This notice relates to the Varley Group (“we”, “our”, “us”). We operate in the United Kingdom as Varley Clothing Limited (registered in England and Wales with company number 07827645), in the European Union as Varley Clothing B.V (registered in the Netherlands with Chamber of Commerce number 83328939) and in the United States as Varley Clothing Inc. (registered in Delaware with entity number 3803955), with a parent company Varley International Holdings Limited (registered in England and Wales with company number 12075176).
This privacy notice will inform you about how we collect and use your personal information. It will also tell you about your privacy rights and how the law protects you.
Please note:
this policy does not form a contract between an individual and us;
we do not use automated processing, including profiling, which produces legal effects concerning you or significantly affects you. We work with Insider (paragraph 4) but the effects of that processing are to only enhance user experience of our retail offering;
to the extent necessary we will share personal data across the Varley Group;
we have CCTV at our stores. That policy is separate and available on request.
The specific privacy rights under the law vary depending on where you are located. We have indicated in this notice where there are rights and obligations conferred under the law of particular jurisdictions.
If you are a UK/EEA data subject, the main sections of this privacy notice apply to you, together with the Further information for UK and EEA data subjects (see section 8).
Although we do not have an establishment in the European Economic Area (“EEA”), we have for the time being not appointed an Article 27 Representative as our processing of the personal data of EU citizens does not meet the thresholds set out in Article 27.
If you are a US resident, please see our Additional notice for US residents (see section 9).
For the purposes of EU and UK data protection law, we are a “controller” of your personal information. This means that we make decisions about how and why your information is used and have a responsibility to make sure your rights are protected when we do so.
1. What does this notice cover?
2. What personal information do we collect?
3. How is your personal information collected?
4. Sharing your information
5. Where is your information accessed?
6. How long do we keep your information?
7. How we keep your personal information safe
8. Further information for UK and EEA data subjects
9. Further Information for US Residents
This notice describes how Varley Group uses your personal information when you visit and submit information through our websites.
We operate the following websites:
https://uk.varley.com for our customers in the United Kingdom and the rest of the world.;
https://eu.varley.com for our customers in the European Union; and
https://www.varley.com for our customers in the United States, the Americas
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information.
If you have any questions, please contact us using the details in the Who we are and how you can get in touch section.
When we refer to “personal information”, we mean information that can be used to identify, or can be directly linked to, a person. This can be disclosed to us on our website, via third parties such as Epsilon or during visits to our stores. We collect personal information about you, including:
Sensitive Personal Information
Under data protection legislation, certain personal information is considered more ‘sensitive’ (e.g., information relating to race, religion, political affiliation and health). This is also known as ‘special category data’. We do not collect any sensitive personal information about you. We do not knowingly collect sensitive personal information through our websites except for account sign-in information and other information needed to provide requested products or services. We do not use or disclose sensitive personal information for purposes that require us to provide a right to limit under the California Consumer Privacy Act.
We collect and retain personal information about you that you have given us in different contexts, for example:
Direct interactions such as where you create an account with us, use our website, subscribe to our newsletter and/or correspond with us by post, phone, email or otherwise.
Third parties’ services we receive personal information from analytics providers such as Google Analytics or through cookies. We also receive data from Epsilon and/or Path2Response LLC (see below) with contact details of consumers who Epsilon and/or Path2Response LLCconsider would be interested in receiving our House Brochure.
We work with service providers, contractors, business partners, and other third parties that may receive personal information for the purposes described in this notice. Some service providers and contractors process personal information on our behalf to provide services such as website hosting, payment processing, order fulfilment, customer support, marketing communications, analytics, security, and cloud storage. Other third parties may receive personal information for advertising, marketing, personalization, or other purposes described below. We assess third parties and enter into appropriate contractual arrangements where required by applicable law
Advertising and online activity. We may disclose identifiers, device and internet activity, commercial information, and related information to advertising, analytics, personalization, and social-media partners. Some of these disclosures may constitute a “sale” or “sharing” of personal information under California law, even though we do not receive money in exchange for the information. California residents may opt out through the Do Not Sell or Share My Personal Information link in the footer of our U.S. website. We also process qualifying opt-out preference signals, such as Global Privacy Control, as required by applicable law.
