1. ABOUT THORA AND THIS PRIVACY POLICY

THORA ("we" or "us") takes all necessary measures to make sure that personal data concerning our customers, business partners and visitors to our website is being processed by us in a lawful, fair and transparent manner.

When you use our various services, i.e. when you purchase our products or visit our website, https://www.thorabv.com (the "Website"), we collect and process your personal data. Consequently, THORA is the data controller of your personal data.

This privacy policy describes the processing activities carried out by us and explains and clarifies your rights regarding the processing of your personal data and how you may exercise those rights. It is important that you read and understand this privacy policy before you use any of our services.

2. WHICH CATEGORIES OF PERSONAL DATA DO WE COLLECT AND WHY?

2.1 ORDERS MADE VIA OUR WEBSITE

In connection with an order of our products, you provide us with personal data such as your name, e-mail address, telephone number and address. When making payments via the Website you need to provide additional information, such as debit or credit card information or, if you wish to pay by invoice, your personal identification number. We process the collected information for the purpose of administering your order, including to communicate with you regarding the order (e.g. for support purposes in the event of any issues with the delivery of the items). Such processing which relates to the purchase is necessary for us to carry out in order to fulfill our contractual obligations in relation to you.

2.2 USE OF THE WEBSITE AND NEWSLETTERS

Based on your consent, which you provide when subscribing to our newsletter, we may process your personal data, e.g. your name and e-mail address, in order to provide you with relevant offers, invitations and news. These e-mails contain information relating to our products and services, such as exclusive offers, collection launches, events or similar. In order to communicate with you as described, we may process personal data regarding your order history, order value, payment method used and from which country you accessed our Website.

In connection with your giving of consent, you will have to confirm that you have read this privacy policy and that you consent to the processing of your personal data as described herein. If you no longer wish to receive our newsletter, you can unsubscribe at any time, by unclicking the "subscribe" checkbox in personal info in my THORA account of any of our newsletters.

2.3 DIRECT MARKETING

By the use of cookies and similar technologies, such as pixels, we may collect visitor statistics, including content and pages visited, referring website and searches made on our Website. We use the data to personalise the online user and shopping experience, and to develop, test and to continuously improve our Website. Furthermore, the information collected may be used to provide you with marketing when you visit other websites than our own. By accepting our use of cookies on the Website, you consent to our processing of the personal data collected through cookies. For more information regarding our use of cookies and similar technologies, please see our Cookie Policy available here.

2.4 SURVEYS, STATISTICS AND BUSINESS DEVELOPMENT

We may process your name, e-mail address and order history to carry out customer surveys, based on our legitimate interest of obtaining further knowledge of how our customers view us and our products and services. The individual results of the surveys are only retained during such period that it takes for us to compile the result on an aggregated level and is thereafter deleted.

Furthermore, we may process personal data such as your location, categories of products purchased and information regarding payment methods used on our Website, for statistical purposes, e.g. in order to see how many individuals in a certain age range have purchased our products. This statistical information may be used for business development purposes and the processing of your personal data is necessary for our legitimate interest of continuously improving our business and providing new products and services.

2.5 INFLUENCERS

In addition to the above, we collect publicly available information about influencers which we may engage in marketing campaigns, based on our legitimate interest of assessing possible marketing strategies. If an individual influencer is contacted by us and if we decide to engage the influencer, we may process the personal data of the influencer to the extent necessary for the entering into and the performance of the contract between us and the influencer.

3. RETENTION OF PERSONAL DATA

We take all reasonable steps to ensure that your personal data is processed and stored securely. Your personal data will never be stored longer than permitted by applicable law or longer than necessary to fulfil the above stated purposes. If you are a customer of THORA, your personal data will be deleted no later than two years after your last purchase or after the expiry of any guarantees which may apply to purchased products.

In addition, we retain information regarding your order and transaction, including any support related communication, should any issues arise with the delivered products. Information regarding your purchase will be retained for accounting purposes in accordance with applicable accounting legislation.

4. WHO HAS ACCESS TO YOUR PERSONAL DATA?

Personal data regarding our customers is an important part of our operations and we do not sell the personal data to anyone else. We may only transfer personal data as described below. We always observe great caution when transferring your personal data and your personal data is only transferred in accordance with this privacy policy and after taking appropriate security measures.

Third party payment providers: We use third party payment providers to process payments via the Website. In order to administer the order and for the performance of the agreement between you and us, we will disclose information regarding your name, address, order information, debit or credit card information and device used for purchase to the third-party payment provider. Such third party payment providers may process your personal data as data controllers and will, consequently, have their own privacy policies. Any customer who sends information to or through such third parties should review the third parties' privacy policies before any personal data is transferred to them.

• Delivery and storage partners: To process orders, we use third party delivery service and storage partners. For the purposes of administering the order and to fulfil our contractual obligations in relation to you, we will share your personal data, including your name, address and telephone number in addition to order information with our delivery and storage partners.
• Business transactions: If all or part of our operations are sold or integrated with any other business, operation or company, your personal data may be disclosed to our advisors, potential buyers and their advisors, and be transferred to the new owners of the operation.
• Marketing partners: Based on your consent, we may transfer your personal data to our marketing partners for the purpose of giving you access to targeted information and offers about products and services. The third-party service providers that we engage are contractually obligated to only process your personal data in accordance with our strict instructions and may not use your data for their own purposes. Additionally, they are obligated to implement technical and organizational security measures to protect and safeguard your personal data.
• Other third parties: Finally, we may disclose your personal to other third parties than outlined above in order to fulfil our legitimate interest of complying with applicable law and regulations and lawful regulatory requests or relevant orders from competent courts and public authorities and to establish, exercise and defend legal claims.

5. YOUR RIGHTS

You have the right to request information about the personal data concerning you that we are processing and how it is being used by contacting us in writing on the contact details provided below. You are also entitled to request correction of incorrect, incomplete or ambiguous personal data concerning you by contacting us. For the protection of your privacy and your personal data, we may require that you identify yourself in connection with our assistance.

In accordance with applicable data protection laws, you also have the right to request that your personal data shall be erased or that the processing of your personal data shall be restricted. In certain situations, you also have the right to object to the processing of your personal data and request that your personal data must be transmitted in an electronic format.