PANDORASOUL

PRIVACY AND COOKIE POLICY

Last updated 4 November 2026.

1. Introduction

1.1 This is the privacy policy of Pandora PS Ltd, trading as PandoraSoul, a private limited company registered in Scotland under company number SC695186 and with its registered office at 72/5 Willowbrae Road, EH8 7HA (we, us, or our). We are the controller responsible for your personal data. You can contact us by email at hello@pandorasoul.com or by post at Suite 1A, 121 Giles Street, Edinburgh, EH6 6BZ, United Kingdom. Whenever this policy asks you to contact us, you can use either of these.

1.2 We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case as amended, including by the Data (Use and Access) Act 2025 (data protection laws). If you live outside the UK, the data protection laws of the place where you live may also apply (see clauses 14 and 15).

1.3 You have the right to complain to us about our use of your personal data. Please email us and we will acknowledge your complaint within 30 days and respond without undue delay. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator at https://ico.org.uk/.

1.4 We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data, such as when you:

(a) visit our website at pandorasoul.com;

(b) buy a Letter subscription, a Gift Plan from us, or join our waiting list or mailing list;

(c) receive one of our Letters as a gift;

(d) apply for a role with us or otherwise engage with us in connection with recruitment opportunities; or

(e) write back to us, contact us with any enquiry or otherwise engage with us.

1.5 Words beginning with a capital letter that aren’t defined in this policy, such as Letter, Gift Plan and Recipient, have the meanings given in our terms of use and sale at pandorasoul.com/terms.

2. The data we may collect about you

2.1 Personal data means information relating to an identified or identifiable individual. It does not include information which has been anonymised so that nobody can be identified. We may collect, use, store and transfer the following categories of personal data:

(a) Identity Data includes your name and any username for your account on our website.

(b) Contact Data includes your billing and delivery address, email address and, if you choose to give it, telephone number.

(c) Financial Data includes payment card details. We do not see or store full payment card details, which are collected and processed by our payment providers, Wix Payments, PayPal and Stripe.

(d) Transaction Data includes details of payments to and from you, refunds, and the plans, Gifts and Letters you have bought from us.

(e) Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone and approximate location, operating system, device information and other technology used to access our website.

(f) Profile Data includes your account details, username and password, preferences, correspondence, enquiries, complaints, feedback and survey responses.

(g) Usage Data includes information about how you use our website, account and services, including whether you open our emails and which links you click.

(h) Marketing Data includes your preferences about receiving marketing from us and your communication preferences.

(i) Content Data includes your replies to our Letters (by post or email), any question you share when you join our waiting list, and any extracts from your replies that you allow us to publish.

(j) Gift Data includes the name and postal address of someone you buy a Gift for, and any gift message you add.

(k) Recruitment Data includes CVs, employment and education history, professional qualifications, right-to-work information, interview notes, references and correspondence relating to job or contractor applications.

(l) Aggregated Data such as statistical or demographic data for any purpose, is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

(m) Special Category Data includes certain particularly sensitive personal data. It covers information about your health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, sex life or sexual orientation and genetic or biometric data. We do not ask for Special Category Data, but you may choose to share it when you write back to us, for example about your health, beliefs or private life. We do not collect information about criminal convictions and offences.

3. How is your personal data collected?

We may collect personal data from and about you in the following ways:

3.1 Direct interactions. You may provide personal data when you create an account, place an order, buy a Gift, join our waiting list or mailing list, write back to us, contact us or give feedback, or apply for a role.

3.2 Automated technologies or interactions. When you use our website or open our emails, we may automatically collect Technical Data and Usage Data using cookies, server logs and similar technologies.

3.3 Third parties and public sources. We may receive personal data from providers supporting our website, payments, communications and analytics, from social media platforms where you interact with us and, if you apply for a role with us, from recruitment agencies, referees and public sources such as professional networking sites. If someone buys you a Gift, we receive your name and postal address, and any gift message, from them.

4. How we use your personal data

We will use your personal data only where we have a lawful basis to do so. Depending on the circumstances, we may rely on:

4.1 Contract. Where processing is necessary to enter into or perform our contract with you, including administering your account, subscription and payments and posting your Letters.

