Privacy policy

Privacy Policy

Cluethers

Last updated: 12 October 2026

At Cluethers, we value your privacy and are committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store and protect your personal data when you visit our website, purchase our products or contact us.

Cluethers is an independent online leather goods business based in London, United Kingdom. Our website is powered by Shopify.

We handle personal information in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR), and relevant amendments introduced by the Data (Use and Access) Act 2025.

1. Who We Are

Cluethers is an online business selling leather goods and accessories, including handbags, jackets, wallets, belts and berets.

For the purposes of applicable UK data protection law, the person operating Cluethers is the data controller responsible for the personal information processed by the business.

Business name: Cluethers

Business structure: Sole Trader

Operated by: Teia Cueva Mena

Business contact address: Thurlow Towers, Knollys Rd SW16 2JY

Email: cluethers@gmail.com

If you have any questions about how we handle your personal information, you can contact us using the details above.

2. Personal Information We Collect

We collect and process personal information that is necessary to operate our online store and provide our services.

Depending on how you interact with Cluethers, this may include:

Contact Information

  • Full name.

  • Email address.

  • Telephone number, where provided.

  • Billing and delivery addresses.

Order Information

  • Products purchased.

  • Product preferences, including sizes and colours.

  • Order numbers and transaction details.

  • Order history.

  • Delivery and tracking information.

  • Returns and refund information.

Payment Information

Payments are processed through Shopify and its supported payment providers.

Payment providers may process information such as payment method details, transaction amounts and payment authorisation information.

Cluethers can access relevant order and payment status information through Shopify, but does not directly store customers' full payment card numbers.

Website and Device Information

  • IP address and device information.

  • Browser type and operating system.

  • Website interactions and browsing activity.

  • Cookie and privacy preferences.

Customer Communications

We may collect information you provide when contacting us by email, completing contact forms, submitting reviews or requesting assistance.

We only collect personal information that is relevant and necessary for the purposes explained in this policy.

3. How We Collect Your Information

We may collect information:

Directly from you

When you place an order, contact us, create a customer account, subscribe to communications or submit information through our website.

Automatically through our website

When you browse our store, Shopify may collect certain technical and usage information using cookies and similar technologies.

From our service providers

We may receive information from Shopify, payment providers, Royal Mail and other service providers involved in fulfilling your order or managing our business.

We do not currently use separately installed Google Analytics, Meta Pixel or TikTok Pixel tracking tools on our website.

If our tracking or data-processing practices change, we will update this policy as necessary.

4. How and Why We Use Personal Information

Under the UK GDPR, we must have an appropriate lawful basis for processing personal information.

We use information for the following purposes:

Processing and Delivering Orders

We use your name, contact details, address and order information to process purchases, arrange payments, prepare products and deliver orders.

Lawful basis: Performance of a contract.

Customer Support and Returns

We use relevant information to respond to enquiries, manage returns and refunds, and resolve concerns about purchases.

Lawful basis: Performance of a contract and, where appropriate, legitimate interests.

Legal and Financial Obligations

We retain certain transaction and financial records to comply with applicable tax, accounting and other legal requirements.

Lawful basis: Legal obligation.

Security and Fraud Prevention

We may use relevant information to help protect our website, investigate suspicious transactions and prevent fraud.

Lawful basis: Legitimate interests and, where applicable, legal obligation.

Our legitimate interests include protecting our customers, preventing fraud and maintaining a secure business.

Website Analytics and Improvements

We use Shopify's built-in analytics to understand how visitors interact with our website, assess its performance and identify opportunities to improve the shopping experience.

Lawful basis: Legitimate interests, where appropriate and following the necessary assessment. Consent will be used where required for particular processing activities.

The lawful basis for processing personal data is separate from any consent or exemption required for cookies and similar technologies.

Marketing Communications

Where we offer marketing subscriptions, we may use contact details to send information about Cluethers, new collections and special offers.

We will only send electronic marketing where you have provided valid consent or where an applicable existing-customer exception permits it.

Where we rely on consent, the lawful basis is consent. Where the existing-customer exception applies, the relevant personal data processing may be based on legitimate interests following an appropriate assessment.

You can unsubscribe from marketing communications at any time.

Order confirmations, delivery notifications and other necessary transactional communications may still be sent.

5. Cookies and Shopify Analytics

Our website uses cookies and similar technologies to support essential store functionality and, where permitted, understand website performance.

Cookies may be used for:

Essential Store Functions

These technologies help operate important website features such as shopping baskets, checkout, security, authentication and remembering certain preferences.

Website Analytics

We use Shopify's built-in analytics to help understand website traffic, visitor interactions and store performance.

Privacy Preferences

Where optional cookies or similar technologies require consent, we will seek that consent before using them.

Certain analytics technologies may qualify for a statutory consent exception where all applicable legal requirements are satisfied, including clear information and an easy way to object.

You can review or change your cookie preferences at any time by selecting "Cookie preferences" in the footer of our website.

You may also be able to manage or block cookies through your browser settings, although disabling essential cookies may affect the website's functionality.

We review the cookies used by our website and update our privacy information when necessary.

For additional information about Shopify's processing activities, please see its privacy information:

https://www.shopify.com/legal/privacy

6. Sharing Your Information

We only share personal information where necessary for the purposes described in this policy or where legally required.

This may include sharing relevant information with:

Shopify

Shopify provides the technology used to operate our website, manage orders, maintain customer accounts and support the checkout process.

Payment Service Providers

Payment providers process transactions and help manage payments, refunds and payment security.

Royal Mail

We share relevant delivery information, including names and addresses, with Royal Mail to arrange and complete shipments.

