borw Limited is a digital peer to peer marketplace that sought to match people that owned clothes (individuals and/or companies) with people interested in renting short-term or long-term clothes.
borw Limited (“Borw “, “We”, “Us”) is a controller of your personal data. We respect your data, and your privacy is important to us.
This Privacy Notice explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.
You have the right to object to some of the processing which borw carries out. More information about your rights and how to exercise these is set out in the “Your Rights” section of this notice.
An overview of how we use your data is here.
borw Limited’s registered office is 6 Williamson Close, SE100HX, London, UK.
1 – Summary of how we use your data and your rights
2 – Information we collect from you
3 – Information we receive from third parties
4 – How we use the information and the legal basis
5 – Data sharing
6 – International transfers
7 – Data retention
8 – Your rights
9 – Contact details
1. Summary of how we use your data and your rights
We use your data to provide and improve our products and services, including for marketing, research, feedback and inquiries, and for safety and security purposes. We also use your data when you enter competitions or awards that we organize.
We will use your data to comply with laws and regulations. We use your data to prevent and detect crime, such as fraud.
You have the right to object to some of the processing borw carries out. More information about your rights and how to exercise these is set out in the “Your Rights” section of this notice.
When you give consent, you are able to withdraw that consent at any time, for instance by emailing.
You can also email to exercise any other data rights, such as obtaining a copy of your data, correcting, deleting, or restricting how we use your data. Please see “Your rights” for more information.
You can unsubscribe from marketing communications at any time. To opt-out of direct marketing, including profiling for direct marketing purposes, you can either adjust the preference settings in your Profile section, or select “unsubscribe” in emails, or email.
2. Information we collect from you
We collect information when you rent any fashion item or use our services or enter our competitions or awards. This includes using our app, joining our “borw Membership”, or corresponding with us.
In particular:
We keep the information you give us directly such as contact details (name, email, postal address, and telephone number), pictures, and comments. We record and analyze app visits, details of your purchases, and where you take advantage of our promotions.
If you post information online about us or provide feedback, we keep a record.
If you contact us directly and complain or give feedback, receive compensation, or enter a competition, we will record details and all related information (including that you provide to us) such as emails, letters, phone calls, to our product customer information helplines including those operated by third parties.
3. Information we receive from third parties
We receive your information from other people in certain circumstances. This can happen when:
4. How we use the information and the legal basis
We are allowed to use your data only if we have a proper reason to do so such as:
To fulfill a contract, we have with you;
When it is in our legitimate interest;
When you consent to it; or
To comply with the law.
A legitimate interest is when we have a business or commercial reason to use your data. This involves us making an assessment of when we can rely on our legitimate interests. For more information on this assessment please contact
We have set out below how and why we use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.
We take information to communicate with you, check your identity, take payment, and provide products and services, including awarding loyalty points if you are a borw member.
To run our business and pursue our legitimate interests, we use your information.
Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our app, and services, developing new products and services, and telling you about them and conducting market research.
Further details of our legitimate interests:
To run and promote our business, we use your information:
To provide and improve our products and services, including “borw Membership” and to respond to you if you contact us.
To record call centre communications, including incoming and outgoing calls and emails, for staff training, quality improvement purposes, and establishing facts and to deal with concerns or complaints that you may raise.
When we monitor our mobile App, social media platforms such as Facebook and Twitter and online services and responses to email marketing. If you post comments online or in other media, we capture this information, use it to contact you, and use it to improve our products and services.
To run competitions and promotions and track which offers to seem of interest to you.
To understand you better as a customer by analyzing your transactions and other information you provide to us or which we learn through your interactions with us.
To send you emails including offers tailored to your perceived preferences where you are a borώ member and your preference settings permit this. We record which emails seem to be of interest to you. Based on your purchase history and membership usage, some borw members may be offered additional loyalty points.
To contact you where you provide us with market research feedback or pass this data to a third-party business partner of ours for panel market research analysis.
To administer and run our organized awards, and to promote the awards through the publishing of winners’ details.
To prevent, investigate, and/or report fraud, terrorism, misrepresentation, security incidents or crime, including where we are required to do so by law, we:
Monitor borw accounts, record call centre communications, and emails.
