Privacy policy

ICEX Privacy Policy

Last updated and effective: 13 August 2026

1. Who we are

ICEX is the trading name of ICEX WEAR LTD, a company incorporated in England and Wales (referred to in this policy as “ICEX”, “we”, “us” or “our”). We are the controller of the personal data described in this policy, which means we decide why and how it is used.

Contact details

● Email: support@icexwear.com

● Registered office: 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom

● Company number: 17379784

This policy applies when you visit icexwear.com, buy from us, contact us, receive marketing from us, or apply for or take part in an ICEX creator partnership.

2. The personal data we collect

Depending on how you interact with us, we may collect:

● Identity and contact data: your name, email address, telephone number, delivery address and billing address.

● Order and transaction data: products purchased, order history, returns, refunds, discounts, delivery status and payment status. Payment providers process your full card or payment credentials; we generally receive confirmation and limited payment details such as payment method and the last four digits.

● Account data: login details, saved preferences and account activity, if you create an account.

● Communications data: messages, emails, customer-service records, reviews, survey answers and your marketing preferences.

● Technical and usage data: IP address, device identifiers, browser and device type, operating system, approximate location, referral source, pages viewed, links clicked and information collected through cookies, pixels and similar technologies.

● Fraud and security data: information used to verify transactions, prevent abuse, secure our website and assess suspected fraud.

● Creator and partner data: information submitted through our Klaviyo creator forms or otherwise provided to us, including social-media handles and public profile information, application details, age or date-of-birth information where necessary, clothing size and colour selection, photographs, audio, video and other submitted content, performance metrics, contracts, usage rights, payment records and parent or guardian details where applicable.

We normally collect data directly from you. We may also receive it from our ecommerce platform, payment providers, delivery partners, social-media platforms, advertising or analytics partners, fraud-prevention services, or a parent or guardian. If another person places an order for you or gives us your details, we may receive data from that person.

Please do not send us special-category data—such as health, biometric, religious or ethnicity information—unless we specifically request it and explain why it is needed.

3. Why we use your data and our lawful bases

We only use personal data when we have a lawful basis under UK data-protection law.

|Purpose |Data typically used |Lawful basis |
|---------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|Take payment; process, fulfil and deliver orders; manage returns and refunds |Identity, contact, order and transaction data |Performance of our contract with you |
|Answer enquiries and provide customer support |Identity, contact, order and communications data |Performance of a contract or our legitimate interests in providing effective support |
|Maintain accounts, wish lists and customer preferences |Identity, contact, account and order data |Performance of a contract and our legitimate interests in operating our store |
|Keep business, accounting and tax records; comply with lawful requests |Identity, contact, order, transaction and communications data |Compliance with legal obligations |
|Prevent fraud, abuse and security incidents; establish or defend legal claims |Identity, contact, transaction, technical, usage and fraud data |Our legitimate interests in protecting customers and our business, and compliance with legal obligations where applicable |
|Improve our website, products and customer experience |Usage, technical, order and communications data |Our legitimate interests, where the processing is necessary and proportionate; consent where required for cookies or similar technologies |
|Measure advertising and show personalised advertising |Technical, usage and marketing data |Consent where required by law |
|Send marketing by email or SMS |Contact and marketing-preference data |Consent, or the UK electronic-marketing “soft opt-in” where all legal conditions are met |
|Operate creator applications and partnerships, send products, manage content approvals, pay creators and exercise agreed content rights|Creator, identity, contact, order, content, contract and payment data|Steps requested before entering into a contract; performance of a contract; legal obligations; and our legitimate interests in administering and protecting the programme|
|Retain a minimal record of people who opted out of marketing |Contact and preference data |Our legitimate interests and compliance with our legal obligations |

Where we rely on legitimate interests, we assess whether the use is necessary and whether your rights override our interests. You may contact us for more information about that assessment.

If we ask for information needed to enter into or perform a contract and you do not provide it, we may be unable to process your order, provide the relevant service or enter into a creator partnership.

