Privacy Policy

Last updated: 22 July 2026

This Privacy Policy explains how KETA GUTMANE collects, uses, discloses, retains, and protects personal data when you use our Website, create a customer account, place or receive an order, subscribe to communications, request a back-in-stock notification, contact us, or otherwise interact with us.

This Privacy Policy is a transparency notice and does not form part of the contract of sale. Purchases are governed by our Terms & Conditions and the policies incorporated into them.

1. Who We Are and Scope of This Policy

1.1 The controller responsible for the processing described in this Privacy Policy is:

SIA “Red is the New Black”
Trading as KETA GUTMANE
Registration No. 40103671488
Registered address: Jeruzalemes iela 2/4–29, Riga, LV-1010, Latvia
VAT No.: LV40103671488
Email: clientservices@ketagutmane.com
Website: www.ketagutmane.com

1.2 References to “KETA GUTMANE”, “we”, “us”, or “our” mean SIA “Red is the New Black”.

1.3 References to “you” or “your” mean the person whose personal data we process, including Website visitors, customers, account holders, order recipients, subscribers, and persons who contact us.

1.4 This Privacy Policy applies to personal data processed in connection with:

(a) our Website and online store;
(b) customer accounts, wishlists, carts, and checkout;
(c) orders, payments, delivery, returns, and refunds;
(d) newsletters and back-in-stock notifications;
(e) customer service, complaints, and product claims; and
(f) security, analytics, advertising, and Website improvement.

2. Personal Data We Collect

2.1 The personal data we collect depends on how you interact with us.

Identity and contact information

2.2 This may include:

(a) name;
(b) email address;
(c) telephone number;
(d) billing and delivery addresses;
(e) city, region, country, and postal code;
(f) company name, where provided; and
(g) another recipient’s information where an order is sent to that person.

Customer-account and preference information

2.3 This may include:

(a) customer-account identifiers;
(b) authentication and session information;
(c) saved addresses and preferences;
(d) wishlist and recently viewed product information; and
(e) order, return, and refund history associated with the account.

Customer authentication is handled by an external account-service provider. We do not directly collect or store your customer-account password.

Order and transaction information

2.4 This may include:

(a) products and variants viewed, saved, ordered, returned, or refunded;
(b) cart contents and identifiers;
(c) order number, date, status, value, and currency;
(d) selected delivery method;
(e) fulfilment, tracking, and delivery information;
(f) cancellations, returns, exchanges, and refunds;
(g) discounts and promotional information; and
(h) customs or import information where required.

Payment information

2.5 Payments are entered and processed through a secure externally hosted checkout and the applicable payment provider.

We normally receive information such as payment status, payment-method type, transaction reference, limited payment details, and fraud-risk information. We do not normally receive or store complete payment-card numbers.

Communications and customer-service information

2.6 We collect information contained in communications concerning:

(a) customer accounts;
(b) orders and payments;
(c) shipping and delivery;
(d) returns, exchanges, and refunds;
(e) faulty, incorrect, damaged, or non-conforming products;
(f) complaints and enquiries; and
(g) account security or suspected fraud.

This may include photographs of products, parcels, packaging, labels, receipts, or other supporting information.

Website, device, and usage information

2.7 This may include:

(a) IP address;
(b) browser, device, operating-system, and language information;
(c) device, session, and technical identifiers;
(d) pages viewed and actions taken;
(e) search queries;
(f) approximate location derived from technical information;
(g) landing and referring pages;
(h) timestamps and session information; and
(i) security, access, and error logs.

Marketing and analytics information

2.8 Where applicable, this may include:

(a) newsletter registrations;
(b) back-in-stock requests;
(c) communication and marketing preferences;
(d) cookie and consent choices;
(e) analytics and advertising identifiers;
(f) campaign and attribution information; and
(g) engagement with the Website and our communications.

2.9 We do not intentionally request special-category personal data, such as information concerning health, biometrics, religion, or political opinions. Please do not provide such information unless it is reasonably necessary for a specific request and we have asked you to provide it.

3. How We Collect Personal Data

3.1 We collect personal data directly from you when you:

(a) browse or search the Website;
(b) create or manage a customer account;
(c) add products to a cart or wishlist;
(d) place an order or provide delivery information;
(e) request a cancellation, return, exchange, or refund;
(f) subscribe to our newsletter;
(g) request a back-in-stock notification; or
(h) contact Client Services.

3.2 We collect certain information automatically through:

(a) Website and server logs;
(b) cookies and similar technologies;
(c) analytics and advertising services used with the required consent; and
(d) payment-security and fraud-prevention systems.

