This Privacy Policy describes ARH and how your personal information is collected, used, and shared when you visit or make a purchase from www.montaguelloyd.com (the “Site”).

Who are we?

When we say ‘Alexander Ross’ or ‘we’ or ‘us’ or ‘our’, we are generally referring to Alexander Ross Holdings Limited and the separate legal entities that make up our group businesses.

Alexander Ross Holdings Limited is a limited company registered in Scotland (SC104728). Registered Office North Main Street, Carronshore, Falkirk, FK2 8HT.

Alexander Ross Management Services Limited is a limited company registered in England & Wales (01536834). Registered Office, Condor House, 10 St Paul’s Churchyard, London, EC4M 8AL.

Unico Limited is a limited company registered in England & Wales (00861294). Registered Office, Condor House, 10 St Paul’s Churchyard, London, EC4M 8AL.

Montague Lloyd is a division of Unico Limited.
Scottish Fine Soaps Limited is a limited company registered in England & Wales (00671154).

Registered Office, Condor House, 10 St Paul’s Churchyard, London, EC4M 8AL.

It will also include other business we may add to Alexander Ross Holdings Limited in the future.

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or

search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store-- you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized- ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Alexander Ross, at your request, can confirm what information we hold about you and how it is processed. If Alexander Ross does hold personal data about you, you can request the following information:

Identify the contact details of the person or organisation that has determined how and why to process your data.

Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.

If the processing is based on the legitimate interests of Alexander Ross Holdings Limited or a third party, information about those interests.

The categories of personal data collected, stored and processed. Recipient(s) or categories of recipients that the data is/will be disclosed to.

If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.

How long the data will be stored

Details of your rights to correct, erase, restrict or object to such processing. Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.

Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

The source of personal data if it wasn’t collected directly from you.

Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Alexander Ross accepts the following forms of ID when information on your personal data is requested:

Passport or driving licence, bank statement or utility bill (dated within the last 3 months).

We will normally respond to your request within one month of it being received. However, in some cases, we may need to extend this to three months. We will always write to you within one month of receiving your original request to tell you if this is the case.

A copy of your personal data is usually provided free of charge. However, we can charge a ‘reasonable fee’ where we find that the data requested is excessive or unfounded and if the request is a repetitive one.

DATA RETENTION

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Montague Lloyd
Re: Privacy Compliance Officer
Montague Lloyd, North Main Street, Carronshore, Falkirk, FK2 8HT, United Kingdom

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‐mail at Online@montaguelloyd.com or by mail using the details provided below: