At naked-underwear.com, we take the protection of your personal data and respect for your privacy very seriously. This privacy notice explains how your data is collected, used, transferred and disclosed by NAKED Underwear. It applies to data collected when you use our website, when you interact with us via social networks, by e-mail or by telephone, or when you take part in our competitions or events. It covers:

• The personal data we collect
• How we collect your data
• How we use your data
• Marketing, advertising and cookie preferences
• Links to third-party websites and services
• How we share your data
• Your rights
• Changes to this privacy notice
• How to contact us

Our commitment to you

We take the protection of your personal data seriously and we are committed to processing it fairly, lawfully and transparently. This privacy notice sets out the types of personal data we collect about you and how it is used.

We will collect and use your personal data only to:

• fulfill your orders
• keep you informed of the latest offers and trends
• offer you a better shopping experience
• be able to offer you products better suited to your preferences and interests
• improve our services
• comply with our legal obligations

How we protect your data

We have put in place appropriate organizational security and protection measures to protect your data against any accidental or unauthorized loss, use, access, alteration or disclosure.

Communication between your browser and our website uses a secure encrypted connection in all contexts where your personal data is involved.

We require all third parties engaged to process your personal data on our behalf to put in place security measures to protect your data and to process it in accordance with the law.

In the unfortunate event of a personal data breach, we will inform you and any applicable regulatory body to the extent that the law requires us to do so.

The personal data we collect

Personal data is information about an individual from which that individual can be identified. It does not include anonymized data, where the identity and identifying information have been removed.

Our site is reserved for adults (18 years of age or over), as provided in our general terms of use. We do not knowingly collect any data concerning minors and do not sell products to them.

We collect personal data in the following categories:

• Identity data includes information such as: first name, last name, title, date of birth (optional), occupation, personal description, photo and gender.
• Contact data includes information such as: e-mail address, billing address, delivery address, country, telephone number, loyalty program membership number and social network identifier (if you log in via a social network).
• Financial data includes information such as payment card and bank account details.
• Transaction data includes information such as the details of your purchases and of the fulfillment of your orders (cart number, order number, subtotal, title, currency, discounts, shipping, number of items, unit item price, category, tax, etc.); payments to and from you, and details of the other products and services you have obtained from us, correspondence or communications with you regarding your orders, and details of rewards and bonuses granted.
• Technical data includes information about the devices used to access our services, your IP address, your login data, your username and password, browser type and version, your time zone and location, your browser plug-in types and versions, your operating system and platform.
• Profile data includes information such as the purchases or orders you have made, your interests in terms of products and styles, your preferences, your feedback and your survey responses.

• Usage data includes the following information: how and when you use our site, your browsing patterns, what you have searched for; site performance statistics, traffic, location, weblogs and other communication data; loyalty program activities; and details of all the other NAKED Underwear products and services you use.
• Marketing and communications data includes information such as: your preferences for receiving promotional campaigns from us and from our third parties, as well as your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data, as it does not reveal your identity directly or indirectly. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the site. However, if we combine or connect aggregated data with your personal data in order to identify you directly or indirectly, we will treat the combined data as personal data, which will be used in accordance with this privacy notice.

How we collect your data

We may collect personal data about you in the following ways:

• Direct interactions: you may provide us with your identity, contact, financial, transaction, profile and marketing and communications data (as described above) by filling in forms, entering information online or corresponding with us by post, telephone, e-mail or otherwise. This includes the personal data you provide, for example, in the following circumstances:
  
  
  • when you create an account or purchase products on our website;
  • when you sign up to our newsletter, our discussion forums or our social networking sites, or when you create wish lists;
  • when you enter a competition;
  • when you join a NAKED Underwear loyalty program;
  • when you take part in market research;
  • when you contact us for information or to report a problem (by telephone, e-mail, social networks or messaging service);
  • when you use the "refer a friend" feature on our website; or
  • when you log in to our site via social networks.

• Automated technologies or interactions: when you interact with our site, we may automatically collect the following types of data (as described above): technical data about your equipment, usage data relating to your actions and browsing patterns, and contact data when tasks carried out via our site remain incomplete, such as incomplete orders or abandoned carts. We collect this data using cookies, server logs and other similar technologies. You can adjust your choices at any time from the Website's cookie management banner.

• Third parties: we may receive personal data about you from third-party companies, including:
  
  
  • Technical data from third-party companies, in particular analytics providers such as Google. To find out more, please refer to the "Marketing, advertising and cookie preferences" section.
  • Technical data from partner networks through which you accessed our site;
  • Identity and contact data from social network platforms when you log in to our site via one of these platforms;
  • Contact, financial and transaction information from technical, payment and delivery service providers.

