1.0 Introduction

ThruDark was born out of our constant requirement for the best clothing and equipment to assist us in this ‘Endeavour Through Adversity’.

The brand name ‘Thru-Dark’ represents the endurance through difficult situations experienced not only by ourselves and our colleagues but to all those who encounter hardship in their own lives.”

We at Thru Dark take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).

This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 15 of this privacy notice.

2.0 Why we Collect your personal information

We collect your personal data for one of the following purposes:
Here is a more detailed breakdown of what we use your personal data for:
To create and manage your personal account at Thru Dark
To process your orders and return via our online services
To send text message notification of delivery status
To contact you in the event of any problems with the delivery of your items
To answer your queries and to inform you of new or changed services
To send marketing offers
To make analyses in order to provide you with relevant products
To analyse data in order to provide personal recommendations
We do not conduct any profiling or rely on any significant automatic decision making in relation to the personal data which we process (see Section 12 of this Privacy Notice).

3.0 Lawful Basis Of Processing Information

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

The data subject (you) has given consent to the processing activity taking place.
The processing is necessary for the performance of necessary for the performance of our legitimate interest of promoting our products.
The processing is necessary for the performance of a contract such as a contract of sale.
The processing is necessary for compliance with a legal obligation to which the controller is subject.

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
The purpose test – to identify the legitimate interest
Necessity test – to consider if the processing is necessary for the purpose identified
Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.

4.0 What Information we collect and from where

We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:
Name, address, telephone number, email.
Purchase history
Web and website activity including tracking cookies
Email / SMS / Social Media interaction history
Personal data and records relating to purchases such as credit card or bank account details.
IP address and location

4.1 Special Category Data
It is Thru Dark’ policy not to collect the special category data (such as health, genetic and biometric data) from you.

4.2 Third Party Collection of Personal Data
We may also collect your data through Third Parties such as those who manage payment and credit applications.

5.0 How Long we Keep Information

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 17 of this policy.


6.0 Security of personal information

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed.

We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.

We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 17 of this policy.

7.0 Children's information

We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in Section 17, so we can remove this information without any undue delay.


8.0 individuals’ rights

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
- Right to Object
- Right of Access
- Right to be Informed
- Right to Rectification
- Right to Request Erasure
- Right to Restrict Processing
- Right to Data Portability

The right to object
You can exercise this right if:
Processing relies on legitimate interest
Processing is for scientific or historical research
Processing includes automated decision making and profiling
Processing is for direct marketing purposes

The right of access
You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.

The right to be informed
We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.

The right of rectification
If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.

The right to request erasure
If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.

The right to restrict processing
You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
Processing is unlawful
We no longer need the personal data, but it is required for a legal process
You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
If you are exercising your right to rectification

The right to data portability
You can request that your personal data is transferred to another controller or processor in a machine-readable format if:

Processing is based on consent
Processing is by automated means (i.e. not paper based)
Processing is necessary for the fulfilment of a contractual obligation

You also have the following rights:
The right to lodge a complaint with the Information Commissioner’s Office (ICO).

The right to an effective judicial remedy against the ICO.

The right to withdraw your consent at any time.

The right to be informed of a data breach that is likely to result in a high risk to your rights and freedoms.

More information relating to the Rights of Individuals under the GDPR can be found on the ICOs’ website.

9.0 Consent

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

10.0 Failure To Provide Personal Information

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

11.0 Cookies

Our website uses cookies. Please see our Cookies Notice for full details of the cookies used.

12.0 Automated Decision Making

Your personal data is not used in any significant automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual). We analyse data such as purchase histories to make product recommendations and to promote our products. If you do not wish to receive these recommendations and promotions please unsubscribe or contact us via the email address listed in Section 17 of this Privacy Notice.
If we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.


13.0 Transfers To Third Parties

Thru Dark Wholefoods may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
Business partners, suppliers, contractors for the performance of any contract we enter into with them or you
Companies within our group where necessary for administrative purposes and to provide services to you
Third parties that support us to provide products and services (e.g. IT support, cloud-based software services, providers of telecommunications equipment)
- Marketing services providers
- Payment service providers
- Recruitment service providers
- Professional advisors e.g. lawyers, auditors
- Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.
Specifically, we work closely with PayPal who support us with financial services relating to purchases of our products and Rakuten who provide us with digital marketing services. More information on these companies’ processing of person data can be found at:

14.0 AdRoll   

Description of Service

This is a marketing and retargeting service.

