Privacy policy

Last updated: 15 October 2026

This Privacy Policy explains how ELOUAZZANI LLC, trading as Swoone (“we”, “us”), collects, uses and shares your personal data when you visit swoonesilk.com, make a purchase or contact us (the “Services”). The site is powered by Shopify. We process your data in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and, for the United Kingdom, the UK GDPR and the Data Protection Act 2018.

Data controller

The data controller is ELOUAZZANI LLC, a limited liability company organised under the laws of the State of Montana, USA, registered with the Montana Secretary of State under file number 17299910, whose principal office is at 1001 S Main St, Ste 700, Kalispell, MT 59901-1498, United States. For any question about your data: contact@swoonesilk.com.

Data we collect

• Contact details: name, billing and delivery addresses, telephone number, email address.
• Payment information: transaction data and payment confirmation. Your card details are processed directly by our payment provider and are not stored by us.
• Account information: login details, preferences and settings.
• Order information: items viewed, basket, purchases, returns, exchanges, order history.
• Communications: the content of your exchanges with our customer service.
• Technical data: device, browser, IP address, identifiers, usage and browsing data.

Purposes and legal bases

We process your data for the following purposes, on the legal bases indicated:

• Managing orders, your account, delivery, returns and customer service: performance of the contract (Article 6(1)(b) GDPR).
• Invoicing and accounting: compliance with a legal obligation (Article 6(1)(c) GDPR).
• Marketing messages (email, SMS) and non-essential cookies, including audience measurement cookies: your consent (Article 6(1)(a) GDPR), which you can withdraw at any time.
• Security, fraud prevention and improvement of the Services: our legitimate interests (Article 6(1)(f) GDPR).

The same legal bases apply under the UK GDPR.

Recipients and processors

Your data is accessible to our staff and to processors acting on our behalf, in particular: Shopify (hosting and operation of the shop), our payment provider, our carriers and logistics providers, our email marketing tool (Klaviyo) and our audience measurement tool (Microsoft Clarity). These providers use your data only to provide their services to us. Your data may also be disclosed to comply with a legal obligation or a request from a competent authority.

International transfers

We are established in the United States, so your personal data is transferred to the United States when you use the Services. Where the transfer is necessary to perform our contract with you, for example to process and deliver your order, it is based on Article 49(1)(b) GDPR (and the same article of the UK GDPR).

Our processors may also process your data in the United States or in other countries outside the European Economic Area and the United Kingdom. These transfers are based on an adequacy decision, including the EU-US Data Privacy Framework (and its UK Extension) where the recipient is certified under it, or on the standard contractual clauses of the European Commission (with the UK International Data Transfer Addendum for data from the United Kingdom) used by our processors. You can ask us for more information about these safeguards.

Retention periods

• Customer account data: for the duration of our relationship, then up to 3 years after your last contact with us.
• Order data and accounting records: for the period required by applicable accounting and tax law.
• Marketing data (newsletter, marketing messages): until you withdraw your consent or, failing that, 3 years after your last contact with us.
• Card details: not stored by us; handled by the payment provider.
• Cookies and trackers: your consent choice is kept for 6 months; trackers have a maximum lifetime of 13 months.
• Requests and disputes: for as long as needed to handle them, then for the applicable limitation periods.

Cookies and trackers

The site uses cookies that are strictly necessary for it to work and, only with your consent, audience measurement cookies (Microsoft Clarity) and marketing cookies. A consent banner lets you accept, refuse or customise non-essential cookies, and you can change your choice at any time through the banner or your browser settings. Refusing non-essential cookies does not prevent you from accessing the site. This follows the ePrivacy Directive (2002/58/EC) as implemented in each EU country and, in the United Kingdom, the Privacy and Electronic Communications Regulations 2003.

Your rights

Under the GDPR and the UK GDPR, you have the right to access your data, to have it rectified or erased, to object to its processing (in particular, at any time, to direct marketing), to restrict its processing and to data portability. You can also withdraw your consent at any time, without affecting the lawfulness of processing carried out before you withdrew it.

To exercise these rights, write to us at contact@swoonesilk.com. We may ask you to prove your identity. We reply within one month; this period may be extended by two months for complex or numerous requests, in which case we will tell you.

You can unsubscribe from our marketing messages at any time using the unsubscribe link included in every email.

Right to lodge a complaint

If you believe that the processing of your data does not comply with data protection law, you may lodge a complaint with the data protection authority of the country where you live, where you work or where the alleged infringement occurred:

• United Kingdom: Information Commissioner’s Office (ico.org.uk)
• Germany: the data protection authority of your federal state (list on www.bfdi.bund.de)
• Spain: Agencia Española de Protección de Datos (www.aepd.es)
• Italy: Garante per la protezione dei dati personali (www.garanteprivacy.it)
• Netherlands: Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl)
• Poland: Prezes Urzędu Ochrony Danych Osobowych (uodo.gov.pl)

Children

The Services are not intended for children under 16, and we do not knowingly collect their data. If you are the parent or guardian of a child who has sent us personal data, contact us and we will delete it.

Security

We use appropriate technical and organisational measures to protect your data. As no system is completely secure, we recommend that you do not send sensitive information through unsecured channels.

Relationship with Shopify

As the Services are hosted by Shopify, some data is processed by Shopify to provide and improve the Services. To find out more, see Shopify’s Privacy Policy and Shopify’s privacy portal.

Changes

We may update this Privacy Policy to reflect changes in our practices or in the law. Any revised version will be published on this page with a new “last updated” date.

Contact

For any question about your personal data or this policy, contact ELOUAZZANI LLC at contact@swoonesilk.com or through our contact form at https://swoonesilk.com/pages/contact. We are the controller of your personal data.