IT and Business Service Providers

We may use service providers that support website hosting, customer communications, data storage, accounting or other essential business operations.

Public Authorities

We may disclose information where legally required, including to relevant tax authorities, regulators or law enforcement bodies.

We do not disclose personal information to unrelated businesses for their independent marketing purposes merely because a customer has placed an order.

Where Shopify independently processes information for its own purposes, its relevant privacy notices and customer rights arrangements may also apply.

7. Shopify and Its Services

Our online store is hosted by Shopify.

Shopify processes certain information to provide and maintain the services that allow Cluethers to operate.

Information may be processed or stored in countries outside the United Kingdom, subject to applicable data protection requirements.

Depending on the services enabled for our store, Shopify may also process information as an independent data controller for certain purposes.

You can learn more about Shopify's privacy practices and available privacy rights through:

Shopify Consumer Privacy Policy

https://www.shopify.com/legal/privacy/app-users

Shopify Privacy Portal

https://privacy.shopify.com/en

[IMPORTANT: IF SHOPIFY NETWORK INTELLIGENCE IS ENABLED, ADD THE SUPPLEMENTARY DISCLOSURE PROVIDED BELOW BEFORE PUBLISHING.]

8. International Data Transfers

Some of the service providers we use, including Shopify and its associated service providers, may process or store personal information outside the United Kingdom.

Where a transfer is subject to the UK GDPR's international transfer restrictions, it must be supported by an appropriate legal mechanism.

Depending on the circumstances, this may include UK adequacy regulations, appropriate contractual safeguards such as the UK International Data Transfer Agreement or UK Addendum, or another lawful transfer mechanism.

Where required, we take appropriate steps to ensure personal information continues to receive the protection required by applicable UK data protection legislation.

You may contact us at cluethers@gmail.com to request further information about relevant transfer safeguards.

9. How Long We Keep Your Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or to comply with applicable legal requirements.

Different retention periods may apply depending on the type of information:

Order and Financial Records

We retain records necessary for accounting and tax purposes for the periods required by applicable UK law.

For sole traders, relevant business and tax records generally need to be retained for at least five years after the 31 January filing deadline for the relevant tax year, subject to applicable exceptions.

Customer Communications

We retain customer support communications for as long as necessary to respond to enquiries, manage complaints, resolve disputes and protect our legal rights.

Customer Accounts

Account information may be retained while an account remains active, subject to any applicable legal retention requirements.

Marketing Preferences

Where marketing is offered, subscription preferences are maintained until the customer unsubscribes or the information is no longer needed. Limited records may be retained to respect an opt-out.

Analytics Information

Analytics data is retained according to the relevant purpose, Shopify's applicable data-retention arrangements and our data protection obligations.

When personal information is no longer required, we will delete, anonymise or securely dispose of it as appropriate.

10. Your Data Protection Rights

Under the UK GDPR, you may have the following rights, subject to applicable conditions and exceptions:

  • Right of access: Request access to personal information we hold about you.

  • Right to rectification: Request correction of inaccurate or incomplete information.

  • Right to erasure: Request deletion of personal information in certain circumstances.

  • Right to restrict processing: Ask us to limit how we use your information in certain circumstances.

  • Right to data portability: Request certain personal information in a structured, commonly used and machine-readable format.

  • Right to object: Object to processing based on legitimate interests in certain circumstances.

  • Rights relating to automated decision-making: Exercise applicable rights where solely automated decisions have legal or similarly significant effects.

You have the right to object to the processing of your personal information for direct marketing at any time.

Where we rely on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise your rights, please contact us at cluethers@gmail.com.

We may need to verify your identity before responding to certain requests.

We will respond within the time limits required by applicable law, generally within one month for requests relating to your UK GDPR rights, subject to lawful extensions or exceptions.

11. Data Security

We take reasonable and appropriate measures to protect personal information against unauthorised access, misuse, loss, alteration and disclosure.

Our website operates using Shopify's e-commerce infrastructure, which provides security features for online transactions and the handling of customer information.

Access to personal information is limited to those who need it for legitimate business purposes.

However, no internet-based system can guarantee absolute security.

If you believe your personal information has been compromised, please contact us at cluethers@gmail.com.

12. Children's Privacy

Our products and services are intended for general consumers and are not specifically directed at children.

We do not knowingly collect personal information from children for purposes that require parental authorisation without an appropriate legal basis.

If you believe a child has provided us with personal information inappropriately, please contact us so we can review the matter and take appropriate action.

13. Third-Party Websites

Our website may contain links to external websites or platforms, including social media services.

We are not responsible for the privacy practices of websites that we do not control.

We encourage customers to review the privacy notices of external services before providing personal information.

14. Data Protection Complaints

If you have a concern or complaint about how Cluethers collects, uses, stores or protects your personal information, please contact us:

Email: cluethers@gmail.com

Please explain your concern and provide any relevant information that may help us investigate.

We will:

  1. Acknowledge your complaint within 30 days of receiving it.

  2. Take appropriate steps to investigate the matter without undue delay.

  3. Keep you informed of progress where appropriate.

  4. Communicate the outcome and any actions taken.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, services, technology or applicable legal requirements.

Any updates will be published on our website with a revised "Last updated" date.

Where required by law, we will provide additional notice of significant changes.

16. Contact Us

For questions about this Privacy Policy, data protection requests or privacy-related concerns, please contact:

Cluethers

Operated by: Teia Cueva Mena

Email: cluethers@gmail.com

Business contact address: Thurlow Towers, Knollys Rd, SW16 2JY

Location: London, United Kingdom

We are committed to handling your personal information responsibly and transparently.