How we use your data

Legal basis for processing your personal data

We will collect and process your personal data only in the cases permitted by law. As the data controller (MLPR, 2 rue Beauvoisine, 76000 Rouen), we are permitted by law to collect and use your personal data under different conditions depending on the method of and reasons for collection.

We collect your personal data only if:

• we have your consent to do so, or
• we need your personal data to perform a contract with you. For example, to process a payment you make, fulfill your orders or provide you with support in connection with an order, or
• the processing of this data is in our legitimate interests and is not overridden by your rights, or
• we have a legal obligation to collect or disclose your personal data.

 

How we use your personal data

Your personal data is used by NAKED Underwear to support a range of different activities. These activities are listed in the table below, together with the types of data used and the legal bases we rely on to process them, including, where applicable, our legitimate interests. Please note that we may process your personal data in different ways permitted by law, depending on the specific activity concerned. Please contact us if you need more details about the specific legal basis we rely on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Legal basis for processing, including legitimate interests
Creating an account and registering you as a new customer (directly or via social networks).	Identity Contact	Performance of a contract with you
Processing and delivering your order, including the following activities: recording the details of your order; keeping you informed of the status of the order; processing payments and refunds and collecting money owed to us; and automated decision-making for fraud prevention and detection.	Identity Contact Transaction Financial	Performance of a contract with you Necessary for our legitimate interests (for example, to recover debts owed to us) For automated decisions, it is in our legitimate interest to ensure that fraud detection and prevention measures are in place so that fraudsters cannot benefit from our services; we also consider it necessary for the conclusion of a contract with you that we are able to verify your identity and prevent fraud.
Managing our relationship with you, including the following activities: providing you with any information, products and services you request from us; informing you of changes to our services, terms and conditions or privacy notice; asking you to leave a review or take part in a survey.	Identity Contact Profile Marketing and communications	Performance of a contract with you Necessary for our legitimate interests (keeping our records up to date and studying how customers use our products and services)
Enabling you to take part in a competition, event or survey, or to receive a reward valid for purchases on our site.	Identity Contact Profile Usage Marketing and communications	Necessary for our legitimate interests (studying how customers use our products and services, developing them and growing our business) Where you have decided to take part in a competition or event, for the performance of a contract with you
Administering, protecting and improving our business and our site, in particular through the following activities: troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting; setting default options for you, such as language and currency.	Identity Contact Profile Technical Financial Marketing and communications	Necessary for our legitimate interests (running our business, providing administrative and IT services, network security, and fraud detection and prevention) Necessary to comply with a legal obligation
Providing you with content, online advertising and information relevant to you, and measuring the effectiveness of the advertising provided.	Identity Contact Profile Usage Marketing and communications Technical	Necessary for our legitimate interests (studying how customers use our products and services, developing them, growing our business and informing our marketing strategy)
Using data analytics to: improve our site, our products, our services, our marketing, our customer relationships and our experiences; and for market research, statistical and survey purposes.	Technical Usage	Necessary for our legitimate interests (defining the types of customers for our products and services, keeping our site up to date and relevant, growing our business and informing our marketing strategy)
Recommending products, services, discounts and offers that may be of interest to you, including by sending you this information by e-mail, post or SMS.	Identity Contact Technical Usage Profile Marketing and communications	Necessary for our legitimate interests (developing our products and services and growing our business) or Consent. For further details, see the "Marketing, advertising and cookie preferences" section
Notifying or reminding you by e-mail of any task carried out via our site that remains incomplete, such as incomplete orders or abandoned carts.	Identity Contact Usage	Necessary for our legitimate interests (improving our customers' shopping experience)
Protecting our customers and our site against fraud and theft	Identity Contact Profile	Necessary for our legitimate interests (detecting and preventing fraud)

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your personal data for other purposes, we will inform you and explain the legal basis that allows us to do so. We may process personal data without your consent, in accordance with the rules above, where this is required or permitted by law.

If you have any questions about the use of your personal data by NAKED Underwear, write to us at contact@naked-underwear.com.

Retention period for your personal data

We will not retain your personal data for longer than is necessary to fulfill the purposes for which it was provided and to ensure compliance with our legal obligations. In practice: orders and invoices are kept for 10 years (accounting obligations, Article L.123-22 of the French Commercial Code); the data used to send you our offers, for up to 3 years after your last purchase or your last contact with us; cookies and other trackers, for a maximum of 13 months; the other data relating to your account and your orders, for the duration of our relationship and then for the applicable limitation period (5 years as a general rule).

Marketing, advertising and cookie preferences

Marketing - your preferences

We may send you marketing communications and promotional offers:

• if you have opened an account with us or purchased products from us, or if you have registered for a promotion or an event, and you have not opted out of receiving the marketing communication in question (in accordance with your preferences, as explained below);
• by e-mail if you have subscribed to our newsletters;
• if you provided us with your contact details when entering a competition and you consented to receive such marketing communications (in accordance with your preferences, as explained below).