4.2 Legitimate interests. Where processing is necessary for our legitimate interests or those of a third party, and your interests and fundamental rights do not override those interests.

4.3 Legal obligation. Where processing is necessary to comply with a legal obligation, including tax, accounting, consumer protection and data protection requirements.

4.4 Consent. Where you have actively agreed to a particular use of your personal data, for example receiving certain marketing communications.

4.5 Special Category Data. If you choose to share Special Category Data when you write back to us, we will rely on your explicit consent under Article 9(2)(a) UK GDPR, which you give by ticking the box on our reply page or by including the words “I agree” when you reply by email. We will only use that information to read and respond to your reply, and we will only publish any of it if your permission clearly covers it. If we reasonably believe someone may be at serious risk of harm and they can’t give consent, we may share relevant information with emergency services to protect them, as Article 9(2)(c) UK GDPR allows.

You may withdraw consent at any time by contacting us. This will not affect processing carried out before withdrawal. If you withdraw consent, we will delete the relevant parts of your reply and remove any published extract from our website and social media accounts.

5. Purposes for which we will use your personal data

5.1 The table below explains the principal purposes for which we use personal data and the lawful bases on which we rely. We may rely on more than one lawful basis depending on the circumstances.

6. Direct marketing and third party marketing

6.1 You will receive marketing communications from us if you have provided your consent to receive such communications or, where permitted under applicable law (including the Privacy and Electronic Communications (EC Directive) Regulations 2003), where you have previously purchased products or services from us, we are marketing similar products or services, and you have not opted out at the time of collection or in any subsequent communication.

6.2 We may also use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to assess which products, services and offers may be of interest to you and to send you relevant marketing communications, where permitted by law. Our email provider, Wix, tells us whether our emails are opened and which links are clicked, and we use this only to understand which emails readers find useful.

6.3 We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

7. Opting out of marketing

7.1 You can ask us to stop sending marketing communications at any time by using the unsubscribe link in a marketing message or by emailing us.

7.2 Opting out of marketing will not stop service messages which we need to send about your account, orders, payments, subscription renewals and reminders, changes to our terms or services, or responses to your requests.

8. Cookies

8.1 We use cookies and similar storage and access technologies on our website. These technologies help us provide essential functions, remember preferences and understand how our website is used. We do not currently use advertising cookies. We will not use non-essential technologies unless we have the consent or other permission required by law.

8.2 Cookies are small text files placed on your device. Similar technologies may include pixels (including in our emails) and local storage. Some of these technologies collect Technical Data and Usage Data.

8.3 We may use the following categories:

(a) Strictly necessary cookies. These support essential functions such as account login, security, shopping baskets and payments. Consent is not required where a legal exemption applies.

(b) Analytical or performance cookies. These help us understand visitor numbers and how people use our website so that we can improve them. We will obtain consent unless the technology falls within an applicable legal exemption and all conditions for that exemption are met. Where we rely on an exemption, we will tell you and give you a simple way to object.

(c) Functionality cookies. These remember choices and preferences, such as account, language or region settings. We will obtain consent where required.

8.4 We use the following cookies:

(a) Essential cookies placed by Wix. These support the operation and security of our website and enable website forms to function. Some expire when you close your browser and others last longer, as shown in our cookie settings.

(b) Analytics cookies placed by Wix. These help us distinguish visitors, understand how our website is used and improve its performance. They remain on your device for the period shown in our cookie settings. We use these cookies only where you have consented through our cookie banner, unless an applicable legal exemption permits their use without consent.

8.5 Wix may receive information collected through its cookies and process it in accordance with its own privacy information.

8.6 When you first visit, a cookie banner lets you accept, reject or customise non-essential cookies. You can change your choices at any time by clicking “Cookie Settings” in the website footer. Most browsers also let you block or delete cookies through their settings; see www.allaboutcookies.org for instructions. If you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our website.

