Privacy Policy — Never Been

Last updated: 01 October 2025

This Privacy Policy explains how Never Been (“we”, “us”, “our”) collects, uses, shares, and protects your personal data when you visit or make a purchase on neverbeenshop.com (the “Website”).

1. Controller & Contact

  • Controller: Never Been

  • Business address: 22, Rue de Rollingergrund, 2440 Luxembourg

  • Privacy contact email: info@neverbeenshop.com

2. Data We Collect

We collect the following categories of information:

  • Order & account data: name, email, billing/shipping address, order details.

  • Payment data: processed securely by Stripe (and Apple Pay via Stripe). We do not store full card details.

  • Communications: emails or messages you send us.

  • Marketing preferences: newsletter sign-ups, consent choices (if any).

  • Device & usage data: IP address, browser/operating system (user-agent), pages visited, and basic analytics data collected by our hosting provider or tools you consent to through cookies

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3. Purpose & Legal Basis

We process data for the following purposes:

  • Orders and deliveries: Contract (Art. 6(1)(b) GDPR)

  • Accounting and tax compliance: Legal obligation (Art. 6(1)(c) GDPR)

  • Customer support, fraud prevention, security: Legitimate interests (Art. 6(1)(f) GDPR)

  • Marketing emails/newsletters: Consent (Art. 6(1)(a) GDPR)

  • Analytics and advertising cookies: Consent via cookie banner (only if enabled)

4. Data Sharing

We share data with trusted providers as needed:

  • Hosting: Hostinger

  • Payments: Stripe (incl. Apple Pay)

  • Shipping: POST Luxembourg, DHL, DPD, UPS

  • Email/newsletters: newsletter service provider (if enabled)

  • Analytics/ads: Google Analytics, Meta/Instagram, Google Ads (only if enabled and consented)

Each third party acts as our processor or an independent controller (e.g., payment and ad platforms). See our Cookie Policy for more details.

5. International Transfers

Some providers may be located outside the European Economic Area (EEA), for example in the United States. In these cases, data transfers are covered by EU adequacy decisions or the provider’s Standard Contractual Clauses (SCCs), together with supplementary safeguards where required.

6. Retention

  • Orders, invoices, tax records: kept for 10 years (required by Luxembourg law).

  • Support correspondence: normally up to 3 years after last contact, unless needed longer for legal purposes.

  • Marketing data: kept until you unsubscribe or withdraw consent.

  • Analytics/ads identifiers: kept only as long as permitted by the tool and your cookie consent.

7. Your Rights

You have the right to:

  • Access, correct, or delete your personal data

  • Restrict or object to processing

  • Withdraw consent at any time (for consent-based processing)

  • Request data portability

To exercise rights, contact us at info@neverbeenshop.com.

You also have the right to complain to your local data protection authority. Our lead authority is the CNPD (Luxembourg).

8. Cookies & Consent

We use essential cookies necessary for the website and checkout to work. We also use analytics and marketing cookies, but only if you consent via our cookie banner.
For details, see our separate Cookie Policy.

9. Children and Minors

Our Website and marketing are accessible to people of all ages, including under-16s. However, purchases require a valid payment method and therefore generally involve parental oversight for customers under 16.

10. Security

We take reasonable steps to protect your personal data against unauthorized access, misuse, loss, or disclosure.

11. Changes

We may update this policy from time to time. The “Last updated” date at the top shows the latest version.

12. Contact

For questions or requests regarding this Privacy Policy, email us at: info@neverbeenshop.com