Personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We only collect personal data relevant to the type of transactions or interactions that you have with Lumiescents. For example, we may collect, use, store and transfer personal data about you as follows:

• Identity Data such as first name, maiden name, last name, username or similar identifier, title, date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  
  We do not store credit card details nor do we share financial details with any 3rd parties
  
  
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you (such as when you join as a Lumiescents Customer) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with member services and benefits). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
  • register with Lumiescents on our website.
  • purchase products through our website
  • subscribe to our member services or newsletters;
  • request marketing to be sent to you;
  • enter or complete a competition, promotion or survey;
  • carry out any transactions on our website;
  • give us some feedback or leave reviews.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Cookies can be used to show you relevant Lumiescents content on social media services or other websites – these are known as ‘retargeting’ or ‘advertising’ cookies. For more information on the cookies we use and how you can control your cookie preferences see our cookie policy.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests as set out in the Glossary at the end of this policy (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you have provided your consent to us to use your personal data in a certain way such as direct marketing by email.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.

We may also process your personal data without your knowledge or consent, in compliance with this policy, where this is required or permitted by law.

Purpose/Activity:
To register you as a new customer

Type of data:
a) Identity; b) Contact; c) Profile; d) Usage; e) Marketing and Communications; f) Technical

Lawful basis for processing including the basis of legitimate interest:
Performance of a contract with you.

Purpose/Activity:
To process and deliver your order including:

1. Manage payments, fees and charges
2. Collect and recover money owed to us

Type of data:
a) Identity; b) Contact; c) Financial; d) Transaction

Lawful basis for processing including basis of legitimate interest:

1. Performance of a contract with you
2. Necessary for our legitimate interests (to recover debts due to us)

Purpose/Activity:
To manage our relationship with you which will include:

1. Notifying you about changes to our terms or privacy policy
2. Asking you to leave a review or take a survey

Type of data:
a) Identity; b) Contact; c) Profile; d) Marketing and communications

Lawful basis for processing including basis of legitimate interest:

1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity:
To enable you to partake in research, a prize draw, competition or complete a survey

Type of data:
a) Identity; b) Contact; c) Profile; d) Usage; e) Marketing and communications

Lawful basis for processing including basis of legitimate interest:

1. Performance of a contract with you
2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:
a) Identity; b) Contact; c) Technical

Lawful basis for processing including basis of legitimate interest:

1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
2. Necessary to comply with a legal obligation

Purpose/Activity:
To deliver relevant and personalised website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data:
a) Identity; b) Contact; c) Profile; d) Usage; e) Marketing and Communications; f) Technical

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:
a) Technical; b) Usage

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity:
To promote the products and services of Lumiescents and analyse its impact on the world of work (including making suggestions and recommendations to you about goods or services that may be of interest to you)

Type of data:
a) Identity; b) Contact; c) Technical; d) Usage; e) Profile

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We may use your personal data to provide you with information about our services and/or products, which we consider may be of interest to you. Where we do this via email, we will not do so without your prior consent except for when you have previously purchased goods or services from us, in which case, you will receive marketing from us unless you have told us that you do not wish to receive that marketing.

You can update your preferences of how and what we communicate to you at any time by emailing opt-out@lumiescents.co.uk and checking or unchecking relevant boxes to adjust your marketing preferences.

OPTING OUT OF DIRECT MARKETING

You can opt out of receiving email communication from Lumiescents by clicking the unsubscribe button at the bottom of any email which will then give you an option to unsubscribe from all emails. Alternatively you can call the customer services team on +44 (0)141 354 8877, or notify us via our Contact Us form. It may take up to 21 days for the changes to come into effect.

THIRD-PARTY MARKETING

We will never sell or share your personal data to third parties for the purposes of marketing.

COOKIES

We collect and use your personal information by using cookies on our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

We do not sell your personal data to other organisations. We may have to share your personal data for the purposes set out in this privacy policy with the following.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In general the personal data that we collect from you will be stored at a destination within the UK or European Economic Area (EEA). However we may also transfer your data outside the EEA.

Please note that some countries outside of the EEA have a lower standard or protection for personal data, including lower security requirements and fewer rights for individuals. Where your personal data is transferred, stored and/or otherwise processed outside the EEA, we will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this policy.