We may use your identity, contact, technical, transaction, usage, profile and marketing and communications data to form a view of what we think may interest you and to send you information about products and offers that may be relevant to you.

We will ask you for your preferences regarding the receipt of marketing communications by e-mail, post, SMS and other communication channels.

From time to time, we may also include in your order promotional items, services or offers from other third-party companies that may be of interest to you.

With regard to third-party marketing communications, we will obtain your explicit consent before sharing your personal data with third parties for marketing purposes.

You will always have full control over your marketing preferences. If you no longer wish to receive marketing information from us (or from a third party, where applicable), at any time:

• you can unsubscribe from or "opt out" of communications by using the unsubscribe button and following the link included in the footer of any marketing e-mail; or
• account holders can withdraw their consent simply by going to My Account and changing their "Contact Preferences".

We will process all unsubscribe requests as soon as possible, but please note that, due to the nature of our IT systems and servers, it may take a few days for any unsubscribe request to be carried out.

Cookies

Our site uses cookies to distinguish you from other users and to track your visits. This allows us to improve our site and to offer you a better user experience during your visits. Cookies also allow us, and our advertising networks, to show you advertisements that match your preferences and interests.

You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our site may become inaccessible or may not function properly.

The cookies used on the Website, by us and by our third-party providers, and the reasons for their use are presented in the Website's cookie management banner, where you can adjust your choices at any time.

Online advertising

Our online advertising lets you stay up to date with our news and find our products. Like many other companies, we display NAKED Underwear banners and advertisements when you browse other websites and applications, based on your contact, technical, usage and profile data. We do this using a variety of digital marketing networks and advertising exchanges and a range of advertising technologies such as web beacons, pixels, ad tags, cookies and mobile identifiers, as well as specific services offered by certain sites and social networks, such as Facebook's Custom Audiences service.

How do we use analytics and targeted advertising tools?

Using a set of analytics and targeted advertising tools, we display relevant content for you on our site and online advertisements on other sites and applications (as indicated above), we provide you with relevant content through commercial advertisements, and we evaluate the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to analyze interest-based targeted advertising data and/or third-party consumer data (such as age, gender and interests) in order to target and improve marketing campaigns, marketing strategies and the content on our site. We may also use other tools offered by third parties, for example Meta (Facebook, Instagram), to perform similar tasks, using your contact, technical, usage and profile data.

To disable targeted advertising, simply disable "cookies" in your browser settings (see your browser's cookie management settings for more details) or disable the Ads Settings applied to the third party concerned. For example, you can disable the Google Display advertising features using their Ads Settings. As an additional measure to protect your privacy, you can also use the Google Analytics opt-out add-on.

The Digital Advertising Alliance (whose members include Google and Meta) offers a tool called WebChoices that performs a quick scan of your computer or mobile devices, finds which participating companies have enabled personalized advertising on your browser, and lets you change your preferences accordingly.

If you would like more information about the data collected by these third parties or how they use it, please contact us.

Links to third-party websites and services

Our site may, from time to time, contain links to and from other sites belonging to our partner networks, advertisers and affiliates, or to social network platforms. If you click on any of these links, please note that these sites have their own privacy policies and that we are not responsible for those policies. Please check those policies before submitting your personal data to these sites.

Marketing text messages and notifications (where applicable):

By entering your telephone number at checkout, you may receive SMS notifications relating to your order (including abandoned cart reminders) and, only if you have agreed to it, our offers by SMS. You can unsubscribe at any time by replying STOP to one of our messages or by writing to us at contact@naked-underwear.com. To send the messages, your number is transmitted to our SMS sending provider, which acts on our behalf; message delivery and click information is used solely to measure our campaigns.

How we share your data

We may share your personal data with the parties designated below:

• if you have consented to this. For example, if you have consented to receive commercial offers from third parties or relating to third-party products and services (including those offered under co-branding or as part of a joint campaign), we may pass your information on to the third parties in question for the purpose of sending you such advertisements;
• with business partners, service providers, subcontractors and any other third parties we use in the course of our business, for the reasons set out in the table above in the "How we use your data" section, including:

• third-party service providers we engage to supply IT systems and software and to host our site;
• third-party service providers to whom we entrust the delivery of the products you order;
• third-party service providers we subcontract to send you e-mails and postal mail, including regarding incomplete orders or abandoned carts or commercial advertisements, and to provide data cleansing services and marketing and advertising services;
• providers of analytics systems and search engines that help us improve and optimize our site;
• partner networks through which you accessed our site;

• with any third party to whom we may decide to sell, transfer or merge parts of our business or our assets. We may also seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as the previous owners, under the terms of this privacy notice.
• To protect our customers and our site against fraud and theft, we may share the personal data necessary to carry out identity checks and personal data (including data about your age, name and location) with third-party organizations (including law enforcement agencies) involved in preventing and detecting fraud and reducing credit risk. Please note that these third parties may keep a copy of the information we provide to them for this purpose;
• we may share personal data with the fraud detection tools of our e-commerce platform (Shopify) and of our payment providers, in order to carry out fraud prevention checks; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
• with our professional advisers: lawyers, bankers, auditors and insurers, who provide banking, legal, consulting, insurance and accounting services.