3.3 We may receive personal data from:

(a) e-commerce, customer-account, checkout, and payment providers;
(b) delivery, logistics, customs, and returns providers;
(c) analytics, marketing, advertising, and customer-communication providers;
(d) technical, security, address-data, and delivery-information providers; and
(e) public or legally accessible sources where necessary to prevent fraud, comply with law, or protect legal rights.

3.4 Where you provide information about another person, such as the recipient of a gift, you should ensure that you are entitled to provide it and that the person understands that it will be used to fulfil the order.

4. Why We Use Personal Data and Our Legal Bases

4.1 We process personal data only where we have a lawful basis.

Contract and steps taken at your request

4.2 We process personal data where necessary to:

(a) create and manage customer accounts;
(b) provide requested cart, wishlist, and account functions;
(c) receive, assess, accept, and fulfil orders;
(d) authorise and process payments and refunds;
(e) arrange shipping, customs clearance, tracking, and delivery;
(f) process cancellations, returns, exchanges, and product claims; and
(g) provide order-related customer service.

The legal basis is taking steps at your request before entering into a contract or performing our contract with you.

Legal obligations

4.3 We process personal data where necessary to:

(a) maintain accounting, payment, tax, and transaction records;
(b) comply with customs, consumer-protection, and product-safety requirements;
(c) handle statutory withdrawal and product-conformity rights;
(d) comply with sanctions and trade restrictions; and
(e) respond to binding requests from courts, regulators, or public authorities.

The legal basis is compliance with a legal obligation.

Legitimate interests

4.4 We may process personal data where necessary for our legitimate interests in:

(a) protecting customer accounts, the Website, and our systems;
(b) preventing and investigating fraud, misuse, and security incidents;
(c) managing payment disputes and chargebacks;
(d) operating and troubleshooting essential services;
(e) managing complaints and business records; and
(f) establishing, exercising, or defending legal claims.

We rely on legitimate interests only where those interests are not overridden by your rights and freedoms.

Consent and requested communications

4.5 We rely on consent where required for:

(a) newsletters and promotional communications;
(b) optional analytics;
(c) advertising measurement and audience matching;
(d) consented onsite marketing; and
(e) heatmaps and sampled session recordings.

4.6 Where you request a back-in-stock notification, we use the information necessary to provide the requested notification. We will not use that request for broader marketing unless we have an appropriate legal basis.

4.7 You may withdraw consent at any time through the relevant unsubscribe method, Website privacy settings, or by contacting us. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

These legal bases and transparency obligations derive from the GDPR, which also permits the disclosure of categories of recipients rather than requiring every service provider to be identified publicly.

5. Information Required to Provide Our Services

5.1 Certain personal data is required to enter into or perform a contract with you, including information needed to:

(a) identify the customer and order;
(b) authorise and process payment;
(c) deliver the products; and
(d) process a return, refund, or statutory claim.

5.2 If required information is not provided, we may be unable to create an account, accept or fulfil an order, deliver products, issue a refund, or respond fully to a request.

5.3 Information that is not required may be identified as optional and may be omitted without preventing the relevant transaction.

6. Analytics, Website Improvement and Advertising

6.1 Subject to your consent choices, we use analytics services to understand:

(a) how visitors reach and use the Website;
(b) which pages, products, and collections are viewed;
(c) cart and ecommerce activity;
(d) Website performance and technical issues;
(e) customer journeys and feature use; and
(f) the effectiveness of Website improvements.

6.2 Analytics information may include technical and usage data, pseudonymous identifiers, approximate location, referral information, and Website or ecommerce events.

6.3 Where analytics consent has been provided, we may use heatmaps and sampled session recordings to understand how visitors navigate and interact with the Website.

Session recordings may reproduce interactions such as navigation, clicking, scrolling, and page changes. We take steps to mask or exclude form inputs, payment information, account credentials, and other sensitive or unnecessary content.

6.4 Subject to marketing consent, we may use advertising and social-media services to:

(a) measure advertising and campaign performance;
(b) understand whether advertising led to Website activity or purchases;
(c) record events such as product views, additions to a cart, and checkout initiation; and
(d) improve the relevance of advertising.

6.5 Where enabled and covered by your consent, advertising partners may receive pseudonymised, normalised, or cryptographically hashed identifiers, such as an email address or telephone number, for advertising measurement and matching.