Unfortunately, no transmission of your personal data over the internet can be guaranteed to be 100% secure.

We take care to ensure the security of your personal data in use, storage and transmission and that it is only accessed by verified persons who have the necessary authority. All of our people who have access to your personal data are obliged to respect the confidentiality of this information and we deliver training to make sure this happens.

Any payment transactions will be encrypted using SSL technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal data from our records seven years after the date it was collected unless different retention periods apply, for example we will keep member data for 15 years after membership expiry in order to comply with requests for verification of membership status that are made to us. However, if before that date (i) your personal data is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove or anonymise your personal data from our records at the relevant time.

Where we anonymise your personal data (so that it can no longer be associated with you) we may use this information for research or statistical purposes indefinitely without further notice to you.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

How to control what we send you

If you would like to unsubscribe from the Lumiescents newsletter please email us at opt-out@lumiescents.co.uk,  You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 72 hours for this to take place.

Your legal rights

We want to ensure that you remain in control of your personal data. You can contact our customer services team at any time by email (dataprotection@lumiescents.co.uk) or telephone (+44 (0)141 354 8877) if you wish to exercise any of your rights. Please provide your full name, membership number (if applicable), contact telephone number and email address.

You have the right to:

Request access to your personal data (commonly known as a “data 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 subject to any exceptions that apply.

To assist us in processing your request, you will need to provide details of the information sought. Please describe, in as much detail as possible, the information you wish to have access to and if appropriate, any dates relevant to the information sought.

Request correction of the personal data that we hold about you. If you believe our records of your personal data are inaccurate you can ask us to update these records, though we may need to verify the accuracy of the new data you provide to us.

If you have an online account with us, you can update your personal data and marketing preferences by making amendments in the ‘My Profile’ section of our website.

Request erasure of your personal data. You can ask us to delete personal data where there is no good reason for us continuing to process it, 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 erasure request for specific legal reasons which will be notified to you, if applicable, at the time of your request or as soon as possible thereafter. We may also anonymise your data rather than delete it.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

Withdraw consent at any time where we are relying on consent to process your personal 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.

If you would like to opt out from receiving marketing messages from us, please see section above on OPTING OUT.

WHAT WE WILL NEED FROM YOU

We will 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.

TIME LIMIT TO RESPOND

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

THIRD-PARTY LINKS

Our websites 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.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 14 March 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

CONTACT DETAILS

Our full details are:
Full name of legal entity: Lumiescents Ltd
Email address: dataprotection@lumiescents.co.uk
Postal address: 272 Bath Street, Glasgow, G2 4JR
Telephone number: +44 (0)141 354 8877

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority (www.ico.org.uk) if you think your data protection rights have been breached by us. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

LAWFUL BASIS

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Lumiescents Group acting as joint controllers or processors who provide IT and system administration services and undertake reporting.

EXTERNAL THIRD PARTIES

• Service providers acting as processors to provide elements of services for us. We have contracts in place with our data processors which means that they will hold your data securely and cannot do anything with your personal data unless we have instructed them to do it.
• Service providers acting as processors based in the United Kingdom and South Africa who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and Ireland who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, Ireland, Singapore and United Arab Emirates who require reporting of processing activities in certain circumstances.
• Where we partner with other organisations we may also share information with them (for example if you register to attend an event jointly held by us and another organisation). We will only share information where necessary and we will make sure to notify you first.

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number. Cookies can help a website to arrange content to match your preferred interests more quickly and are used by most major websites. Cookies cannot be used by themselves to identify you. Click here to find out more about cookies.

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled. Please click here to find out how to disable/enable cookies

4.1
Our website also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help our Websites analyse how users use the sites. The information generated by the cookie about your use of our Websites (including your IP address) will be transmitted to and stored by Google on servers in the United States.

4.2
Google will use this information for the purpose of evaluating your use of our Websites, compiling reports on Website activity for Website operators and providing other services relating to Website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

By using our Websites, you consent to the processing of data about you by Lumiescents, its subsidiaries and Google in the manner and for the purposes set out above.

Lumiescents Cookie Policy
March 2020