In particular, these are some of the third party service providers to whom we may disclose your personal information:
to Epsilon Abacus (registered in the UK as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The Abacus Alliance helps participating retailers to understand the behaviour and preferences of their customers. Therefore, you may be contacted by a third party retailer. You are free to opt out of that marketing. You can learn more about how Epsilon Abacus processes your personal information in their privacy notice, which is available here.
to Insider a company that uses AI-driven segmentation, analysis of browser behaviour, predictive modelling, and automation to personalise Varley’s homepage and website content. Offering each browser bespoke homepage content enhances user experience and optimises engagement. You can learn more about how Insider processes your personal information in their privacy notice, which is available here.
to Attentive, a company we use in the UK and USA only to provide SMS, MMS and RCS text messaging services to you, sent using an automatic telephone dialing system and/or AI-assisted technology. We use your information (email, telephone number and message history) to deliver, analyze, maintain and support the messaging service. We may also use your information to enhance the messaging service features and customize and personalize your experiences. Attentive acts as our service provider and data processor of your information in accordance with this Privacy Policy, and Attentive’s Privacy Policy, which is available here.
We may also share information with any other authorized third-party vendor and service providers who provide services to us for a variety of business purposes, such as payment processing, customer services, e-mail deployment, advertising and marketing, security and performance, processing or fulfilling orders and transactions or to a corporate affiliate in the Varley Group.
As part of our business we may have to share personal data in the following circumstances:
1. to government authorities and/or law enforcement officials if required for the purposes above, if required by law or if required in order to protect our legitimate interests (e.g. for tax regulation purposes);
2. as part of a sale of shares i.e. a merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
3. with our professional advisors, lawyers, accountants and auditors;
4. in connection with any or potential legal, litigation or regulatory process.
Our websites cater for customers all around the world (in particular in the UK, US and EU). We have dedicated staff in the UK and the US.
Varley Group has retail outlets in the UK and US.
We will only keep your personal information for as long as we need it to achieve the purposes for which we collected it, to comply with our legal and regulatory obligations, to exercise our legal rights and to protect ourselves from legal claims.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
To protect your privacy, we will make sure your personal information is kept securely and disclosed only to relevant organisations or representatives who need to access it to perform their roles. We use appropriate organisational, technical and administrative measures to protect personal information within our organisation. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Who we are and how you can get in touch section below.
This section is part of the privacy notice as it applies to UK and EEA data subjects.
Legal basis for data collection
We will only use your personal information when the law allows us to. Usually, we will use your personal information in the following circumstances:
where we need it to perform a contract we are about to enter into or have entered into with you;
where it is necessary for our ‘legitimate interests’ (or those of a third party) and your interests and rights do not override our interests;
where you have given us your consent;
where we need to comply with the law.
When we refer to our ‘legitimate interests’, we mean our ability to:
provide our goods and services to you;
communicate with your purchases from our websites or retail stores, about your Varley account or in response to a query from you;
undertake marketing and build marketing strategies which may involve assessing the effectiveness of social media platforms and other marketing solutions; and
study how our websites is used and make improvements to it.
The information below sets out in detail the types of data we collect and the purposes and legal bases for processing the data. It applies where we are processing data of individuals in the UK, EEA and US.
Data we collect
Direct marketing
Where you have provided consent, we will contact you by e-mail to send you our newsletter and keep you updated on products and features that you may be interested in. We may also contact you by e-mail if your information was provided to us by the Refer a Friend Programme, via Wishlist or where you have provided your birth date to receive a birthday gift code We may also contact you occasionally by e-mail and/or post to invite you to special in store retail events.
You can opt-out from receiving our marketing communications or update your contact preferences at any time by clicking the unsubscribe button on the bottom of any email from us or by writing to us at support@varley.com.
Although the majority of our marketing uses email we recognise that some prefer other communication methods. When you register you can agree to receive communication by SMS. We also publish a House Brochure which we are very happy to post. It is important for us that our community lets us know how we can keep in contact. Our website has these communication options so please update accordingly.
International transfer of data and personal information
Where we need to share your personal information with people or entities outside the UK or EEA, such recipients might be subject to data protection laws that offer less protection than European data protection law. Where this is the case, we we use an appropriate transfer mechanism, which may include the EU Standard Contractual Clauses, the UK International Data Transfer Addendum, the EU-U.S. Data Privacy Framework, or the UK Extension to the EU-U.S. Data Privacy Framework, as applicable. As referred to above where necessary we conduct due diligence on third parties regardless of where they are located.
Cookies
Our websites use cookies to enhance your experience while using those sites. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For further details about our use of cookies, please visit our Cookie Notice here.
Your data protection rights
If you are in the UK or the EEA, you have the right:
to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully;
to correct, delete or restrict (stop any active) use of your personal information;
to request the transfer of your personal information to you or to a third party in certain circumstances. We will provide your personal information to you (or the third party you have chosen) in a structured, commonly used, machine-readable format;
to object to the processing of your personal information in certain circumstances;
to withdraw consent where you have given us consent to use your personal information. If you withdraw consent we will stop using your personal information immediately, unless we are required to process it for a different purpose (for example, the information is necessary to comply with a legal obligation). If you decide to withdraw your consent, this will not affect the lawfulness of our processing before your consent was withdrawn;
to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
To exercise any of these rights, or to make a complaint to us, you can get in touch using the details set out in the Who we are and how you can get in touch section below. Please note:
1. that we are obliged to verify the credentials of any data subject who exercises these rights. This is to prevent unlawful disclosure of personal data to the wrong recipient;
2. we may reach out to you to understand exactly what data you need and why. This enables you to more promptly receive your data and our analysis of why we are processing it;
3. there are circumstances where we can reject the exercise of these rights or demand that you pay a reasonable fee.