Data and countries outside Europe

The personal data we collect from you may be transferred to and stored in countries outside the European Economic Area ("EEA") through the mechanisms provided by law for cross-border data transfers. It may be processed by staff operating outside the EEA who work for us or for one of our service providers. The staff carrying out these transfers may be involved, among other things, in fulfilling your order, processing your payment details and providing support services. We will take all steps necessary to ensure that your data is processed securely and in accordance with this privacy policy.

Whenever we transfer personal data outside the EEA, we ensure that a similar degree of protection is afforded to it by ensuring that appropriate safeguards are in place, as required by law. These include entering into the standard contractual clauses adopted by the European Commission (Implementing Decision (EU) 2021/914), or relying on a country or framework recognized by the Commission as providing an adequate level of protection (for example the EU-U.S. Data Privacy Framework, for certified companies). You can find further information about this here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj

Please contact us if you would like further information about the countries to which we may transfer your personal data and the specific mechanism we use when transferring your personal data outside the EEA.

Your rights

You have various rights under data protection law. Where applicable, you have the right to:

• request access to your personal data
• request rectification of your personal data
• request erasure of your personal data
• request restriction of the processing of your personal data
• request the transfer of your personal data
• object to the processing of your personal data
• object to automated decision-making
• Request human intervention

Some details about each of these rights. If you wish to exercise any of these rights, please send us an e-mail at contact@naked-underwear.com

Request access to your personal data

You have the right to obtain a copy of the personal data we hold about you and certain information relating to how we process your personal data.

Request rectification of your personal data

You have the right to have your personal data rectified if it is inaccurate or incomplete. You can update your personal data at any time by logging in to your account and updating your information, or by sending us an e-mail at contact@naked-underwear.com

Request erasure of your personal data

You may ask NAKED Underwear to delete your personal data where we have no good reason to continue processing it. Please note, however, that we may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you, where applicable, at the time of your request.

Request restriction of the processing of your personal data

You have the right to ask NAKED Underwear to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the accuracy of the data, or if you have objected to our use of your data, because we need to verify whether we have overriding legitimate grounds to use it. Where processing is restricted, we are permitted to retain enough information about you to ensure that the restriction is respected in the future.

Request the transfer of your personal data

You have the right to receive a copy of your personal data in digital format or to request the transfer of your personal data to another company. However, please note that this right only applies to automated data which you gave us permission to use or which we used to perform a contract with you.

Objecting to the processing of your personal data

You have the right to object to the processing of your personal data even where we believe we have a legitimate interest in processing it (as indicated above). For processing based on our legitimate interest, we may, in some cases, demonstrate compelling legitimate grounds which override your rights and freedoms. You do, however, have the right to object at any time, without having to give any reason, to the processing of your personal data for direct marketing purposes: we always act on such an objection.

Request human intervention in automated decision-making and profiling.

You have the right to request human intervention where we make automated decisions in the processing of your personal data. Where necessary, this type of processing is permitted, within the framework of our contract with you, provided that appropriate safeguards are in place or that your explicit consent has been obtained.

We respond to your request within one month of receiving it. This period may be extended by two months if your request is particularly complex or if you have made several requests; in that case, we will inform you within the first month, stating the reasons for the extension. We may ask you for specific information to help us confirm your identity and ensure your right to exercise any of the rights mentioned above. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to lodge a complaint

For any concern or complaint about the way we handle your data, please e-mail us directly at contact@naked-underwear.com.

Changes to this privacy notice

We may change the terms of this privacy notice from time to time. In the event of significant changes, we will post updates on our website or we will inform you by e-mail.

How to contact us

We welcome your comments and are happy to answer any questions you may have about your data.

You can send your questions, comments or requests for information to the data controller, MLPR, at contact@naked-underwear.com.

This privacy notice was updated on 2 October 2026.

The controller of your personal data is MLPR, a French simplified joint-stock company (société par actions simplifiée), whose registered office is located at 2 rue Beauvoisine, 76000 Rouen, France (RCS 908 188 675), operating the NAKED Underwear brand. For any question relating to your personal data: contact@naked-underwear.com.

 

Complaint to the CNIL

If, after contacting us, you consider that your rights over your data are not being respected, you may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL): www.cnil.fr, CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07. You may also bring it before the data protection authority of the European Union country where you reside or work (Article 77 of the GDPR).