6.6 Detailed information about cookies, pixels, browser storage, their providers, purposes, and durations is contained in our separate Cookie Policy and Website Cookie Settings.

7. Newsletters and Back-in-Stock Notifications

7.1 Where you subscribe to our newsletter, we may use your contact information and communication preferences to send news, product information, collection updates, and offers.

7.2 You may unsubscribe from marketing at any time by using the unsubscribe method included in the communication or by contacting us.

7.3 Where you request a back-in-stock notification, we use your email address and the relevant product information to provide that notification.

7.4 Unsubscribing from marketing does not prevent us from sending transactional or service communications concerning an account, order, payment, delivery, return, refund, security issue, or legal notice.

7.5 We may retain limited information on a suppression list so that we can continue to respect an unsubscribe request.

8. Who We Share Personal Data With

8.1 We may share personal data with the following categories of recipients where necessary for the purposes described in this Policy:

(a) e-commerce, customer-account, hosting, checkout, and order-management providers;
(b) payment processors, banks, card networks, authentication services, and fraud-prevention providers;
(c) delivery carriers, logistics providers, customs agents, and returns providers;
(d) email, newsletter, customer-support, and communication providers;
(e) analytics, Website-improvement, heatmap, and session-recording providers;
(f) advertising, campaign-measurement, and social-media partners;
(g) content-management, security, maintenance, and technical-service providers;
(h) address-data and delivery-information providers;
(i) accountants, auditors, insurers, legal advisers, and other professional advisers;
(j) courts, regulators, tax authorities, customs authorities, law-enforcement bodies, and other public authorities where disclosure is legally required or justified; and
(k) prospective purchasers, successors, investors, or advisers involved in a genuine merger, financing, reorganisation, acquisition, or sale of all or part of our business.

8.2 Service providers acting on our behalf are permitted to process personal data only for authorised purposes and subject to applicable contractual and legal requirements.

8.3 Some recipients may act as independent controllers and determine certain purposes and means of processing themselves. Their processing is also governed by their own privacy information.

8.4 In limited circumstances, we and another recipient may act as joint controllers where we jointly determine the relevant purposes and means of processing. Where required, we will make the essence of the applicable arrangement available.

The GDPR expressly permits a privacy notice to identify either the recipients or the categories of recipients to whom personal data is disclosed.

9. International Data Transfers

9.1 Some recipients or their systems may be located outside Latvia or the European Economic Area.

9.2 Where personal data is transferred outside the European Economic Area, we use a transfer mechanism permitted by applicable data-protection law, which may include:

(a) a European Commission adequacy decision;
(b) European Commission standard contractual clauses;
(c) approved binding corporate rules; or
(d) another legally recognised safeguard or derogation.

9.3 Where appropriate, supplementary contractual, organisational, or technical safeguards may also be used.

9.4 You may contact us for further information about the safeguards relevant to a particular transfer. Copies may be subject to appropriate redactions protecting confidential or commercially sensitive information.

The GDPR recognises mechanisms including adequacy decisions, standard contractual clauses, and binding corporate rules for qualifying international transfers.

10. How Long We Keep Personal Data

10.1 We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and to comply with legal obligations.

10.2 Retention periods are determined by considering:

(a) the duration of our relationship with you;
(b) the nature and sensitivity of the information;
(c) accounting, tax, customs, payment, and consumer-protection requirements;
(d) applicable limitation periods;
(e) unresolved returns, complaints, disputes, chargebacks, or claims; and
(f) security, fraud-prevention, and audit requirements.

10.3 In general:

(a) customer-account information is retained while the account remains active and for a reasonable period afterwards, subject to records that must be retained separately;

(b) order, payment, delivery, return, refund, and accounting records are retained for applicable statutory periods and as necessary to manage claims;

(c) customer-service and complaint records are retained for as long as necessary to resolve the matter and protect related legal rights;

(d) wishlist and preference information is retained until deleted, replaced, or no longer required;

(e) back-in-stock information is retained until the requested notification is sent, the request expires, or the information is no longer required;

(f) marketing information is retained until you unsubscribe, withdraw consent, or the information is no longer required, subject to a limited suppression record; and

(g) analytics, heatmap, and session-recording information is retained according to our configured retention periods and only for as long as reasonably necessary for the relevant purpose.

10.4 Personal data may be retained for longer where required by law or reasonably necessary because of an unresolved dispute, investigation, legal hold, or enforcement matter.

10.5 When personal data is no longer required, it will be deleted or anonymised unless continued retention is legally required.