4. Please note that regarding data subject access requests, we may refuse to:
a. provide all or some of the requested information and, depending on the circumstances;
b. comply at all if the request is manifestly unfounded or manifestly excessive. Manifestly unfounded includes making the request to further or escalate any dispute you may have with us. The right of access exists to allow you to verify our compliance with GDPR.
Who we are and how you can get in touch
Varley Clothing Limited is a company incorporated under the laws of England and Wales, whose registered address is at 101 New Cavendish Road, 1st Floor South, London, United Kingdom.
Varley Clothing B.V is a company incorporated under the laws of the Netherlands, whose registered address is at Herengracht 420, 1017BZ Amsterdam, the Netherlands.
Varley Clothing Inc. is a corporation incorporated under the laws of Delaware, whose registered address is at 860 S. Los Angeles Street, Suite 513, Los Angeles California 90014, United States.
If you have any questions about this privacy notice, including any requests to exercise your legal rights outlined above, please contact us at support@varley.com, or via our Live Chat.
Individuals in the UK and the EEA have the right to make a complaint at any time to the local data protection supervisory authority. For details of supervisory authorities in the EEA see here. For the UK’s data protection authority, contact the Information Commissioner’s Office (ICO) here. We would appreciate the chance to deal with your concerns before you approach the relevant supervisory authority. So please contact us support@varley.com in the first instance.
To opt out of the sale or sharing of personal information, use the Do Not Sell or Share My Personal Information link in the footer of our U.S. website.
This section applies to you only if you are a resident of a U.S. state that grants privacy rights to consumers and we meet the relevant applicability thresholds under those laws (e.g., revenue/transactional thresholds, volume of data processed, or nature of processing activities). If you are not sure whether your state has applicable privacy laws or whether these laws apply to you, please review the resources provided by your state government or consult a legal professional.
Depending on where you reside, you may have some or all of the following rights with respect to your personal information:
To exercise any of these rights, or to make a complaint, please get in touch using the details set out in the Who we are and how you can get in touch section below. Please note:
Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We may require proof of authorization and direct verification of your identity with us (depending on the type of request and applicable law).
We will not discriminate against you for exercising any of the rights described above. Unless permitted by law, we will not deny you goods or services, charge you different prices or rates, or provide a different level or quality of service just because you exercised your rights. To opt out of the sale or sharing of personal information, use the Do Not Sell or Share My Personal Information link in the footer of our U.S. website. We will also treat qualifying opt-out preference signals, including Global Privacy Control, as valid requests to opt out where required by applicable law. We do not require you to create an account or verify your identity to submit an opt-out request.
Additional Disclosures for California Residents:
During the preceding 12 months, we have collected the categories of personal information described in the What personal information do we collect? section above from the sources described in How is your personal information collected? We use that information for the business and commercial purposes described in this notice and disclose it to the categories of recipients described in Sharing your information.
We do not sell personal information for money. We may disclose identifiers, device and internet activity, commercial information, and related information to advertising, analytics, personalization, and social-media partners in ways that may constitute a “sale” or “sharing” under California law. California residents may opt out through the Do Not Sell or Share My Personal Information link in the footer of our U.S. website or through a qualifying opt-out preference signal.
We do not knowingly sell or share the personal information of consumers under 16 years of age.
We do not use or disclose sensitive personal information for purposes that require us to provide a right to limit under the CCPA.
We retain personal information only for as long as reasonably necessary for the disclosed purposes, taking into account the criteria described in How long do we keep your information?
We offer eligible first-time customers a 10% discount on an eligible first online order when they sign up to receive our newsletter. This program may constitute a financial incentive under California law because it involves the collection and use of personal information, including your email address, marketing preferences, and information concerning the issuance and redemption of the promotional code. Participation is voluntary, and you may withdraw at any time by unsubscribing from our marketing emails. For the program’s material terms, the value assigned to the personal information involved, and the method used to calculate that value, please review our [Financial Incentive Notice].
California’s Shine the Light law permits California residents to request certain information concerning disclosures of personal information to third parties for their own direct-marketing purposes. To submit a request, contact us at support@varley.com.
We will not discriminate against you for exercising a privacy right, except as permitted by applicable law.
Last Updated 16 September 2026
