Privacy Policy


Welcome to the Forefront Merchandise (International) LTD 's privacy policy.

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

Forefront Merchandise (International) LTD is a company incorporated and registered in England and Wales under company number 11584094 and whose registered office is at Apartment 6 Avening Mill Mill Lane Avening TetBury Gloucestershire GL8 8PD.

Forefront Merchandise (International) LTD collects uses and is responsible for certain personal information about you. When we do so we are regulated under the Data Protection Act 2018 (Data Legislation) and we are responsible as ‘controller’ of that personal information for the purposes of the Data Legislation.


We collect the following personal information when you provide it to us:


Type of data

Lawful basis for processing including basis of legitimate interest

To respond to your enquiry to us received through contact us page on the website or other social media platforms such as Facebook

  • Identity information
  • Contact details
      • To provide you with answer to your query

To register you as our member

  • Identity information
  • Contact details
  • Financial information
  • Marketing and Communications


      • Performance of a contract with you
      • Necessary for our legitimate interests (to collect membership fees due to us)

To process and deliver your order including:

      1. manage payments, fees and charges
      2. collect and recover money owed to us
      3. managing returns and refunds
  • Identity information
  • Contact details
  • Financial information
  • Details of other transactions with us
  • Marketing and Communications
      • Performance of a contract with you
      • Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  1. notifying you about changes to our terms or privacy notice
  2. asking you to leave a review or take a survey
  3. to send you promocode if you are a member
  • Identity information
  • Contact details
  • Profile information concerning your purchasing history
  • Marketing and Communications
      • Performance of a contract with you
      • Necessary to comply with a legal obligation
      • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

  • Identity information
  • Contact details
  • Profile information concerning your account and purchasing history
  • Details of your usage of our website, goods and services
  • Marketing and Communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity information
  • Contact details
  • Technical IT data
      • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
      • Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  • Technical IT data
  • Details of your usage of our website, goods and services

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

If you subscribe to become a member, we will use your personal data to identify goods or services that may be of interest to you and send you promotional codes of certain identified good and/or services.

If you are not a member but, in the event, that we have your consent, we may use your personal data to make suggestions and recommendations to you about goods or services that may be of interest to you. If you would like to unsubscribe from any emails from us, you can also click on the ‘unsubscribe’ button at the bottom of the email.

We do not seek to collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

This website is not intended for children and we do not knowingly collect data relating to children.


Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


We also obtain personal information from other sources as follows:

  • Automated technologies or interactions. As you interact with our website, we may automatically collect certain technical data (for example, browser type and version, time zone setting and location, browser plug-in types and version, operating system and platform and other technology on the devices you use to access this website) about your equipment, browsing actions and patterns. We collect this data by using cookies, web beacons and other similar technologies but do not collect any personal data from these cookies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy here for further details
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  1. analytics providers such as Google based outside the EU;
  2. people who refer you to us, including existing subscribers/members.


We may share your name, home address and other contact details with our third party suppliers.  This data sharing enables us to bring in the right suppliers to deliver the services we supply to you.  We will share your financial information with our third party who meet the requirements of Payment Card Industry Data Security Standard. This data sharing enables us to process your payments securely in line with the industry acceptable standard. Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.


We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements – we keep your file containing any personal data we have collected from you (save for payment details which are deleted within 35 days after use) for up to 7 years after the date of the relevant order or after you cease to become a member.


To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • with our suppliers, and customer support located outside the EEA – for example, we may provide your address details to a supplier based outside the EEA (for example, in the USA or China; and
  • if you are based outside the EEA.

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. We will use our best endeavours to ensure the transfer complies with data protection law and all personal information will be secure.

We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries


Under the Data Legislation you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information
  • access to your personal information and to certain other supplementary information that this privacy notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on the ICO’s website concerning individuals’ rights under the Data Legislation.

If you would like to exercise any of those rights, please:

  • email, call or write to us (our contact details are at the bottom of this privacy notice)
  • let us have enough information to identify you
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at or telephone: 0303 123 1113.

Changes to this privacy notice

This privacy notice was published on 8/19/20.

We may change this privacy notice from time to time, when we do we will inform you via email.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to or write to Apartment 6 Avening Mill Mill Lane Avening TetBury Gloucestershire GL8 8PD