9. Disclosures of your personal data

9.1 We may share personal data where reasonably necessary:

(a) with any staff or contractors who need it to provide our services and operate our business;

(b) with providers supporting our website, online shop, accounts, payments, email, marketing, analytics, IT, hosting and administration, including Wix Payments, PayPal and Stripe;

(c) with the Post Office and Royal Mail and, for Letters posted to the United States, the United States Postal Service and US Customs and Border Protection, who receive the Recipient's name and address and a description of the contents so that Letters can be delivered and cleared through customs;

(d) with professional advisers, insurers, auditors, prospective buyers, investors or lenders in connection with advice, insurance, legal claims or a proposed sale, investment, restructuring or transfer of our business;

(e) where disclosure is required by law, regulation, a court, the ICO or another competent authority;

(f) where necessary to establish, exercise or defend legal claims or protect the rights, property, health or safety of our business, staff, customers, visitors or others including sharing information with emergency services if we reasonably believe someone may be at serious risk of harm; and

(g) with fraud-prevention agencies, payment providers, financial institutions, insurers or law-enforcement authorities where necessary for fraud prevention, payment administration, risk management or legal compliance.

9.2 Our service providers may include providers of:

(a) payment processing and banking services;

(b) website, online shop, account, hosting and content-management services;

(c) subscription-management and customer-relationship systems;

(d) data analytics, cookie-management and marketing services;

(e) email and other communications services;

(f) IT support, cloud storage and information-security services;

(g) social media and online review services; and

(h) professional advisers, including legal, accounting, audit and insurance providers.

9.3 We require service providers acting as our processors to protect personal data and process it only for agreed purposes and in accordance with our instructions. Some recipients, such as payment providers, professional advisers and social media platforms, may act as independent controllers and will process personal data under their own privacy information.

10. Data security

10.1 We use appropriate technical and organisational measures to protect personal data against accidental or unlawful loss, alteration, disclosure or access. These measures include, where appropriate:

(a) using secure systems and limiting the personal data collected;

(b) password protection, two-step verification, access controls and appropriate staff and contractor confidentiality requirements; and

(c) contracts and due-diligence measures for relevant service providers.

10.2 We restrict access to personal data to people who need it for their role. Letters you post to us are kept securely and shredded when we no longer need them. Those handling personal data are subject to confidentiality and security requirements.

10.3 We maintain procedures for responding to suspected personal data breaches and will notify the ICO and affected individuals where required by law.

10.4 You are responsible for keeping your account password and login information confidential. Please do not share them with anyone.

10.5 No method of electronic transmission or storage is completely secure. We nevertheless take appropriate steps to protect personal data transmitted through our website and other systems.

11. International transfers

11.1 Some of our providers, including Wix, PayPal and Stripe, process personal data outside the UK, including in the United States. When we post Letters to the United States, the Recipient's name and address and a description of the contents are also shared with US postal and customs authorities so that the Letters can be delivered.

11.2 Where personal data is transferred outside the UK, we will use a lawful transfer mechanism and any additional measures required by data protection laws. Depending on the destination and Recipient, this may include:

(a) a UK adequacy regulation, including the UK Extension to the EU-US Data Privacy Framework where the US Recipient is appropriately certified;

(b) the UK International Data Transfer Agreement or the UK Addendum to approved EU standard contractual clauses, together with any required transfer risk assessment and supplementary measures;

(c) another safeguard approved under UK data protection laws; or

(d) an applicable exception under Article 49 UK GDPR, used only where its legal conditions are met.

11.3 The UK recognises the European Economic Area as providing an adequate level of protection for personal data.

11.4 Please contact us if you would like further information about the transfer mechanism used for your personal data or a copy of the relevant safeguard.

12. Data retention

12.1 We keep personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, regulatory, tax, accounting, insurance and reporting requirements and the establishment, exercise or defence of legal claims.

12.2 When setting retention periods, we consider the amount, nature and sensitivity of the data, the risks arising from unauthorised use or disclosure, the purposes of processing, whether those purposes can be achieved in another way and applicable legal, regulatory, insurance and contractual requirements.

12.3 We will generally retain order, payment and transaction records for six years after the end of the financial year to which they relate, for tax, accounting and legal-claims purposes. We keep a record of your agreement to automatic renewal for three years, or for one year after your subscription ends if that is longer.

12.4 We will generally keep your replies to our Letters for two years after we receive them, unless you ask us to delete them sooner. Extracts you have allowed us to publish stay on our website and social media accounts until you withdraw your permission.