Use other organisations to check the validity of the credit or debit card details you use to pay.
To comply with the law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:
We keep records and pass your data to Whitbread Group PLC and our insurers when necessary.
We monitor, and record call centre communications, including incoming and outgoing calls and emails.
We verify your identity in certain circumstances.
If you give us consent, we:
Use cookies or similar technologies on the app and in marketing emails, including analytic cookies.
Through the settings on your device, send you to push notifications through the app.
Use data for other purposes where we explain that purpose when we ask for your consent.
When you give consent, you are able to withdraw that consent at any time by contacting us, for instance by emailing If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.
Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time.
You can opt-out of marketing by selecting “unsubscribe” in emails or by adjusting the preference settings on your account or by emailin
When the law requires us to process your data we will do so. This can include:
Legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement.
When you exercise your rights under data protection legislation, including when you ask to unsubscribe from our marketing communications.
5. Data Sharing
We use third-party providers for the following services:
Sending promotional offers
Customer feedback surveys
Online order fulfillment, including the management of queries, concerns or complaints related to your order(s)
Data analysis to enable us to optimize our services (including locations and products)
Loyalty scheme platform
Insurance
IT development, support, maintenance, and hosting.
Payments’ processing to enable you to pay by credit or debit card.
Administration of our competitions and awards.
If our business is to be integrated with another business or sold, your details would be shared with our advisers and any prospective purchaser’s advisers. Your information could be passed to the new owners.
Personal data may be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.
6. The International transfers
Sometimes we send or store your data outside of the European Economic Area (the EU plus Iceland, Lichtenstein and Norway) (‘EEA’). For example, to follow your instructions, comply with a legal duty or to work with or receive services from our service providers whom we use to help run your accounts and our services.
If we do transfer information outside of the EEA, we will make sure that it is protected by using one of these safeguards:
Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Some countries have been deemed adequate by the EU.
Put in place a contract with the recipient that means they must protect it to the same standards as the EEA or use other mechanisms and measures to achieve adequate protection. We also may use the Standard Contractual Clauses published by the EU.
Transfer it to organizations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
Binding corporate rules. These are internal rules adopted by group companies to allow international transfers of personal data to entities within the same corporate group located in countries that do not provide an adequate level of protection.
7. Data retention
We keep your data to enable us to fulfill our contract with you or to provide services, whilst you are an active user of our app, where required by law or to protect legal rights. We always look to keep your data for the minimum time in line with data protection principles and our processes. For example, we keep:
Information on borw members as follows.
If you register but do not collect and/or use any points using your app within 12 months, your registration points will expire, and we will delete your borw account information at that point.
Records of payment information in line with tax law and audit requirements.
Customer feedback and correspondence with our customer services teams for up to 4 years afterward, depending on the nature of the interaction and any applicable law, such as health and safety. This enables us to respond to any questions or complaints.
Information to maintain records according to rules that apply to us.
If you unsubscribe from marketing communications, we keep a record of this request indefinitely to ensure we do not send you direct marketing again.
We may keep your data for longer if we cannot delete it for legal, regulatory, or technical reasons.
8. Your rights
You have rights over your personal data.
You can:
ask for a copy of your information;
ask for information to be corrected;
ask for information to be erased or deleted;
ask for us to limit or restrict processing;
object to us processing your data, in particular, where we do not have to process the data to meet a contractual or other legal requirement and in relation to the processing for direct marketing purposes, including profiling for direct marketing purposes;
ask us to send you a copy in a structured digital format or ask for us to send it to another party.
Some rights, however, may be limited. We may be obliged by law or regulation to keep information. We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data. On occasion, there may be a compelling legitimate interest to keep processing data.
If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below. To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data.
You have a right to complain to an EU data protection authority. This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”).
9. Contact details
To exercise any of your rights or to withdraw consent you can email
To discuss or change your borw account details, including preference settings, you can log into ‘My Account’ and go to (account details) and Contact Preferences or contact customer services at.
For any queries relating to data protection, please contact borw’s Data Protection Officer by email at.
We may change or update this notice from time to time. We will communicate these as appropriate – for example, by updating our app or, where legally required, by actively telling you about the changes.