Privacy Policy



What’s it all about?


This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle our data, and keep it safe.


We appreciate that there is a lot of information here but it is important to us that you are fully informed about your rights, and how Topazglow Direct uses your data, for example how Topazglow Direct combines data collected to build a picture of you.


It is our hope that the following sections will answer any questions you have but in the rare occasion that it does not please do not hesitate to contact us.


This Privacy Policy will be updated from time to time, when any changes are significant we will notify you other than that you are more than welcome to come back and review it when ever you wish too.


When you are using the Topazglow Direct website (, Topazglow Direct is the data controller.



What is Topazglow Direct?


Topazglow Direct is a partnership with Jane Klugerman, trading as Topazglow, VAT NO: 613156764. In this document we will refer to Topazglow Direct as “we” and “us”.


What are the legal bases that we rely on?




In specific situations, we can collect and process your data with your consent. An example of this would be if you ticked a box to receive our Email newsletters. When collecting your personal data, we will always make it clear to you which data is necessary in connection with a particular service.


Contractual Obligations


In some circumstances we may need your personal data to comply with our contractual obligations. An example of this would be if you placed an order with us and to enable a delivery to be made the address details we have collected will be passed to our courier.


Legal Compliance


If the law requires us to we may need to collect and process your data. An example of this would be if we needed to pass on details of people involved in fraud or other criminal activity affecting us to any law enforcement agencies.


Legitimate Interest


In certain circumstances we may require your data to pursue our interests in a way which might be reasonably expected as part of running our business and which does not impact on your rights, freedom or interests. An example of this is that we will use your purchase history to send you or make you aware of personalized offers.


When do we collect your Personal Data?


There are many occasions when we may do so, and the following details when:


  • When you visit our website and use your Account to buy products or redeem a voucher online.
  • When you make an online purchase and check out as a guest, in which case we just collect transaction based data.
  • When you create an Account with us.
  • When you engage with us on social media
  • When you join our loyalty programme.
  • When you contact us by any means with queries, complaints etc.
  • When you enter competitions or prize draws.
  • When you attend any of our events, for example an open day.
  • When you choose to complete a survey.
  • When you comment on or review our products.
  • When you have given a third party permission to share information they hold about you, with us.


What sort of Personal Data do we collect?


The following details the types of data we collect:


    • Details of your interactions with us online.
    • Details of your visit to our website and from which site you came from.
    • Information gathered by use of cookies in your web browser. For more information visit our Cookies and Similar Technologies Page.
    • Personal details, which help us, recommend items of interest.
    • Your comments and product reviews.
    • To help deliver you the best possible web experience we collect technical information about your Internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed, the advertisements you clicked on and any search terms you entered.


    How and why do we use your Personal Data?


    We want to give you the best possible customer experience. One way to achieve this is to get the most comprehensive picture of you that we can, by combining the data we have about you.


    We can then use this to offer you promotions and products that are most likely to be of interest to you. In the case of our loyalty scheme members we will also offer you relevant rewards.


    The Data Privacy law allows this as part of our legitimate interest in understanding our customers and providing the best possible customer experience. Of course, you may not want this, if that is the case pleas refer to the “What are my rights?” section below. 


    Please remember that if you choose not to share your Personal Data with us or refuse certain contact permissions we may not be able to give you the service you have asked for. An example of this is that you have asked to be informed when an item comes back into stock but we cannot do that if you have withdrawn your general consent to hear from us.


    Here is how we will use your Personal Data and why?


    • To process any orders you make on our website online or any orders made offline. If we do not collect your personal data during checkout we will not be able to process your order and fulfill our legal obligations.
    • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond, we may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you through out. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interest in providing you with the best service and understanding how we can improve our service based on your experience.
    • To protect our business and your Account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your Account. We will also monitor your browsing activity with us to identify and resolve any problems and protect the integrity of our website. We will do all of this as part of our legitimate interest.
    • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests and this also helps to protect our customers from fraud.
    • If we discover any criminal activity or alleged criminal activity through our use of fraud monitoring and suspicious transaction monitoring we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
    • With your consent we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
    • To send you relevant, personalized communications by post in relation to updates, offers, services and products.
    • To send you communications required by law or which are necessary to inform you about changes to our products and services.
    • To display the most interesting content to you on our website we will use data we hold about your favorite brands or products.
    • To administer any of our prize draws or competitions, which you have entered, based on your consent given at the time of entering.
    • To develop, test and improve the systems, services and products we provide to you.
    • To comply with our contractual or legal obligations to share with law enforcement agencies.
    • To send you survey and feedback requests to help improve our service.
    • To build the best profile of who you are and what you like, and to inform you of our business decisions we will combine data captured from across our business.
    • To process your order sometimes we will need to share your details with a third party who is providing a service such as a delivery courier. Without sharing your personal data we would be unable to fulfill your request.


    Combining your Data for personalized direct marketing.


    We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across our business.


    How do we protect your Personal Data?


    We know how much data security matters to all our customers and because of this we will treat your data with the upmost care and take all appropriate steps to protect it.


    We secure access to all transactional areas of our website using “https” technology.


    Access to your personal data is password protected and sensitive data such as payment card information is secured and tokenized to ensure it is protected.


    We regularly monitor our system for possible vulnerabilities and attacks and carry out penetration testing to identify ways to further strengthen security. 


    How long will we keep your Personal Data?


    Whenever we collect or process your personal data we will only keep it for as long as is necessary for the purpose it was collected.