4. Orders and service communications

We may send messages needed to complete or manage an order, including confirmations, delivery updates, safety notices, responses to support requests and important changes affecting a service. These are service messages, not marketing. We do not use an order-update choice as permission to send promotional messages.

5. Email and SMS marketing

We send promotional emails or SMS messages only where permitted by the Privacy and Electronic Communications Regulations 2003 (PECR). This will normally be where:

● you have actively consented to that specific channel; or

● you gave us your contact details when buying, or genuinely negotiating to buy, an ICEX product; we market only our own similar products; and we gave you a clear, simple opportunity to opt out when we collected your details and in every later message.

Marketing consent is optional and is not a condition of purchase. Email and SMS choices must be presented separately and must not use pre-ticked boxes. We keep a record of when, how and what you consented to.

You can unsubscribe from emails using the link in any marketing email. You can opt out of promotional SMS messages by replying STOP where that instruction is provided, or by contacting support@icexwear.com. Carrier message and data charges may apply. We will action marketing objections and withdrawals promptly, but may keep the minimum information required on a suppression list so that we do not contact you again. Where Klaviyo provides our email, SMS, forms or audience-management services, it processes the relevant contact details, form responses, consent records, engagement data and marketing preferences for us.

6. Cookies and similar technologies

We use cookies, pixels, local storage and similar technologies. Strictly necessary technologies may be used without consent where the law permits—for example, to operate the basket, process checkout, remember privacy choices, prevent fraud and keep the website secure.

We will not set or access non-essential analytics, personalisation or advertising technologies until you have made a valid choice, unless another legal exemption clearly applies. Our consent control makes rejecting non-essential technologies as easy as accepting them. You can change or withdraw your choice at any time through the Cookie Settings control displayed on our website.

The cookie information available through our consent banner or Cookie Settings control identifies the technologies in use, their providers, purposes, categories and durations. Browser settings can also block or delete cookies, although parts of the website may then not work correctly.

7. Who we share data with

We share only the data reasonably needed with:

● Shopify, which provides our ecommerce platform, website hosting, checkout, store administration, analytics and related services;

● the payment provider selected at checkout, including Shopify’s payment services and PayPal where offered;

● Amazon Fulfilment, which stores stock and fulfils and delivers relevant customer orders, together with the carriers it uses;

● Klaviyo, which provides our creator forms and may also provide email, SMS, audience-management, consent-recording and marketing services;

● suppliers, warehouses, couriers and returns providers where needed to fulfil an order or process a return;

● customer-support, business email, cloud-storage and document providers used to communicate with customers and administer creator partnerships;

● analytics, consent-management, social-media and advertising providers enabled on our website, but only in line with your cookie and marketing choices;

● professional advisers, insurers, auditors and service providers supporting our business;

● regulators, courts, law-enforcement bodies, tax authorities or other parties where required or permitted by law; and

● a buyer, investor or successor if we sell, reorganise or transfer all or part of our business, subject to appropriate confidentiality and data-protection safeguards.

Some providers act as our processors and may use data only on our documented instructions. Others, including some payment, social-media or delivery providers, may act as separate controllers for their own purposes. Their privacy notices explain those uses.

We do not sell your personal data.

8. International transfers

Some providers may store or access personal data outside the United Kingdom. Where UK data-protection law requires safeguards, we use an applicable UK adequacy regulation or appropriate contractual safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to approved standard contractual clauses, together with any required transfer-risk assessment and supplementary measures.

9. How long we keep data

We keep personal data only for as long as reasonably necessary for the purpose collected, including legal, tax, accounting, fraud-prevention and dispute requirements. Our usual periods are:

