activity||Legal basis for Processing|
|Provision of Sites, Apps, products, and services: providing our Sites, Apps, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, products, or services.||
|Operating our business: operating and managing our Sites, our Apps, our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, our products, or our services; and notifying you of changes to any of our Sites, our Apps, our products, or our services.||
|Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.||
|Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices.||
|Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.||
|Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.||
|Financial management: sales; finance; corporate audit; and vendor management.||
|Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, our products, or our services.||
|Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).||
|Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.||
|Legal proceedings: establishing, exercising and defending legal rights.||
|Legal compliance: compliance with our legal and regulatory obligations under applicable law.||
|Improving our Sites, Apps, products, and services: identifying issues with our Sites, our Apps, our products, or our services; planning improvements to our Sites, our Apps, our products, or our services; and creating new Sites, Apps, products, or services.||
|Fraud prevention: Detecting, preventing and investigating fraud.||
|Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.||
(G) Disclosure of Personal Data to third parties
Summary – Disclosure of Personal Data to third parties
We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.
We disclose Personal Data to other entities within the Oasis group, for legitimate business purposes and the operation of our Sites, Apps, products, or services to you), in accordance with applicable law. In addition, we disclose Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
Summary – Profiling
Personal Data are subject to automated decision-making and Profiling.
We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:
|Profiling activity||Logic of the Profiling activity||Consequences for you|
|Fraud screening||Where we engage a third party (e.g., a payment service provider) to provide us with fraud screening at payment stage.||This Profiling activity may affect whether you are able purchase on our website.|
|Customised communications||Where we analyse your purchasing activity and your interests. This information is analysed to determine the most appropriate content and promotions to offer you.||This Profiling activity may mean that you receive tailored content and discounts that are not available to others, and that others receive content and discounts that are not available to you.|
(I) International transfer of Personal Data
Summary – International transfer of Personal Data
We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of EU-US Privacy Shield.
Because of the international nature of our business, we transfer Personal Data within the Oasis group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of EU-US Privacy Shield. You are entitled to request a copy of our EU-US Privacy Shield using the contact details provided in Section (R) below.
Please note that when you transfer any Personal Data directly to an Oasis entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.
(J) Data security
Summary – Data security
We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
(L) Data minimisation
Summary – Data minimisation
We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.
(M) Data retention
Summary – Data retention
We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
|(1) we will retain Personal Data in a form that permits identification only for as long as:||
|plus:||(2) the duration of:||
|and:||(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.|
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
(N) Your legal rights
Summary – Your legal rights
Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
- erasure of your Relevant Personal Data; or
- restriction of Processing of your Relevant Personal Data;
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
(O) Cookies and similar technologies
Summary – Cookies and similar technologies
(Q) Direct marketing
Summary – Direct marketing
We Process Personal Data to contact you with information regarding Sites, Apps, products, or services that may be of interest to you. You may unsubscribe for free at any time.
We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, products, or services that may be of interest to you. If we provide Sites, Apps, products, or services to you, we may send information to you regarding our Sites, Apps, products, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, products, or services you have requested.
(R) Details of Controllers
Summary – Details of Controllers
There are several Oasis entities that act as Controllers for the purposes of this Privacy Notice.
For the purposes of this Notice, the relevant Controllers are:
|Controller entity||Contact details|
|Oasis Customer Services||0345 257 3333|
Alternatively, you may contact us by emailing email@example.com .
“App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
“EEA” means the European Economic Area.
“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
“Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Relevant Personal Data” means Personal Data in respect of which we are the Controller.
“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
“Site” means any website operated, or maintained, by us or on our behalf.
Here at Oasis good ethics are fundamental to the way we work - from the consideration of workers' rights to good animal Welfare and support for local community organisations.
We adopted our first Code of Conduct over a decade ago, because, as much as we're all about clothes that make you smile, we're absolutely committed to ensuring those behind our products are treated fairly. We're proud of the long-standing relationships we have with many of our suppliers and the sense of responsibility we share with our partners towards working conditions.
What does this mean in a nutshell? Well, our strategy includes policies in line with good practice, a monitoring and auditing programme, communication and education (both internally and with our suppliers) and our living wage strategy.
The majority of our production comes from China, Turkey, Vietnam, Romania and Bulgaria, and we also have a small number of suppliers in India, Pakistan and Morocco too. Over 80% of our clothing comes from our top 20 suppliers; around half of these have been suppliers for over a decade. The cornerstone of what we do is our Code of Conduct , which is based on the conventions of the International Labour Organisation. It includes the following commitments:
- No child labour
- Safe working conditions
- A living wage
- No excessive hours
- No discrimination
- Freedom of association as a right
- No forced labour
- Regular employment
- No harsh or unfair treatment
Suppliers are expected to meet national laws and where the Code and local law address the same subject, apply the necessary provisions that give greater protection to workers.
How do we translate our ethics into actions? Here are some examples:
In 2011, Oasis joined other stakeholders (including trade unions and industry peers) in publicly supporting a ban on sandblasting. Sandblasting can be extremely damaging to a worker's health if sand is inhaled can lead to a disabling and potentially fatal lung disease called silicosis. Our policy bans sand and other abrasive substances too.
We've also banned cotton from Uzbekistan as a result of long-standing concerns regarding child and forced labour in the harvesting of Uzbek cotton.
In China - our largest sourcing country - we carry out internal audits, conducted by our Ethical Trading team. The audit involves a review of records (including payroll, attendance records, labour contracts, personnel files, social insurance records, business licenses and health and safety certificates and permits), confidential interviews with workers, discussions with management and a physical inspection of premises.
Outside of China, we commission third-party audits to measure practices against our code. We only authorise certain third-party companies to carry out audits on our behalf. As a member of SEDEX, we can share audits conducted by other companies, but we only accept those we believe have been performed to our own rigorous standards. If an audit shows non-compliances with our standards, we work with suppliers to ensure progress is made over a reasonable timeframe. We support suppliers to implement solutions that are practical and make a difference. This support may include providing verbal advice on labour law, practical tools to better manage production and instructive training delivered to factory management teams.
As well as our suppliers and factories, relevant internal teams are trained on our policies so they know how they can support our ethical standards.
Oasis has also undertaken a project seeking to trace the source of raw materials in our supply chain. This has enabled us to better understand our environment and the impact we have as a business.
Oasis supports Richard House, a children's hospice that provides care and support to children and young people who suffer from life-limiting or life-threatening illnesses. We've supported the charity in a number of ways including direct donations through fundraising team events, refurbishing the Richard House Upminster store and donating stock.
Our staff also support various charities through Workplace Giving (a scheme that allows employees to make tax-free donations to their chosen charities through payroll) or by undertaking fund-raising activities, which we always encourage.
We're continuously updating our corporate strategy. If you have any questions relating to this statement, please email firstname.lastname@example.org .