11. Cookies and Similar Technologies

11.1 We use cookies and similar technologies to:

(a) operate and secure the Website;
(b) provide requested account, cart, wishlist, and preference functions;
(c) measure Website and ecommerce activity; and
(d) support advertising and marketing where consent has been provided.

11.2 Our separate Cookie Policy explains:

(a) the categories of technologies used;
(b) their providers and purposes;
(c) their durations; and
(d) how to accept, refuse, or withdraw consent.

11.3 You can review or change optional cookie choices through the Cookie Settings available on the Website.

11.4 Withdrawing consent does not affect processing lawfully carried out before consent was withdrawn.

12. Fraud Screening and Automated Processing

12.1 Our payment, commerce, and security systems may automatically analyse transaction, account, device, and technical information to identify possible fraud, unauthorised payments, or security risks.

12.2 Risk indicators may be used to:

(a) request further verification;
(b) place an order under review;
(c) restrict a transaction or account; or
(d) support a decision to decline or cancel an order where permitted by our Terms & Conditions and applicable law.

12.3 We do not intend to make decisions producing legal or similarly significant effects solely through automated processing without meaningful human involvement, unless the processing is authorised by law and the required safeguards are provided.

12.4 Payment and financial-service providers may conduct their own payment-authorisation, security, and fraud checks under their applicable terms and privacy information.

12.5 You may contact us if you believe that an order or account decision was based on inaccurate information or an automated assessment.

13. Your Data-Protection Rights

13.1 Subject to applicable conditions and exceptions, you may have the right to:

(a) obtain confirmation as to whether we process your personal data;
(b) access your personal data and information about its processing;
(c) correct inaccurate information and complete incomplete information;
(d) request deletion of personal data;
(e) request restriction of processing;
(f) object to processing based on legitimate interests;
(g) object at any time to processing for direct marketing;
(h) receive certain personal data in a structured, commonly used, machine-readable format and transmit it to another controller;
(i) withdraw consent at any time where processing is based on consent; and
(j) exercise applicable rights relating to qualifying automated decision-making.

13.2 These rights are not absolute. We may retain or continue processing information where required or permitted by law, including to complete a transaction, comply with legal obligations, manage a dispute, or establish or defend legal claims.

13.3 To exercise a right, contact:

Email: clientservices@ketagutmane.com
Postal address: SIA “Red is the New Black”, Jeruzalemes iela 2/4–29, Riga, LV-1010, Latvia

13.4 We may request information reasonably necessary to verify your identity and protect personal data against unauthorised disclosure.

13.5 We will respond without undue delay and normally within one month. Where permitted because of the complexity or number of requests, the response period may be extended by up to two further months. We will inform you of any extension and explain the reason.

13.6 Exercising a right is normally free of charge. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse the request where permitted by law.

These rights and response periods reflect the GDPR’s data-subject-rights framework.

14. Security and Children

14.1 We use appropriate technical and organisational measures designed to protect personal data against:

(a) unauthorised or unlawful access, use, alteration, or disclosure;
(b) accidental loss or destruction; and
(c) other unlawful processing.

14.2 We select safeguards according to the nature of the processing and the risks involved. We do not publish detailed security configurations or internal system information where doing so is unnecessary or could weaken those safeguards.

14.3 You are responsible for protecting access to your customer account and should notify us promptly if you suspect unauthorised activity.

14.4 The Website is not directed specifically at children. Orders may be placed only by persons who have legal capacity to enter into a binding contract.

14.5 We do not knowingly collect personal data from a child where the processing requires an authorisation that has not been provided. Please contact us if you believe a child has submitted personal data without an appropriate lawful basis.

15. Contact, Complaints and Changes

15.1 Questions, requests, or complaints concerning this Privacy Policy or our processing of personal data may be submitted to:

SIA “Red is the New Black”
Trading as KETA GUTMANE
Registration No. 40103671488
Registered address: Jeruzalemes iela 2/4–29, Riga, LV-1010, Latvia
Email: clientservices@ketagutmane.com

15.2 We encourage you to contact us first so that we can review and respond to your concern.

15.3 You also have the right to lodge a complaint with the Latvian Data State Inspectorate or, where applicable, another competent data-protection supervisory authority. The Latvian Data State Inspectorate provides a procedure for complaints concerning allegedly unlawful processing of personal data.

15.4 We may update this Privacy Policy to reflect changes in law, our services, service providers, or processing activities.

15.5 The updated version will be published with a revised “Last updated” date. Where required by law or appropriate because a change is material, we will provide additional notice.