    At the end of this period your data will be either deleted or anonymised, for example by aggregation with other data so that it can be used in an non identifiable way for statistical analysis and business planning.


    Who do we share your Personal Data with?


    We sometimes share your Personal Data with trusted third parties. An example of this is our delivery couriers.


    Here is the policy we apply to those organisations to keep your data safe and protect your privacy.


    • We provide only the information needed to preform their specific service.
    • They may only use your data for the exact purposes we specify in our contract with them.
    • We work closely with them to ensure your privacy is respected and protected at all times
    • If we stop using their services any of your data held by them will be either deleted or anonymised.



    Examples of the kind of third parties we work with.


    • IT companies who support our website and other business systems
    • Operational companies such as delivery couriers.
    • Direct marketing companies who we may use to manage our communications with you.
    • Google/Facebook to show you products that might interest you while you are browsing the Internet. This is based on either your marketing consent or your acceptance of cookies on our website. See our Cookies Notice Page for more information.


    Sharing your Data with third parties for their own purposes.


    • For fraud management we may share information about fraudulent or potentially fraudulent activity on our systems. This may include sharing data about individuals with law enforcement bodies.
    • We may be required to disclose your personal details to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
    • We may, from time to time, expand, reduce or sell our business and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
    • For further information please contact the Data Protection Officer.


    Where may your Data be processed?


    Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.


    International Orders


    If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to our business in the UK.


    Protecting your Data outside the EEA


    The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third party data processors in countries that are outside the EEA.


    If we do this we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA.


    Any transfer of your person data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.


    What are your rights over your Personal Data?


    An overview of your different rights


    You have the right to request:


    • Access to the personal data we hold about you, free of charge in most cases.
    • The correction of your personal data when incorrect, out of date or incomplete.
    • That we stop using your Personal Data for direct marketing either through specific channels, or all channels.
    • That we stop any consent based processing of your personal data after you withdraw that consent.
    • A review by a Director of any decision made based solely on automatic processing of your data. For example where no human has yet reviewed the outcome and criteria for the decision.


    You have the right to request a copy of any information about you that the company holds at any time, and to have that information corrected if inaccurate. To ask for your information or to have it amended please contact:


    FAO: Mr. Jayden Hartmann (Data Protection Officer).

     Topazglow Direct,

    Thirty Five, Sycamore Park

    Oak Drive

    Leeds, LS14 2FB.


    Or Email:



    If we choose not to action your request we will explain to you the reasons for our refusal.


    Your right to withdraw consent


    Whenever you have given us your consent to use your personal data you have the right to change your mind at any time and withdraw that consent.


    Where we rely on our legitimate interest


    In cases where we are processing your personal data on the basis of our legitimate interest you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.


    Direct marketing


    You have the right to stop the use of your personal Data for direct marketing activity through all channels or selected channels. We must always comply with your request.


    Checking your identity


    To protect the confidentiality of your information we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorized a third party to submit a request on your behalf we will ask them to prove they have your permission to act. 


    How can you stop the use of your personal data for direct marketing?


    There are several ways you can stop direct marketing communications from us:


    You can click the “unsubscribe” link in any email communication that we send you. We will then stop any further emails.


    You can write to:

    FAO: Mr. Jayden Hartmann (Data Protection Officer).

     Topazglow Direct,

    Thirty Five, Sycamore Park

    Oak Drive

    Leeds, LS14 2FB.


    Or Email:



    Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.


    How to Contact the Regulator?


    If you feel that your data has not been handled correctly, or that you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.


    You can contact the by calling 0303 123 1113


    Or visit their website


    If you are based outside the UK you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Further details can be found below.


    What if you live outside the UK?


    For all non UK customers


    By using our services or providing your personal data to us you expressly consent to the processing of your personal data by us or on our behalf. Of course you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.


    Sometimes we will need to transfer your personal data between countries to enable us to supply the goods you have requested. In the ordinary course of business we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.


    By dealing with us you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.


    This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.


    We will ensure that all reasonable steps are taken to prevent third parties outside your country of residence using your personal data in a way that is not set out in this Privacy Notice. We will also make sure we adequately protect the confidentiality and privacy of your personal data.




    For the purposes of this Privacy Notice “personal data” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.


    If you are in Australia you may submit any questions, comments or complaints to our UK based Data Protection Officer who will respond to you within 30 days.


    If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.


    We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We would be grateful for your cooperation with us during this process by providing us with any relevant information that we may need.


    If we have not replied to you within 30 days, or you are not happy with the response we give you may submit a complaint to the Office of the Australian Information Commissioner.


    We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.


    Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth)




    To learn more about our cookies and website “track” and “do not track” practices please see our Cookies Notice.




    As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.


    The personal data we process may be accessed by people within the Company, or by our third party service providers, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is largely held in the UK.


    If you have any questions please contact our Data Protection Officer.


    If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada.


    South Korea, Malaysia, Singapore and Qatar


    Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (PDPA).


    By placing an order with us, opening an Account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookie Notice, including for analytics and research into web use.


    What if I have further questions?


    We hope this Privacy Notice has been helpful in describing the way we handle your Personal Data and your rights to control it.


    If you have any further questions please contact our Data Protection Office who will be pleased to help you. Please contact him by post at:


    FAO: Mr. Jayden Hartmann (Data Protection Officer).

     Topazglow Direct,

    Thirty Five, Sycamore Park

    Oak Drive

    Leeds, LS14 2FB.


    Or Email:



    This policy was last reviewed and revised in February, 2020.