Processing Company

NextRoll, Inc.

2300 Harrison St, Fl 2, San Francisco CA, 94110 United States of America


Data Protection Officer of Processing Company

Below you can find the email address of the data protection officer of the processing company.



Data Purposes

This list represents the purposes of the data collection and processing.

- Retargeting

- Marketing


Technologies Used

This list represents all technologies this service uses to collect data. Typical technologies are Cookies and Pixels that are placed in the browser.


Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

IP address

Date and time of visit


Advertiser website activity

Customer ID

What page an ad appeared on

Device type

Third party information

Data from advertising partners

Hashed version of email address

Browsing activity

Website activity

Mobile device's unique identifier

How many times an ad has been served

Page views

Amount of time spent on a page

Pseudonymized advertiser identifiers

Cookie ID

Items placed in shopping cart

Views and interactions with content and ads


Legal Basis

In the following the required legal basis for the processing of data is listed.

Art. 6 para. 1 s. 1 lit. a GDPR


Location of Processing

This is the primary location where the collected data is being processed. If the data is also processed in other countries, you are informed separately.


United States of America

Retention Period

The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.

The data will be deleted as soon as they are no longer needed for the processing purposes.


Transfer to Third Countries

This service may forward the collected data to a different country. Please note that this service might transfer the data outside of the EU/EEA and to a country without the required data protection standards. If the data is transferred to the US, there is a risk that your data can be processed by US authorities, for control and surveillance measures, possibly without legal remedies. Below you can find a list of countries to which the data is being transferred. This can be for different reasons like storing or processing.

United States of America


Data Recipients

In the following the recipients of the data collected are listed.

Other advertising companies in the digital advertising ecosystem

NextRoll, Inc.

Click here to read the privacy policy of the data processor


Click here to opt out from this processor across all domains



Storage Information

Maximum age of cookie storage: 1 year, 1 month

Stored Information

Name: __adroll; This cookie is set by AdRoll Group, to identify the device when the users move between different Digital Properties, for the purpose of serving targeted advertisements.; Type: cookie; Duration: 1 year, 1 month; Domain: d.adroll.com;

Name: __adroll_shared ; The domain of this cookie is owned by Adroll. This cookie is used for collecting user data across website. The collected data is used to serve more relevant advertisement. ; Type: cookie; Duration: 1 year, 1 month; Domain: .adroll.com ;

Name: __adroll_fpc ; This cookie is set by AdRoll Group to identify the device when the users move between different Digital Properties, for the purpose of serving targeted advertisements. ; Type: cookie; Duration: 1 year

Name: tluid; This cookie is set by the provider AdRoll.This cookie is used to identify the visitor and to serve them with relevant ads by collecting user behaviour from multiple websites.; Type: cookie; Duration: 3 months;


15.0 Transfers Outside Of The UK

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).

We may share personal information to third parties outside of the UK Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer.
These could include:
- Standard Contractual Clauses
- Binding Corporate Rules
An exception as defined in Article 49 of the UK GDPR
For more information about transfers and safeguarding measures, please contact us using the information in section 17.

16.0 Right to complain

We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on support@thrudark.com.
Alternatively, you can contact us via our website www.thrudark.com/pages/contact
As mentioned in Section 8, you also have the right to make a complaint to the Information Commissioner’s Office (ico.org.uk).


17.0 European Union Representation

We do not currently promote ourselves or our products outside of the UK. If you are a resident of an EU Member State and you wish to exercise your rights under the GDPR or have any questions regarding data privacy, please contact us at support@thrudark.com.

18.0 Additional information

Your trust is important to us. That is why we are always available to answer any questions concerning your data and how it is processed. If you have any questions that could not be answered by this privacy notice or if you wish to receive more in-depth information about any topic within it, please contact us via email at dpo@thrudark.com.

19.0 Policy Review and Amendments

We keep this Policy under regular review. This Policy was last updated October 2022.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.