Privacy Policy


Last updated: 24 January 2022


1.1 The website (the Site) is operated by Complex Creative Ltd (“we”, “us”, “our”), a company incorporated in England and Wales under company number 123447472. Our registered office is at 3.01 E1 Studios, 7 Whitechapel Road, London, E1 1DY. 

1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).

1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.

1.4 This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made. 


2.1 If you have any concerns or would like further information about our use of data or this policy in general, you can contact our Sabrina Chevannes at 


3.1 We collect, store and use the types of personal data set out in the table at the end of this policy.


4.1 We will use your personal data for the purposes set out in the table at the end of this policy.


5.1 When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.

In addition, where necessary, your personal data may be shared:

5.1.1 with parties who provide products or services to us, such as software development, user analytics, email services, payment processing, advertising, user notification and feedback functionality, data insight companies etc.

5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.


6.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.


7.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.

7.2 Depending on the reason we have your personal data, you have a right to:

7.2.1 access the personal information we hold about you (commonly known as subject access);

7.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete; 

7.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 7.5; 

7.2.4 restrict how we use your personal information, in certain circumstances; 

7.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and

7.2.6 where we have asked for your consent to process your data, to withdraw this consent.

7.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.

7.4 If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above. 

7.5 Your right to object 

You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.

7.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website:


8.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.


9.1We process your personal data in accordance with the following principles: 

9.1.1 we process your personal data lawfully, fairly and in a transparent way; 

9.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;

9.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed; 

9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;

9.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and

9.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage. 

9.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.  

9.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.


10.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.

10.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:

10.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.

10.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.

10.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.

10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.

10.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.

10.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.


10.1 Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:

(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here:  Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:


The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.

Category of personal dataPurpose of processingLawful basis for processingRetention period
Name and contact details   To deliver your purchases to youTo send you order updatesFor fraud prevention and detection To contact you with information, newsletters and marketing materials about our products and services Performance of contract Compliance with legal obligation Consent  For six years since you gave consent, or until you withdraw consent if earlier 
Payment information To take payment and give refundsFor fraud prevention and detectionPerformance of contract Compliance with legal obligation For six years since you last logged on to the Site
Saved items in online shopping basketTo sell products and services to youPerformance of contractUntil you complete your order or for seven days after the item is saved 
Purchase history To provide customer service and support and handle returns To  find out what products you likePerformance of contract Consent For three years since you gave consent, or until you withdraw consent if earlier 
Browser, device and Site usage information To improve the SiteTo protect the Site against fraudTo set default options for you, such as language and currencyPerformance of contract Legitimate interest in maintaining our SiteFor three years since you last logged on to the Site 
Information from linked accounts To enable you to log into the Site simply without having to create a specific accountLegitimate interest in providing high quality customer serviceFor three years since you last logged on to the Site 
Responses to surveys, competitions and promotions To run the survey, competition or promotionPerformance of contract Legitimate interest in administering and/or improving our products and services generallyFor six years 
Customer comments and product reviews  To improve our products and servicesWhere relevant, to establish, exercise or defend legal claimsPerformance of contract Legitimate interest in dealing with complaints or claims and improving our products and/or services generally For six years 
Information generated in the course of the use of our products and services For internal research and development purposesTo improve and test the features and functions of our SitePerformance of contract Legitimate interest in maintaining our Site and improving our products and/or services generally For four years
Information collected through cookies and similar technologiesTo conduct and store site usage analytics, statistical and trend analysis and market researchTo generate customer profiles to facilitate marketing initiativesConsentFor three years since you gave consent, or until you withdraw consent if earlier