|Record |Usual retention period |
|----------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|Orders, payments, returns, refunds and core accounting records |Usually 6 years after the end of the relevant financial or accounting period, or longer if legally required or a dispute is active |
|Customer-service and complaint records |Up to 6 years after the matter closes where needed to manage disputes or legal claims; routine enquiries may be deleted sooner |
|Account data |While the account remains active and normally for up to 2 years after the last account activity, unless needed for another lawful reason |
|Creator applications not accepted |Normally 6 months after the decision, unless the applicant asks to be considered for future opportunities and valid permission is recorded |
|Creator contracts, approvals, payment and content-rights records|For the contract term and usually up to 6 years afterwards; licensed content and proof of rights may be retained for as long as the relevant rights or claims can continue|
|Marketing records |Until you opt out, withdraw consent or the data is no longer needed; suppression records are kept as long as reasonably necessary to honour the opt-out |
|Cookie and advertising data |For the periods shown in the Cookie Settings information and relevant provider settings |
|Security and fraud records |Normally for up to 2 years, or longer where an incident, investigation, chargeback, legal claim or legal obligation requires it |

We may anonymise data so it can no longer identify you and use that anonymous information for statistics or business analysis.

10. Children and creator applicants

Our online store is not directed at children under 13, and children under 13 should not create an account or submit personal data through the website. If we discover that we collected a child’s data unlawfully, we will delete it.

Some ICEX products and creator opportunities may be relevant to teenagers. We provide age-appropriate privacy information where required. We require the involvement and agreement of a parent or legal guardian for every creator applicant under 18 before we send products, enter into a creator agreement, arrange payment, or use the applicant’s image, voice or content. We may collect the parent or guardian’s name, contact details, confirmation of responsibility, agreement records and payment-administration information for these purposes. We use this information to take steps towards and perform the creator agreement, protect the young person, keep evidence of permissions and comply with our legal obligations. We will not use a child’s personal data for behavioural advertising or make consent to optional marketing a condition of participation.

Parents or guardians can contact support@icexwear.com with privacy questions concerning a child. We may need to verify identity and parental responsibility before acting on a request.

11. Security

We use appropriate technical and organisational measures designed to protect personal data, including access controls, limited staff and provider access, secure transmission where appropriate, account security, supplier checks and procedures for handling suspected personal-data breaches.

No internet or storage system is completely secure. You are responsible for keeping account credentials confidential and should contact us promptly if you suspect unauthorised account use. If a personal-data breach creates a legal duty to notify you or the Information Commissioner’s Office (ICO), we will do so.

12. Automated decisions

We and our ecommerce or payment providers may use automated tools to help detect suspicious orders or fraud. ICEX does not make final decisions based solely on automated processing that produce legal or similarly significant effects on you. A payment or order may be paused or declined by a payment or fraud-prevention provider under its own procedures. If qualifying solely automated decision-making is introduced by ICEX, we will provide the information and safeguards required by law.

13. Your data-protection rights

Depending on the circumstances and lawful basis, you may have the right to:

● be informed about how we use your data;

● ask for access to your personal data;

● ask us to correct inaccurate or incomplete data;

● ask us to erase data;

● ask us to restrict how data is used;

● object to processing based on legitimate interests;

● object at any time to the use of your data for direct marketing;

● receive certain data in a portable format and ask us to transmit it to another controller;

● withdraw consent at any time, without affecting earlier lawful processing; and

● ask for safeguards relating to qualifying solely automated decisions.

Your right to object to direct marketing is absolute. If you object, we will stop using your personal data for direct marketing.

To exercise a right, email support@icexwear.com. There is normally no fee. We may ask for proportionate information to verify your identity and clarify your request. We normally respond within one month, subject to lawful extensions for complex or multiple requests.

You may complain to the ICO at ico.org.uk/make-a-complaint or by telephone on 0303 123 1113. We would appreciate the opportunity to address your concern first, but you do not have to contact us before complaining to the ICO.

14. Third-party websites and social platforms

Our website may link to third-party websites, apps or social platforms. Those organisations control their own processing, and this policy does not cover it. Review their privacy notices before providing personal data.

15. Changes to this policy

We may update this policy to reflect changes in our practices, providers or legal obligations. We will publish the revised version here and change the “last updated” date. If a change materially affects how we use your data, we will provide an additional notice where required.

16. Contact us

For questions, requests or complaints about privacy, contact:

ICEX WEAR LTD
Email: support@icexwear.com
Registered office: 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom