Privacy policy

Effective date: June 1, 2022


The Naked Room (collectively referred to as "We" or "Our" or "Us") is committed to protecting your privacy. This privacy policy (the “Privacy Policy”) governs the way we collect and use your personal data (as described below) both online and onsite, including at and its subdomains, websites, and social media platforms accessed through your mobile devices as well as downloadable mobile applications. Collectively, we refer to our websites, apps, social media pages, emails, and offline business interactions, including onsite interactions, as the “Services”.


What Is Personal Data?

Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


Personal Data That We Collect

We may process, collect, use, and store different types of Personal Data. We will never collect any unnecessary Personal Data from you and do not process your information in any way, other than as specified in this Privacy Policy. The kinds of personal data we collect and process may include the following:

  • Name

  • Postal address (including billing and shipping addresses)

  • Telephone number

  • Email address 

  • Payment card data

  • Transaction history

  • Communication records (telephone conversations, online contact, contact via email address)


How We Collect Personal Data

We collect Personal Data in the following ways:

  • When you visit our website.

  • When you visit our events.

  • When you fill in contact forms on our website.

  • When you subscribe to our newsletter as offered on our website.

  • When you contact us via phone, email, or otherwise provide Personal Data directly to us.

  • When you place an order or make a purchase.

  • We may receive your Personal Data when you 'like', ‘follow’ or interact in another way with our pages on Facebook, LinkedIn, Instagram, Twitter, YouTube and other social media platforms.


How We Use Personal Data

We take your privacy very seriously and will never disclose, share or sell your data without your consent, unless required to do so by law. The purposes and reasons for collecting and processing your Personal Data are detailed below:

Performance of contract:

  • To enter into, perform, manage, administer and enforce the Services including any related contract and fulfill your order.

  • To share Personal Data with our service providers and partners, to provide the Services to you.

  • To manage payments of fees and charges.

  • To notify you about changes to all applicable terms of the services or use, and our Privacy Policy.

Legitimate interest:

  • For statistical and market analysis and research.

  • For training and quality assurance.

  • To analyze, enhance and improve our services, systems and processes.

  • To share your Personal Data with people or other relevant bodies to support our business systems and processes or to comply with legal or regulatory requirements.

  • To monitor, check, and record communications between you and us.

  • To occasionally send you marketing information and newsletter.

Compliance with legal or regulatory obligations:

  • For compliance with legal and regulatory requirements.


Your Rights

You have the following rights in relation to the use of your Personal Data. Under certain circumstances, you have the right to:

Request access: is commonly known as a "data subject access request". This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction: this enables you to have any incomplete or inaccurate Personal Data we hold about you corrected, though we may need to verify the accuracy of the new Personal Data you provide to us.

Request erasure: this enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing: you have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to our processing. For further information about the right to object please see the "Right of objection" section below.

Request restriction of processing: this enables you to ask us to suspend the processing of your Personal Data in the following circumstances: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Withdraw consent at any time: applicable only where we are relying on your consent to process your Personal Data. Any withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Right of objection: you have the right to object to our use of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have legitimate grounds to process your information which override your rights and freedoms.

If you would like to exercise any of these rights, please contact us (See the "Questions and Concerns" section below).

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.


Sharing And Disclosing Your Personal Data

We do not share or disclose any of your Personal Data without your consent, other than for the purposes specified in this Privacy Policy or where there is a legal requirement. We use third-parties and our affiliates to provide the services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this Privacy Policy, the data protection laws and any other appropriate confidentiality and security measures.


Third-Party Payment Services

The Services may provide functionality allowing you to make payments to Us using third-party payment services. When you use such a service to make a payment to us, your Personal Data will be collected by such third-party and not by Us, and will be subject to the third-party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for this third-party’s collection, use, and disclosure of your Personal Data.


Safeguarding Measures

  • We take your privacy seriously and take every reasonable measure and precaution to protect and secure your Personal Data.

  • We have put in place appropriate security measures to prevent Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

  • We have put in place procedures to deal with any suspected data security breach or incident and will notify you and any applicable regulator of a suspected breach or incident where we are legally required to do so.

  • If we share Personal Data with third parties, we require that they take appropriate security measures to protect Personal Data. We do not allow third party service providers to use Personal Data for their own irrelevant purposes, they are only allowed to use and process your Personal Data for specified purposes and in accordance with our instructions.


International Data Transfers

We may transfer Personal Data outside the EU. We will ensure that the Personal Data is protected by appropriate safeguards, such safeguards include at least one of the followings:

  • The destination country has been deemed to provide an adequate level of protection for Personal Data by the European Commission.

  • The service provider is bound by relevant and specific contractual obligations required under applicable data protection laws.


Consequences of Not Providing Your Personal Data

You are not obliged to provide your Personal Data to us. However, as this information is required for us to provide you with our services or respond to your inquiries, we will not be able to offer some or any of our Services without it.


How Long We Keep Your Data

We only retain Personal Data for as long as is necessary. In retaining Personal Data, we consider:

  • The duration of the purposes that we collected it for, importantly the duration that we are obliged to provide the relevant services.

  • Fulfilling and managing our relationship with you.

  • We also retain Personal Data for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and guidance.


Age Limitations

To the extent prohibited by applicable law, we do not allow use of our Services by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with Personal Data, please contact us, and we will take steps to delete such information.


Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict our use of your Personal Data and (ii) lodge a complaint with your local data protection authority.


Links To Other Websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over those websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should be cautious and look at the policy applicable to the website in question.


Questions And Concerns

In case of any questions or concerns, please contact our Data Protection Officer by email at:


Changes To This Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, We will provide additional notice via email. If you disagree with the changes to this Privacy Policy, please contact our Data Protection Officer at