THG Ingenuity

What THG Ingenuity is and what it does

THG Ingenuity is the commerce platform and services arm of The Hut Group (THG plc), a British ecommerce conglomerate listed on the London Stock Exchange. It powers complete direct to consumer online stores for global brands, combining a storefront builder, order management, fulfilment from warehouses across the United Kingdom, United States, Australia and the European Union, digital marketing, content production and translation. Brands use THG Ingenuity as the technology, logistics and operations backbone of their own branded stores.

Data and cookies collected by THG Ingenuity

Because THG Ingenuity runs the entire storefront on the brand domain, it processes a broad set of personal data: account and identity information, billing and shipping addresses, payment tokens, full order and return history, device and browser metadata, IP address, page views, clickstream and basket events, A/B test assignments, marketing attribution identifiers and behavioural segments. Typical cookies include thg_visitor_id, thg_session_id, thg_cart, thg_ab_test, _thg_consent and various payment and fraud prevention tokens.

GDPR and ePrivacy implications

Most THG Ingenuity cookies fall outside the strict necessity exemption of Article 5(3) of the ePrivacy Directive and the German TDDDG, so they require prior informed consent before being set. The brand acts as data controller for its customers and THG Ingenuity acts as processor under Article 28 GDPR, requiring a written data processing agreement, documented sub processors, security measures and assistance with data subject requests. Behavioural profiling and personalisation also trigger transparency obligations under Articles 13 and 14 GDPR.

Consent requirements and legal basis

Order fulfilment, payment processing and core account functions can rely on contract performance under Article 6(1)(b) GDPR and on the strict necessity exemption for the corresponding cookies. Analytics, A/B testing, marketing tags, retargeting, personalisation and behavioural segmentation require prior, freely given, specific, informed and unambiguous consent under Article 6(1)(a) GDPR and Article 5(3) ePrivacy. Consent must be collected through a compliant banner before any non essential THG script or pixel loads.

Cross border data transfers and practical compliance steps

THG Ingenuity hosts primarily in the United Kingdom with United States and EU Frankfurt regions for global brands. Transfers from the EU to the UK rely on the European Commission adequacy decision adopted in 2021 and subject to periodic review, while transfers to the United States rely on Standard Contractual Clauses and, where applicable, the EU US Data Privacy Framework. Practical steps include signing the THG data processing agreement, mapping sub processors, deploying a consent management platform that blocks non essential tags, configuring data retention, and documenting transfer impact assessments.