12.5 Marketing records will generally be kept until you opt out, after which we may retain limited details on a suppression list so that we can respect your preference.

12.6 We keep website analytics data only for as long as we need it to understand how our website is used, and we review it at least once a year.

12.7 Recruitment records relating to an unsuccessful applicant will generally be retained for six months after the recruitment process ends. If the applicant agrees that we may contact them about future opportunities, we may retain their details for up to 12 months. Relevant records relating to a successful applicant will become part of their employment or contractor record and will be retained in accordance with our applicable retention policy.

12.8 At the end of the relevant retention period, personal data will be securely deleted or anonymised. We may retain properly anonymised information for statistical, planning and service-improvement purposes because it no longer identifies anyone.

13. Your legal rights

13.1 Because we are based in the UK, UK data protection laws apply to all the personal data we hold, wherever you live. This means you have the right to:

(a) Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c) Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

(e) You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in clause 7 for details of how to object to receiving direct marketing communications).

(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g) Withdraw consent at any time where we are relying on consent to process your personal data (see the table in clause 5 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

(h) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

(i) If you want us to establish the data's accuracy;

(ii) Where our use of the data is unlawful but you do not want us to erase it;

(iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

13.2 If you wish to exercise any of the rights set out above, please contact us by post or email.

13.3 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 could refuse to comply with your request in these circumstances.

13.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

13.5 We try to respond to all legitimate requests within one month. Occasionally it could 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.

13.6 We won’t treat you differently, for example by charging you more or giving you a lower standard of service, because you have used any of these rights.

14. Additional information for US residents

14.1 We do not sell your personal information, share it for cross-context behavioural advertising or use it for targeted advertising.

14.2 Wherever you live, you can use the rights in clause 13. Depending on the US state where you live, you may also have additional rights under state law. To use any of these rights, please contact us by post or email.

14.3 Our website does not currently respond to “Do Not Track” browser signals. We do not allow other companies to track you across other websites through our website.

15. Consumer health data privacy policy

15.1 This clause is our consumer health data privacy policy for the purposes of Washington’s My Health My Data Act and similar US state laws. It applies to information about your physical or mental health that you choose to include when you write back to us (consumer health data).

15.2 What we collect and why. The only consumer health data we collect is what you choose to tell us about your physical or mental health or wellbeing in your replies. We use it only to read and respond to your reply and, if you give separate permission, to publish an extract without your name.

15.3 Where it comes from. We collect consumer health data only directly from you.

15.4 Who we share it with. We do not sell consumer health data. The categories of consumer health data described above are stored for us by our website and email provider, Wix, and our IT and cloud storage providers. We do not share consumer health data with anyone else, except in extracts you have given us separate permission to publish, or where the law requires or allows it.

15.5 Your consent. We only collect consumer health data with your consent, which you give by ticking the box on our reply page or by including the words “I agree” when you reply by email. We will ask for your separate consent before publishing an extract that includes it. You can withdraw your consent at any time by emailing us.

15.6 Your rights. You can ask us to confirm whether we hold your consumer health data, to give you access to it and a list of anyone we have shared it with (with their contact details), and to delete it. Please email us with the subject line “Health data request”. We will respond within 45 days. If we need more time, we will tell you and may extend this once by a further 45 days.

15.7 Appeals. If we refuse to act on your request, you can appeal by emailing us with the subject line “Health data appeal”. We will tell you in writing within 45 days what action we have taken and why. If your appeal is unsuccessful, you can contact the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.

16. Children

Our products are for adults, and you must be 18 or over to place an order. We do not knowingly collect personal data from anyone under 18, other than a Recipient’s name and address given to us by the person who bought the Gift. Recipients receive a short note with their first Letter explaining how we got their details and how to contact us. If you think a child has given us personal data, please email us and we will delete it.

17. Third party links

Our 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 policy of every website you visit.

18. Changes to this privacy policy and your duty to inform us of changes

18.1 We keep this policy under review and may update it from time to time. The date at the top shows when it was last updated. If we make a significant change, we will tell you by email before it takes effect.

18.2 Please tell us if your personal data changes during your relationship with us so that we can keep our records accurate and current.